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GDPR PRIVACY POLICY



14 June 2023,
Pogust Goodhead (a trading name of PGMBM Law Limited – SRA License Number
512898)

Your privacy is important to Pogust Goodhead (a trading name of PGMBM Law
Limited). This Privacy Policy explains how we collect, use and process your
personal data, and how we comply with our legal obligations. We are committed to
protecting and safeguarding your data privacy rights and comply with the General
Data Protection Regulation (EU 2016/679), the “GDPR”.

We also comply with the Brazilian Lei Geral de Proteção de Dados (Lei n. 13.853,
2019), the “LGPD”.

The term “Personal Data” means any information relating to you, who can be
identified, directly or indirectly, by reference to other information that we
have access to. Where services are provided to you by other entities within
Pogust Goodhead (referred to this Privacy Policy as “Pogust Goodhead” or “us”),
the entity providing the service will be responsible for your personal data.


COMPLAINTS HANDLING POLICY


FAQS SURROUNDING DATA AND PRIVACY:


WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT?

The information described below is in addition to any personal data we are
required by law to process in any given situation.

CLIENT DATA: When joining a litigation case, we may collect contact and identity
details such as name, telephone number, email, postal addresses, date of birth,
payment details, tax residence information, copies of photo identifications such
as your driving license and/or passport/identity card, information about
nationality/citizenship/place of birth, your national identification number,
identity verification documents and signature in order to comply with our legal
and regulatory obligations.

We may also collect special categories of more sensitive data such as health,
physical and mental health information, depending on the necessity of the legal
case.

Where relevant, we may also hold additional information that someone in your
organisation has chosen to disclose to us. If we need any additional personal
data for any reason, we will inform you.

SUPPLIER DATA: We may collect your contact details or the contact details of
individuals within your organisation  (such as names, telephone numbers, email
and/or postal addresses). Depending on the circumstances, we may also collect
bank details for payment purposes.

JOB APPLICANT DATA: We may collect your C.V., work history, name, contact
details, details of professional status, records and qualifications, referees,
salaries and social media profiles, if you decide to apply for a job within our
company.

PEOPLE WHOSE DATA WE RECEIVE FROM JOB APPLICANTS AND STAFF, SUCH AS REFEREES AND
EMERGENCY CONTACTS: To ask for a reference, we may need the referee’s contact
details (such as name, email address and telephone number). We will also need
these details if a job applicant or a member of our staff has put you down as
their emergency contact so that we can contact you in the event of an accident
or an emergency.

WEBSITE USERS: We collect a limited amount of data from our website users which
we use to help us  improve your experience when using our website and to help us
manage the services we provide. This includes information such as how you use
our website, including the time and duration of visit, your CPU speed, the
operating system/platform you are using, the frequency with which you access our
website, your browser type, the location you view our website from, and the
language you choose to view it in.  We may record site traffic patterns,
“clickstreams”, and the times that our website is most popular. If you contact
us or submit an application for a consultancy via the website, we will collect
any information that you provide to us, for example, your name and/or contact
details. We may use that information to assess and respond to your application
or enquiry.

HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect personal data through the website in two ways:

 1. Personal data that we receive directly from you
 2. Personal data that we collect automatically when you use our website.

 * DIRECTLY FROM YOU: We receive personal data directly from you where you
   contact us proactively, usually via an online form, by phone or email; and/or
 * Where we contact you, whether by phone, email or any other form of
   communication.

WEBSITE USERS: When you visit our website, there is certain information that we
may automatically collect, whether or not you decide to use our services. This
includes your IP address, the date and the times and frequency with which you
access the website and the way you browse its content. We will also collect data
from you when you contact us via our website, for example, when you submit a
query.

We collect your data automatically via cookies, in line with cookie settings in
your browser. You can also opt out of non-essential cookies through the cookies
settings on our homepage.

HOW DO WE USE YOUR PERSONAL DATA?

The personal data that we collect is utilised to enhance our professional
relationship with you. These are our legal bases for processing data under
Articles 6 and 9 of the GDPR.

