ZAB VILGERTS SIA, registration number: 40203309933, legal address: Skanstes iela 7 k-1, Rīga, LV-1013, e-mail address: [email protected] (“we“, “our“, or “us“) is committed to protecting your privacy.
This privacy policy (“Policy”) explains how we collect and use information when you visit our websites at vilgerts.com (“Website”) or use our legal services (“Services”).
By communicating with us through the Website or our Services, you (“Client” or “you”) may be explicitly asked to confirm acceptance of this Policy. Reference in this Policy to “your Personal Data” means any information that can be used to directly or indirectly uniquely identify, contact or locate you as a private individual (“Personal Data”).
We process Personal Data under this Policy and in accordance with applicable legislation, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”) and other applicable European Union and national data protection laws.
This Policy describes how we process Personal Data in connection with:
- all matters related to our clients, former clients and potential clients, including, anti-money laundering (“AML”), know-your-customer (“KYC”) or international and national sanction screening (“Sanctions”) procedures;
- newsletters, events and other marketing initiatives we organize from time to time.
- Who is responsible for your data?
- We determine and are responsible for the processing of your personal information described in this Policy and for the purpose of the GDPR we are the data controller.
- Our Website may contain links to other websites. We are not responsible for these website’s privacy practices and encourage you to carefully read the privacy statements of each and every website you visit. This Policy does not apply to third-party websites and services.
- What kind of personal information we collect about you, on what legal basis and for how long?
- Most of your Personal Data described in the Policy is submitted to us by you. However, we may also collect and receive your Personal Data from other sources, public databases, governmental institutions, other clients or third parties, if necessary for the Conflict of Interest or AML check, or provision of legal services. If you are an opposing party, representative, or other third-party participant in a case dealt with by us, we will generally process your personal data in order to be able to represent our client in the case in question.
- We do not keep your personal data for any longer than is necessary to fulfill the purpose for which we collected it, or to comply with any legal, regulatory or reporting obligations or to assert or defend against legal claims.
- We will indicate to you if the provision of certain personal information is mandatory or optional. If you choose not to provide any information marked as mandatory, we may not be able to respond to your queries or provide you our Services.
- We limit the processing of your Personal Data to the scope of purpose for which the data was collected. In cases where the processing is based on your consent, you have the right to withdraw your consent to such processing at any time.
- Access to your Personal Data will be restricted to personnel who are required to process the Personal Data to fulfill their professional responsibilities and their duties.
- Table below sets out the categories of personal data we collect about our clients, potential clients, opposite parties or other parties involved in the case as well as subscribers to our newsletters, how we use that information, the lawful basis we rely on and criteria for storing Personal Data:
| Personal data categories |
Purpose |
Legal basis |
Data Retention Period |
| Information about the client (for natural persons – name, surname, identification code; for legal persons – company name, registration number, UBO), case details and information about the opposite party. |
Conflict of Interest check |
Legal obligation |
For the period of Conflict of Interest check. |
| Information about a natural person – name, surname, identification code in Latvia or date of birth, address, phone number, email address, personal ID document number, place of work, position, information about the payment for our services, including source of funds and type of business activity, information about PEP, if acting on behalf of a legal person – information about it’s UBO and way of control. Copy of ID card or passport. Information about a legal person – company name, registration number, legal address, phone number and email address. Copy of registration certificate and other establishment documents and information contained in them. |
KYC and Sanction screenings |
Legal obligation |
For the period of which we have a legal relationship with you and at least for 5 years after the termination of the Engagement Agreement. |
| Information related to the case and any information included in the case file, for example, information related to the business activities, employees or representatives of the client, opposite side, as well as personal data of other persons if processed by us while providing legal services, which can also include special (or sensitive) Personal Data. |
Provision of legal services |
Contractual necessity |
For the period of which we have a legal relationship with you and at least for 10 years after the termination of the Engagement Agreement. |
| Personal Data related to invoicing, including name, surname, email address, bank account and invoice details. |
Invoice management |
Contractual necessity |
Up to 10 years after the due date of the invoice. |
| Name, Surname, email address, category of legal services provided to you. |
Sending newsletters and other marketing materials. |
Your consent given on our Website when subscribing to our newsletters if you are not an existing client.
