Legal Notices

Nothing in this website is aimed to be legal advice, and shall not be taken as one. If you require legal advice, please get in touch with us.

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Citil & Guner respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or deal with us, and tell you about your privacy rights and how the law protects you.

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1. Important information and who we are

This privacy policy gives you information about how Citil & Guner collects and uses your personal data belonging to you or your personnel in the context of providing legal services to you or your business, through your use of the firm's website and through any of the other ways we interact, as set out in more detail in paragraph 3 below.

The firm's website is not intended for children, and we do not knowingly collect data relating to children.

Controller

Citil & Guner Ltd is the controller and responsible for your personal data (collectively referred to as Citil & Guner, we, us or our in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights (Paragraph 9), contact us using the information set out in the contact details section (Paragraph 10).

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2. The personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you:

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2.1. Clients

· Identity Data includes first name, last name, any previous names, username or similar identifier, passport number, date of birth, gender, place of birth, photo ID, ID number, and signature.

· Contact Data includes email address, phone number, work number and work address.

· Professional Data includes title, name of the workplace.

· Financial Data includes bank account and payment card details.

· Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.

· Usage Data includes information about how you interact with and use our website, products and services.

In certain circumstances, our collection of the different categories of data set out above may include the collection of Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also may collect Criminal Convictions and Offences Data.

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2.2. Applicants

If you apply for a job with us, including if you proceed to the onboarding stage having been successful in your application:

· Identity Data includes first name, last name, any previous names, username or similar identifier, passport number, date of birth, gender, place of birth, photo ID, ID number, and signature.

· Contact Data includes email address, phone number, work number and work address.

· Professional Data includes title, qualifications, languages, education and employment history.

· Usage Data includes information about how you interact with and use our website, products and services.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of our engagement with you (as set out in our engagement letter and terms of business), and you fail to provide that data when requested, we may not be able to perform the services set out in the engagement letter.

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2.3. Online visitors

· Identity Data includes first name and last name.

· Contact Data includes email address, phone number, work number and work address.

· Professional Data includes title, name of the workplace.

· Usage Data includes information about how you interact with and use our website, products and services.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

If you fail to provide personal data

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3. How is your personal data collected?

We use different methods to collect data from and about you including:

· In the process of carrying out work for you (or your business) where we will in almost all instances act as a controller. In very limited circumstances we may act as a processor in which case we will let you know and ensure that an appropriate contract is put in place.

· When we communicate with you by email or other electronic correspondence, by telephone or using video conferencing software, you may give us your Identity, Contact, and Professional Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

· make a request for our services;

· apply for a job;

· make a request for us to contact you;

· provide us with feedback.

· Networking (for example, at in-person or virtual events).

· Through your use of our guest Wi-Fi service.

· By virtue of our access to CCTV footage.

· Otherwise through providing our legal services and operating our business.

We also collect data from and about you via our website:

· Through your actions (for example, when submitting a form)

· Through automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. This would be by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

· Through third parties or publicly available sources. We will receive personal data about you from various third parties and public sources.

· Technical Data is collected from analytics providers such as Google based outside the UK; advertising networks based inside or outside the UK; and search information providers based inside or outside the UK;

· Identity and Contact Data from publicly available sources based inside or outside the UK.

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4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

· Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

· Legal obligation: Where we need to comply with a legal obligation to which we are subject.

· Legitimate interests: Where it is necessary for our legitimate interests as a legal services provider (or those of a third party) and your interests and fundamental rights do not override those interests. These legitimate interests include our interests in managing our relationship with our clients, prospective clients and their staff, hosting clients and others at our offices, hosting virtual and in-person events and ensuring appropriate standards and compliance with policies, practices or procedures.

· Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

· Where processing of "special category data" is necessary in the context of legal claims or where another legal ground other than explicit consent is available to us under relevant data protection legislation.

· Where our legal services require us to process "special category data" and where we have obtained your explicit consent to do so. If we seek and obtain your consent, you may withdraw it at any time.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use

To check whether we can act for you as a new or existing client or across from you as a counter party or other third party on a matter involving a new or existing client, and carry out all of our regulatory compliance requirements, including conflicts of interest, anti-money laundering, anti-terrorism, sanctions, fraud and background screening.

Type of Data

Identity; Contact; Financial; Professional; Technical Data; Usage Data

Lawful Basis

Performance of a contract with you; Necessary to comply with a legal or regulatory obligation; Necessary for our legitimate interests (to detect and prevent the commission of fraud, money laundering and terrorism offences)

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Purpose/Use

To deliver our services to you including engaging service providers, managing payments, fees and charges and collecting and recovering money owed to us.

Type of Data

Identity; Contact; Financial; Transaction; Professional; Technical Data; Usage Data; Special Category of Personal Data

Lawful Basis

Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to recover debts due to us)

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Purpose/Use

To manage our relationship with you which will include notifying you about changes to our terms or privacy policy.

Type of Data

Identity; Contact

Lawful Basis

Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated)

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Purpose/Use

To review your job application and proceed with the onboarding process.

Type of Data

Identity; Contact; Professional; Technical Data; Usage Data; Special Category of Personal Data

Lawful Basis

Performance of a contract with you; Necessary to comply with a legal or regulatory obligation; Necessary for our legitimate interests

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Purpose/Use

To communicate with you.

Type of Data

Identity; Contact; Professional; Technical Data; Usage Data

Lawful Basis

Performance of a contract to with you; Necessary for our legitimate interests

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Purpose/Use

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Type of Data

Identity; Contact; Technical Data; Usage Data

Lawful Basis

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); Necessary to comply with a legal obligation

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Purpose/Use

To use data analytics to improve our website, products and services, marketing, customer relationships and experiences.

Type of Data

Technical Data; Usage Data

Lawful Basis

Necessary for our legitimate interests (to define types of clients and customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of this website may become inaccessible or not function properly.

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5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table "Purposes for which we will use your personal data" above.

· Internal Third Parties.

· External Third Parties.

· Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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6. International transfers

We may transfer your data outside the UK.

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that adequate safeguards are implemented.

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that one or both of the following safeguards are in place:

· We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.

· We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us at personaldata@citilguner.com or link to Contact details (paragraph 10).

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7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

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8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In general, we delete personal information when:

· the purpose for processing of personal data has been fulfilled or the contractual relationship with our client, you or your company has ended;

· all mutual claims have been fulfilled; and

· there are no other legal obligations to keep the personal data nor legal bases for further processing.

Typically, we keep personal data about our client for 10 years after the completion of the matter, unless there are specific circumstances compelling us to otherwise.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

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9. Your legal rights

You have rights under data protection laws in relation to your personal data to:

· Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

· Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

· Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

· You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting out of marketing in paragraph 4 for details of how to object to receiving direct marketing communications).

· Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

· Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

· If you want us to establish the data's accuracy;

· Where our use of the data is unlawful, but you do not want us to erase it;

· Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

· You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

· Email address: personaldata@citilguner.com

· Postal address: Suite 2.47, 14 Gray’s Inn Road, London, United Kingdom, WC1X 8HN

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11. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 25 December 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

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13. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.