USING CLIENT DATA: Below are the various ways in which we use your data in order
to ensure the smooth running of our agreements and dealings with you:

 1. Professional services activities – Processing your data in order to store
    your details (and updating them when necessary) on our database, so that we
    can contact you in relation to our relevant activities; and keeping records
    of our conversations and meetings, so that we can provide targeted services
    to you and in order to comply with our legal and regulatory obligations.

We may use your personal data for these purposes if we deem this to be necessary
for our legitimate interests.

 2. To help us to establish, exercise or defend legal claims – In more unusual
    circumstances, we may use your personal data to help us to establish,
    exercise or defend legal claims.

USING SUPPLIER DATA: We will only use your information:

 1. To store (and update when necessary) your details on our database, so that
    we can contact you in relation to our agreements or our dealings with you;
 2. To facilitate our payroll and invoicing processes, for example, in relation
    to consultants or self-employed contractors; and
 3. In more unusual circumstances, to help us to establish, exercise or defend
    legal claims.

If you are not happy about this, you have the right to opt out of receiving
marketing material from us and can find out more about how to do so by
emailing mydata@pogustgoodhead.com.

PEOPLE WHOSE DATA WE RECEIVE FROM JOB APPLICANTS AND STAFF, SUCH AS REFEREES,
EMERGENCY CONTACTS AND DEPENDENTS:

We will only use the information about you for the following purposes:

 * If a Job Applicant or staff member put you down on our form as an emergency
   contact, we will contact you in the case of an accident or emergency
   affecting them; or
 * If you were put down by a Job Applicant as a referee, we will contact you in
   order to take up a reference; or
 * If you were put down by a staff member as a next of kin or dependent, we will
   store your personal data to ensure the personnel records of the staff member
   are correct and disclose your information to the relevant benefits provider.

If you are not happy about this, you have the right to object and can find out
more about how to do so by emailing mydata@pogustgoodhead.com.

WEBSITE USERS: We use your data to help us to improve your experience of using
our website, for example, by analysing your recent search criteria to help us to
present information to you that we think you will be interested in.

WHAT ARE OUR LEGAL BASES FOR PROCESSING YOUR DATA?

LEGITIMATE INTERESTS

We can process your data where it is necessary for the purposes of the
legitimate interests pursued by us or by a third party, except where such
interests are overridden by your interests or fundamental rights or freedoms,
which require protection of personal data. These interests were identified by
carrying out a Legitimate Interests Assessment.

You have the right to object to us processing your personal data on this basis.
If you would like to know more about how to do so, please
contact mydata@pogustgoodhead.com.

CLIENT DATA

To ensure that we provide you with the best service possible, we use and store
your personal data and/or the personal data of individual contacts at your
organisation as well as keeping records of our conversations and meetings.

We think this is reasonable – we deem these uses of your personal data to be
necessary for our legitimate interests in order to carry out our business
activities.

We have to make sure our business runs smoothly, so that we can carry on
providing services. We therefore also need to use your data for our internal
administrative activities, such as invoicing where relevant.

We have our own obligations under the law, which is a legitimate interest of
ours to insist on meeting. If we believe in good faith that it is necessary, we
may therefore share your data in connection with crime detection or tax
collection.

SUPPLIER DATA

We use and store the personal data of individuals within your organisation in
order to facilitate the receipt of services from you as one of our suppliers.
Where you are a sole trader, we also hold your financial details, so that we can
pay you for your services.

We deem all such activities to be necessary within the range of our legitimate
interests as a recipient of your services.

PEOPLE WHOSE DATA WE RECEIVE FROM JOB APPLICANTS AND STAFF, SUCH AS REFEREES AND
EMERGENCY CONTACTS

If you have been put down by a job applicant or a member of Pogust Goodhead as
one of their referees, we use your personal data in order to contact you for a
reference.

If a staff member has given us your details as an emergency contact, we will use
these details to contact you in the case of an accident or emergency. We have a
legitimate interest to store this data and use it in appropriate circumstances
on behalf of our staff.

If a staff member has given us your details as a dependent or a next of kin, we
will use your personal data as appropriate for the purpose of benefits or
employment rights.