Our legitimate interest to perform direct marketing, maintain the client relationship and provide you with legal updates and other information related to your field of business if you are an existing client. |
Until you withdraw your consent or unsubscribe to our newsletters.
|
| Cookie data |
To obtain information about your use of our Website. For further information, please see our Cookie Notice. |
Your consent. |
According to our Cookie Notice. |
- Personal Data sharing
- We share the information and documents related to you with our data hosting and IT service providers.
- For the purpose of providing legal services, we share your Personal Data with the following third parties:
- certain service providers we have retained in connection with the legal services we provide, including, consultants, experts and other legal specialists such as law firms for obtaining specialist or foreign legal advice, financial experts, accountants, translators, couriers, and other necessary entities;
- if we have collected your Personal Data in the course of providing legal services to any of our clients, we may disclose it to that client, and where permitted by law to others for the purpose of providing our services;
- with courts, law enforcement authorities, regulators, government officials or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defense of a legal claim, or for the purposes of a confidential alternative dispute resolution process.
- For accounting purposes, we share Personal Data with our external accounting service providers and financial auditors.
- For the marketing purposes, we share your email address with our email marketing service providers and third parties listed in our Cookie Notice.
- Storing and transferring your personal information
- Security. We have taken the appropriate technical and organizational measures to ensure the secure processing of your Personal Data. Your data will be processed in such a manner to ensure confidentiality and data integrity.
- International Transfers of your personal information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. If you are located in the European Economic Area (“EEA“), your personal information may be processed outside of the EEA. These international transfers of your personal information will be made pursuant to appropriate safeguards, including:
- ensuring that recipients or the country in which they are located are deemed by the European Commission to provide adequate protection for personal information; and/or
- ensuring that transfers are subject to standard contractual clauses approved by the European Commission for the transfer of personal information.
- We will take appropriate steps to ensure that your personal information is treated securely and in accordance with applicable law and this Policy regardless of where it is processed. If you wish to enquire further about the safeguards we use, please contact us using the details set out at the top of this Policy.
- Your rights in respect of your personal information
- You have the following rights with respect to your personal data:
- Right of access. You have the right to obtain:
- confirmation of whether we are processing your Personal Data;
- information about the categories of Personal Data we are processing, the purposes for which we process your Personal Data and information as to how we determine applicable retention periods;
- information about the categories of recipients with whom we may share your Personal Data; and
- a copy of the Personal Data we hold about you.
- Right to data portability. You have the right to receive a copy of the Personal Data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Data to another person.
- Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete Personal Data we hold about you without undue delay.
- Right to erasure. You have the right, in some circumstances, to require us to erase your Personal Data without undue delay if the continued processing of that Personal Data is not justified.
- Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your Personal Data if the continued processing of the Personal Data in this way is not justified, such as where the accuracy of the Personal Data is contested by you.
- Right to withdraw consent. If you have provided consent for the processing of your Personal Data, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your Personal Data before your withdrawal.
- Complaints. If you believe that your personal data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority. The national personal data protection authority of the Republic of Latvia is Data State Inspectorate (Datu valsts inspekcija).
- You have a right to object to any processing based on our legitimate interests. There may, depending on the particular circumstances, be compelling reasons for continuing to process your Personal Data despite your objection, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
- If you wish to exercise one of these rights, please contact us using the contact details at the top of this Policy.
- Changes to this Policy
We may update this Policy from time to time and so you should review it periodically. When we change this Policy in a material way, we will update the “last modified” date at the end of this Policy. Changes to this Policy are effective when they are published on the Website.
Last updated: 01.09.2023
