OVERVIEW
MB Legal CJSC (also referred to below as the “Firm,” “we,” “us,” or “our“) is committed to safeguarding the privacy of visitors to https://mblegal.am (the “Website”), contacts for our clients and prospective clients, contacts for suppliers of goods and services to the Firm, candidates for employment or engagement, and any other individuals (collectively “you”) about whom the Firm obtains personal data (described below).
In this Privacy Policy, “Personal Data” means information that (either in isolation or in combination with other information held by the Firm) enables you to be identified as an individual or recognized directly or indirectly. With respect to California residents, references to “Personal Data” in this Privacy Policy means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, subject to certain exceptions set forth in the California Consumer Privacy Act.
Unless we specifically state otherwise, the Firm is the data controller in relation to any Personal Data that the Firm processes about you and is therefore responsible for ensuring that the systems and processes we use are compliant with data protection laws, to the extent applicable to us, including the, but not limited to, European Union General Data Protection Regulation, RA Law on the Personal Data Protection and the California Consumer Privacy Act of 2018.
This Privacy Policy sets out the principles governing the Firm’s use of Personal Data that we may obtain about you, how the Firm collects, uses, and otherwise processes your Personal Data as well as the rights that you have in relation to our processing of that information.
COLLECTION OF PERSONAL DATA
We collect personal data from a number of sources: (i) directly from you (e.g., when you contact us); (ii) in the course of our relationship with you (e.g., if we provide legal advice to you or in the course of corresponding with you); (iii) when you make your Personal Data public (e.g., if you make a public post on social media); (iv) when you visit our Website; (v) we may also receive Personal Data about you from third parties (e.g., courts, law enforcement authorities).
Although you are not required to provide any Personal Data while visiting our Website, you may choose to do so by completing requests for proposal forms, job application forms etc. Should you do so, we may, for example, keep a record of your name, surname, email address, and any other information you voluntarily provide to us.
Additionally, we may collect the following categories of Personal Data from you in the course of business, including through your use of the Website, when you contact or request information from us, when we provide services to you or receive services from you:
- Identification data: Name, surname, date of birth, passport details, bank details.
- Contact information: Your phone number(s), your email address, residence or registration address
- Job applicant data: Identification data and contact information, resumé and other data provided by you on our Website or online recruitment portal (e.g. staff.am).
- Transaction data: Personal data contained in documents, correspondence or other materials provided by you or relating to transactions conducted by our clients.
- Compliance data: Government identifiers, passports or other identification documents, dates of birth, beneficial ownership data, and due diligence data
- Cookie and device data: such as information about your visit of our Website, IP address, device identifier, browser type and version, operating system and network, location and time zone setting.
We may supplement the information that you provide to us with information that we receive or obtain from other sources, such as from our staff, clients, third parties with whom we interact, and publicly available sources (e.g., electoral poll, Datalex database).
USE OF PERSONAL DATA
We will only use your Personal Data if and to the extent that applicable law allows. The purposes for which we use Personal Data, and the legal bases for such processing, are as follows:
- To provide legal advice and administer our client relationships, we use Personal Data that you voluntarily submit to us on the Website or during the course of our engagement, regardless of the media used, such as identification data, contact details, and other data that we may process in connection with the provision of legal services.
- To provide relevant marketing, such as providing you with information about events or services that may be of interest to you including legal services, and legal updates. For this purpose, we use identification data and contact information. It is necessary for our legitimate interests to process this information in order to provide you with tailored and relevant marketing, updates and invitations.
- To address compliance and legal obligations, such as complying with the Firm’s tax reporting obligations, checking the identity of new clients and preventing money laundering and/or fraud we use identification data, transaction data, compliance data and device data. This processing is necessary for the purposes of complying with legal requirements that apply to the Firm. In addition, job applicant data and compliance data may be used as necessary to comply with legal, regulatory, and corporate governance requirements to which we are subject.
- To consider individuals for employment and contractor opportunities, we use job applicant data and compliance data. The processing is necessary for the purposes of managing recruitment and onboarding procedures.
- To improve our Website, we use cookie and device data. This processing is necessary for our legitimate interests to constantly monitor the functionality and user-friendliness of our Website and improve our online presence and services to you.