We have a legitimate interest to store this data and use it in appropriate
circumstances on behalf of our staff.

CONSENT

In certain circumstances, we are required to obtain your consent to the
processing of your personal data in relation to certain activities. Depending on
exactly what we are doing with your information, this consent will be opt-in
consent or soft opt-in consent. In all cases where we rely on consent:

 * You have to give us your consent freely, without us putting you under any
   type of pressure; and
 * You have to know what you are consenting to – so we’ll make sure we give you
   enough information.

We will keep records of the consents that you have given in this way.

In some cases, we will be able to rely on soft opt-in consent. We are allowed to
market products or services to you which are related to the services we provide
as long as you do not actively opt-out from these communications.

As we have mentioned, you have the right to withdraw your consent to these
activities. You can do so at any time by emailing mydata@pogustgoodhead.com

LEGAL OBLIGATIONS

We also have legal and regulatory obligations that we need to comply with.

If we believe in good faith that it is necessary, we may share your data in
connection with crime detection or tax collection.

We also may share your data with regulatory agencies or other relevant bodies in
order to comply with our regulatory obligations.

We will keep records of your personal data (including personal data contained in
communications and calls) in accordance with our legal and regulatory right and
obligations.

CONTRACT

We can process your data where we are carrying out necessary steps in relation
to a contract to which you are party or prior to you entering into a contract,
for example, because you wish to instruct us to carry out legal services for
you.

ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS

Sometimes it may be necessary for us to process personal data and, where
appropriate and in accordance with local laws and requirements, sensitive
personal data, in connection with exercising or defending legal claims.

This may arise for example where we need to take legal advice in relation to
legal proceedings or are required by law to preserve or disclose certain
information as part of the legal process.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Where appropriate and in accordance with local laws and requirements, we may
share your personal data, in various ways and for various reasons, with the
following categories of people:

 * Any of our offices;
 * Individuals and organisations who hold information related to a Job
   Applicant’s reference or application to work with us, such as current or
   prospective employers and employment and recruitment agencies;
 * Tax, audit, regulatory bodies or other authorities, when we believe in good
   faith that the law or other regulation requires us to share this data (for
   example, because of a request by a tax authority, in connection with any
   anticipated litigation or in compliance with our legal and regulatory
   obligations);
 * Third party service providers (including suppliers) who perform functions on
   our behalf (including benefit providers such as pension providers, private
   medical insurance, dental insurance and childcare providers, external
   consultants, business associates and professional advisers such as lawyers,
   auditors and accountants, transport and distribution suppliers, technical
   support functions and IT consultants carrying out testing and development
   work on our business technology systems);
 * Third party outsourced IT and document storage providers where we have an
   appropriate processing agreement (or similar protections) in place;
 * Marketing technology platforms and suppliers (cookie data only); and
 * If Pogust Goodhead merges with or is acquired by another business or company
   in the future, we may share your personal data with the new owners of the
   business or company (and provide you with notice of this disclosure).

We do not sell any personally identifiable information provided to us to any
unrelated third party, but, as set out above, we may share it with related
entities or with unrelated third parties in connection with our own marketing
activities or the maintenance and operation of our site, or as may be legally
required. Please do not to send confidential or sensitive information to us
through this site.

HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

We are committed to taking all reasonable and appropriate steps to protect the
personal information that we hold from misuse, loss, or unauthorised access. We
do this by having in place a range of necessary technical and organisational
measures including but not limited to encrypted systems, to hold your personal
data securely in both electronic and physical form.

All our Partners, staff, third party services and cross borders who have or may
have access to your personal data, are instructed and subjected to
confidentiality obligations. We take all the appropriate measures to maximally
secure personal information and to deal with any suspected data breach.

HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

We will ordinarily process your data throughout the course of our interactions
and will then generally retain it for an appropriate amount of time after we
have parted ways, depending on local law requirements, type of data in question,
any overarching legal and regulatory, our legitimate business and
risk-management needs. We may, for example, be required to retain certain data
for the purposes of tax reporting or responding to tax queries.  In other
instances, there may be some other legal, regulatory or risk-management
requirements to retain data, including where certain data might be relevant to
any potential litigation (bearing in mind relevant limitation periods).

