LAST UPDATED: FEBRUARY 2019
A. WHO ARE WE?
This website at cms-holbornasia.law (the “Website”) is owned and operated by Holborn Law. Please see the Legal Information page for information about Holborn Law.
Holborn Law are data controllers of the personal information collected on this Website.
Holborn Law are located at the following address:
7 Straits View
Marina One East Tower
“Personal Information” is information about you which can be used alone, or combined with other information, to identify you personally.
C. HOW, WHEN AND WHY DO WE COLLECT AND USE PERSONAL INFORMATION?
1. Legal grounds for collection and use of Personal Information
We will only collect, use and otherwise handle your Personal Information on the Website when it is necessary for our legitimate interests in connection with operating the Website, in particular:
- responding to your queries;
- carrying out direct marketing;
- providing services and/or information to you;
- transmitting Personal Information within Holborn Law for internal administrative purposes;
- hosting and maintaining our Website;
- providing technical support to you;
- preventing and detecting fraud and other criminal offences; and/or
- ensuring network and information security, as long as, in each case, these interests are in line with applicable law and your legal rights and freedoms; where you have agreed to this for specified, explicit and legitimate purposes; and/or where this is necessary for legal obligations which apply to us.
2. How we use Personal Information that you provide to us
- Contact Forms - we may collect your Personal Information which you choose to provide when you fill in forms on our Website. This may include, for example, your name, position, company, contact details (such as business email, telephone number and business address) and your personal preferences, choices and requirements specific to particular requests or services. We may use this Personal Information to respond to your queries, and/or provide the services and/or information that you have requested.
- Events - if you register for one of our events, we will share your name, professional title and your professional address with other people that are attending the same event.
- Marketing – where you have provided us with your contact details, we may contact you by telephone or by post for marketing purposes relating to our services, our Website, and/or to research opinion on proposed legal or business developments where legally permitted to do so, unless you let us know that you do not want to receive this type of marketing. We will only contact you for these marketing purposes by electronic means (email or SMS) where you have agreed to this. Your agreement to the use of your Personal Information for these purposes is optional and if you fail to provide your agreement, your visit to and use of the Website will not be affected.
Marketing Opt-Out - you are entitled to opt-out from receipt of marketing communication at any time and free of charge by using the “unsubscribe” option included in any marketing e-mail or other marketing material received from us.
We may also use any Personal Information that you provide to us:
- where legally permitted for specific purposes made clear at the point of collection on particular pages of our Website; and/or
- where we otherwise have legal grounds for collection and use of your Personal Information as explained in more detail above.
If you choose not to provide Personal Information requested by us, we may not be able to provide you with the information and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the Personal Information. Aside from this, your visit to the Website will remain unaffected.
4. Information from other sources
Where permissible under applicable local laws, we may combine information that you have provided to us with other information that we already hold about you and which we have collected for a compatible purpose.
D. HOW AND WHEN DO WE SHARE INFORMATION WITH THIRD PARTIES?
Some services that we provide require the involvement of third parties. We have carefully selected these third parties and taken steps to ensure that your Personal Information is adequately protected.
1. Google Analytics
This Website uses Google Analytics, a web analysis service provided by Google Inc. ("Google"). Google Analytics works using cookies.
Google Analytics cookies collect your IP address, however because IP anonymisation is used on this Website, your IP address will be shortened (and therefore anonymised) as soon as technically possible and before it is stored or otherwise used in connection with Google Analytics.
The anonymisation process takes place within the European Union or the European Economic Area, except in exceptional cases, where your full IP address may be sent to a Google server in the U.S.A. and shortened there.
We use the information collected by Google Analytics cookies to find out about how visitors use our Website.
The IP address sent by your browser in connection with Google Analytics will not be combined by Google with other data.
You can prevent Google Analytics cookies from being stored by setting your browser software accordingly (see our Cookie Notice for further information). However, please note that you may not then be able to make full use of all the Website's functions.
You can also opt-out of Google Analytics by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
2. Sharing within Holborn Law and to Service Providers
When Holborn Law intends to use your Personal Information for a new purpose, they will let you know about this.
We will let you know if we need to transfer your Personal Information to any third party service providers located outside of the EEA.
3. Sharing with other third parties
We may also provide your information to other third parties such as regulators and law enforcement agencies, where we are required by law to do so, where necessary for the purposes of preventing and detecting fraud, other criminal offences and/or to ensure network and information security.
E. INTERNATIONAL TRANSFERS
The transfer of your Personal Information within Holborn Law may involve your Personal Information being sent outside of Singapore and the EEA (where our website is hosted), to locations that may not provide the same level of protection as those where you first provided the information.
However, we will only transfer your Personal Information outside of Singapore and the EEA:
- where we have put in place appropriate safeguards, for example by using a contract for the transfer which contains specific data protection provisions that have been adopted by the relevant data protection authority in Singapore and the EEA.
- where you have consented to this, or there is another legal basis on which we are entitled to make the transfer.
F. HOW LONG DO WE STORE PERSONAL INFORMATION?
For more information on how long cookies are stored, please refer to our Cookie Notice.
Our Website is hosted on servers in the EEA. We employ appropriate security measures to help protect your Personal Information and guard against access by unauthorised persons. Information storage is on secure computers in a locked and certified information centre and information is encrypted wherever possible. We undergo periodic reviews of our security policies and procedures to ensure that our systems are secure and protected. However, as the transmission of information via the Internet is not completely secure we cannot guarantee the security of your information transmitted to our Website.
I. YOUR RIGHTS
If you wish to:
- access, confirm, correct, rectify, update, supplement, anonymise, block, restrict or delete your Personal Information;
- object to our use of your Personal Information;
- if you have any questions about our processing of your Personal Information; or
- if you would like to transfer your Personal Information from us to another person or business, please email [email protected]
We will provide you with all rights in relation to your Personal Information to which you are entitled under applicable law. If you are unhappy with the way that we have handled your Personal Information, you can make a complaint to the authority responsible for data protection in the country that you are based. Contact details are typically available online, or alternatively you may contact us for assistance.
J. HOW TO CONTACT US