DATA SHARING
We may disclose your Personal Data in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality and professional secrecy. We may disclose your Personal Data to:
- legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
- accountants, auditors, lawyers and other outside professional advisors to the Firm, subject to binding contractual obligations of confidentiality.
DATA SUBJECT RIGHTS
Under certain circumstances and in compliance with applicable laws, you have the right to:
- Access. Subject to certain exceptions, you have the right to request a copy of the Personal Data we are processing about you, which we will provide to you in electronic form. At our discretion, we may require you to prove your identity before providing the requested information. If you require multiple copies of your Personal Data, we may charge a reasonable administration fee.
- Rectification. You have the right to require that any incomplete or inaccurate Personal Data that we process about you is amended.
- Deletion. You have the right to request that we delete Personal Data that we process about you, unless we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
- Restriction. You have the right to request that we restrict our processing of your Personal Data where:
– you believe such data to be inaccurate;
– our processing is unlawful; or
– we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it. - Portability. You have the right to request that we transmit the Personal Data we hold in respect of you to another data controller, where this is:
– Personal Data which you have provided to us;
– and we are processing that data on the basis of your consent or in order to perform our obligations under contract to you (such as to provide legal services). - Objection. Where the legal justification for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
- Withdrawing Consent. If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge
Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the personal information or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.
DATA SECURITY
We endeavour to implement technical and organisational security measures to safeguard the Personal Data in our custody and control. Such measures include, for example, limiting access to Personal Data only to our staff and authorised service providers on a need-to-know basis for the purposes described in this Privacy Policy, as well as other administrative, technical, and physical safeguards.
CHILDREN’S PRIVACY PROTECTION
We understand the importance of protecting children’s privacy in the interactive online world. This Website is not designed for or intentionally targeted at children 13 years of age or younger. It is not our policy to intentionally collect or maintain information about anyone under the age of 13.
DATA RETENTION
We will only retain your personal information for as long as necessary for the purposes for which that information was collected as set out in this Privacy Policy or for longer as required under any applicable legal, regulatory, accounting, or reporting requirements.
THIRD-PARTY WEBSITES
Our Website may contain links to other websites which are controlled by third parties. We also use social media sites, such as LinkedIn and Facebook and third-party platforms to host events, training and seminars. You should review the privacy policies of these external websites. We do not accept any responsibility for the information you provide on those websites or their collection and use of your personal information.
COOKIES AND OTHER TECHNOLOGIES
We use and engage certain providers to use cookies, web beacons, and similar tracking technologies (collectively, “cookies“) on our Website.
Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to a website. More information about cookies and how they work is available at All About Cookies.
Cookies on our Website are generally divided into the following categories:
- Necessary cookies: They help make a Website usable by enabling basic functions like page navigation and access to secure areas of the Website. The Website cannot function properly without these cookies.
- Analytical/Performance Cookies: These allow us to recognize and count the number of visitors to our Website and understand how such visitors navigate through our Website. These cookies are session cookies which are erased when you close your browser. We use Google Analytics, and you can see below for how to control the use of cookies by Google Analytics.
- Marketing cookies: These are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual visitor and thereby more valuable for publishers and third-party advertisers.
What are your options if you do not want cookies on your computer?
You can review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain Cookies. If you disable or delete certain Cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Website, and you may be required to re-enter your login details.
To learn more about the use of cookies for Google Analytics and to exercise choice regarding such cookies, please visit the Google Analytics Opt-out Browser Add-on.
CONTACT DETAILS
If you have any comments, questions or concerns about data privacy, including the processing of Personal Data carried out by us, or on our behalf, please visit our contact us form and send your request.
CHANGES TO THIS PRIVACY POLICY
We hope that this Privacy Policy can resolve any query or concern you raise about our use of your Personal Data. If you feel we have not handled your query or concern to your satisfaction you can contact us by sending an email to info@mblegal.am or by our contact us form.
We may occasionally update this Privacy Statement as our services and privacy practices change, or as required by applicable legal or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, the last update date is posted below, and we encourage you to review this Privacy Statement periodically to be informed of how we use your personal information.
Last updated: February 2024