In determining the appropriate retention period for various types of personal
data, in addition to ensuring that we comply with our legal, regulatory and
risk-management obligations, 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 need to process your
personal data and whether we can achieve those purposes through other means, and
the applicable legal requirements.

HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO
US?

You retain various rights in respect of your data, even once you have given it
to us. These are described below:

 * Right to be informed
 * Right to access*
 * Right to rectification
 * Right to erasure
 * Right to restrict processing
 * Right to data portability
 * Right to object
 * Rights in relation to automated decision making and profiling
 * *Right to access: This right enables you to ask us to confirm what
   information we hold about you at any time, and request us to modify, update
   or delete such information. This is called Data Subject Access Request (SAR
   or DSAR).We may ask you to verify your identity and for more information
   about your request. The SAR has no costs for you, unless your request is
   “manifestly unfounded or excessive”. If you request further copies of this
   information from us, we may charge you a reasonable administrative cost where
   legally permissible. Where we are legally permitted to do so, we may refuse
   your request. If we refuse your request, we will always tell you the reasons
   for doing so.

To get in touch or exercise any of these rights, please contact our Data
Protection Officer, at mydata@pogustgoodhead.com. We will seek to deal with your
request without undue delay, and in any event within one month (subject to any
extensions to which we are lawfully entitled). Please note that we may keep a
record of your communications to help us resolve any issues which you raise.

TRANSFERRING YOUR DATA INTERNATIONALLY

In order to provide you with the best service and to carry out the purposes
described in this Privacy Policy, your data may be transferred:

 * To third parties (such as regulatory authorities, advisers or other suppliers
   to Pogust Goodhead)
 * To overseas suppliers; and
 * To a cloud-based storage provider.

We want to make sure that your data is stored and transferred in a way which is
secure. We will therefore only transfer data outside of the United Kingdom and
the European Economic Area (EEA) where it is compliant with data protection
legislation and the means of transfer provides adequate safeguards in relation
to your data, for example:

 * By way of data transfer agreement, incorporating the current standard
   contractual clauses adopted by the European Commission for the transfer of
   personal data by data controllers in the UK or EEA to data controllers and
   processors in jurisdictions without adequate data protection laws;
 * Transferring your data to a country where there has been a finding of
   adequacy by the European Commission in respect of that country’s levels of
   data protection via its legislation;
 * Where it is necessary for the conclusion or performance of a contract between
   ourselves and a third party and the transfer is in your interests for the
   purposes of that contract (for example, if we need to transfer data outside
   the EEA in order to meet our obligations under that contract if you are a
   client of ours); or
 * Where you have consented to the data transfer.

To ensure that your personal information receives an adequate level of
protection, we have put in place appropriate procedures with the third parties
we share your personal data with, to ensure that your personal information is
treated by those third parties in a way that is consistent with and which
respects the law on data protection.

COOKIES POLICY

WHAT’S A COOKIE?

Cookies are small text files that can be used by nearly all websites to make a
user’s experience more efficient. It allows the website to recognise that user’s
device and store some information about the user’s preferences or past actions.

HOW DO WE USE COOKIES?

This website uses cookies. We use cookies to personalise content and ads, to
provide social media features and to analyse our traffic. We also share
information about your use of our site with our social media, advertising and
analytics partners who may combine it with other information that you’ve
provided to them or that they’ve collected from your use of their services.

This site uses different types of cookies. Some cookies are placed by third
party services that appear on our pages.

Your consent applies to the  domain www.pogustgoodhead.com, and you can at any
time change or withdraw your consent from the Cookie Declaration on our website.

COMPLAINTS

You have the right to make a complaint at any time to the Information
Commissioner’s Office (ICO), the UK supervisory authority for data protection
issues, by calling their helpline on 0303 123 1113 or via their website
at https://ico.org.uk/global/contact-us/

If you have any questions about this privacy policy or how we handle your
personal information, please contact us at mydata@pogustgoodhead.com. 

As a data subject, you are entitled to contact a Data Protection Authority if
you have enquiries, concerns, or complaints regarding the processing of your
data:

 * United Kingdom: the Information Commissioner’s Office (“ICO”) is an
   independent regulatory body that enforces data protection laws in the UK. You
   may contact the ICO via their website or by calling +44 0303 123 1113.
 * Brazil: the National Data Protection Authority (Autoridade Nacional de
   Proteção de Dados) may be contacted via their website or by calling +55 (61)
   2025-8101.

To view our 2019 GDPR Privacy Policy, please click here.


CONTACT US

Whether you’re a client, journalist, NGO, political operative, or legal
professional, we’re always happy to talk. If you require any help or advice,
please get in touch with the Pogust Goodhead team.  If you are a client in the
Mariana dam disaster claim, please click here to be redirected to the client
portal.

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Pogust Goodhead (a trading name of PGMBM Law Ltd) SRA License Number 512898.

Pogust Goodhead is authorised and regulated by the Solicitors Regulation
Authority and complies with the Solicitors Code of Conduct, a copy of which can
be located here. VAT No: 974 7183 77.

© Copyright 2023 Pogust Goodhead. All rights reserved. Attorney Advertising.
Prior results do not guarantee a similar outcome.

Content does not constitute legal advice or the creation of an attorney-client
relationship. You should not act or rely on the basis of information on this
site without seeking the advice of an attorney.

PGMBM Nederland B.V., trading under the name Pogust Goodhead, is a limited
liability company registered at Chamber of Commerce (no. 83137718) with its
registered office at Herengracht 433, 1017 BR Amsterdam. Tax number is
NL862745470B01.

PGMBM Nederland B.V. is a Dutch law firm that has entered into a partnership
with the law firms PGMBM Law Ltd and PGMBM Ltd, with the purpose to cooperate in
accordance with section 5.2 of the Legal Profession Byelaw (in Dutch:
Verordening op de Advocatuur).

PGMBM Nederland B.V. focuses (as the other partners within the said partnership)
on collective actions. PGMBM Nederland B.V. is the contracting entity in
relation to services provided by lawyers working at PGMBM Nederland B.V.


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 * GDPR Privacy Policy
 * Privacy Policy
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 * Complaints Policy
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 * Terms & Conditions
 * GDPR Privacy Policy
 * Privacy Policy
 * Complaints Handling Policy
 * Complaints Policy
 * Rechtsgebiedenregister
 * Accessibility Policy
 * Trust Centre
 * Cookie Preferences

Pogust Goodhead (a trading name of PGMBM Law Ltd) SRA License Number 512898.
Pogust Goodhead is authorised and regulated by the Solicitors Regulation
Authority and complies with the Solicitors Code of Conduct, a copy of which can
be located here. VAT No: 974 7183 77.

© Copyright 2023 Pogust Goodhead. All rights reserved. Attorney Advertising.
Prior results do not guarantee a similar outcome.

Content does not constitute legal advice or the creation of an attorney-client
relationship. You should not act or rely on the basis of information on this
site without seeking the advice of an attorney.

PGMBM Nederland B.V., trading under the name Pogust Goodhead, is a limited
liability company registered at Chamber of Commerce (no. 83137718) with its
registered office at Herengracht 433, 1017 BR Amsterdam. Tax number is
NL862745470B01.

PGMBM Nederland B.V. is a Dutch law firm that has entered into a partnership
with the law firms PGMBM Law Ltd and PGMBM Ltd, with the purpose to cooperate in
accordance with section 5.2 of the Legal Profession Byelaw (in Dutch:
Verordening op de Advocatuur).

PGMBM Nederland B.V. focuses (as the other partners within the said partnership)
on collective actions. PGMBM Nederland B.V. is the contracting entity in
relation to services provided by lawyers working at PGMBM Nederland B.V.

 * Terms & Conditions
 * GDPR Privacy Policy
 * Privacy Policy
 * Complaints Handling Policy
 * Complaints Policy
 * Rechtsgebiedenregister
 * Accessibility Policy
 * Trust Centre
 * Cookie Preferences


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