Privacy Policy Statement

THIS PRIVACY STATEMENT EXPLAINS HOW PRAXIO S.C.S MAY USE, PROCESS AND STORE YOUR DATA UNDER THE PROVISIONS OF THE GENERAL DATA PROTECTION REGULATION (the “GDPR”) AND APPLICABLE LUXEMBOURG LEGAL PROVISIONS (THE “PRIVACY STATEMENT”)

1. Who is responsible for the data protection?

Praxio S.C.S., a law firm established as a société en commandite simple inscrite au Barreau de Luxembourg (common limited partnership registered with the Luxembourg Bar) (the “Law Firm”), established at 4a, rue Henri Schnadt, L-2530 Luxembourg, Grand Duchy of Luxembourg, registered with the Luxembourg Trade & Companies Register under number B223247 is the data controller responsible for your personal information.

2. How do we acquire your data?

The Law Firm gathers personal data directly from its clients, prospective clients, business partners, beneficial owners, service providers, contracting parties, potential candidates, intermediaries, in the context of its activities, which include legal assistance, advice and other services.

3. Why do we collect your data?

We ask for your consent to process your personal information in order to:
– comply with supervisory law or other requirements set out by government authorities;
– fulfil our obligations with regard to the prevention of fraud and money laundering (e.g., comparisons with European and international anti-terror lists;
– comply with control and notification obligations under tax law as well as the archiving of data for the purposes of data protection and data security;
– respond to your queries;
– provide services and/or information to you;
– recruit personnel.

In general, you may revoke your consent at any time. You will be informed of the purposes and the consequences of revocation or failure to give consent in the corresponding text of the consent.
In principle, revocation of consent only affects the future. Any processing carried out prior to the revocation remains unaffected and legal.

4. Types of data processed

Where necessary for the contractual relationship with you and the application you have submitted, we process any data received from other bodies or from other third parties in a permissible manner. In addition, we process personal data that we have obtained, received, or acquired in a permissible way from publicly accessible sources (such as commercial and association registers, civil registers, press, internet, and other media), where required and where we are allowed to process such data in accordance with the statutory provisions.

Relevant categories of personal data may be in particular:

Contact data such as:

  • name (including initials);
  • address;
    – email address;
  • telephone number, mobile number and other contact information;
  • date and place of birth;
  • nationality;
  • gender;
  • employment details (position or profession, employment history, name of company or organization);
  • tax status;
  • interest areas;
  • marital status;
  • copies of identity documents (passport number, national ID card, driver’s license, social security identification numbers).

Financial and business data such as:

  • source of wealth;
  • utility bill;
  • bank statement;
  • account number;
  • credit or debit card numbers;
  • billing information;
  • other data which are necessary to fulfil the actual requirements of fraud prevention law and anti-money laundering law;
  • data provided before during or after the execution of contract or relationship between the Law Firm and your organization/company or voluntarily provided by undermentioned entities.

 

KYC and AML information requested by the law on the fight against money laundering and terrorist financing provisions, which may include:

  • proof of source of funds,
  • information and documentation which we may request and/or obtain from third party sources.

 

Physical Access Data such as relating to details of your visits to our office or information you provide to us for the purposes of attending meetings and events, or your image for the use of video surveillance at the entrance to our offices.

Sensitive Personal Data:

In the time of providing the legal services such as legal representation we may require to collect and process sensitive personal information about you such as:

  • information about racial or ethnic origin;
  • political opinions;
  • genetic or biometric data;
  •  religious beliefs;
  • trade union activities;
  • physical or mental health;
  • sexual orientation;
  • genetic or biometric data.

 

When executing mandates conferred by clients, the Law Firm may act as a data processor with respect to data received from the client. In such cases, the processing to be executed by the Law Firm will be regulated by the terms & conditions of the Law Firm, which take into account the requirements listed under article 28 of the GDPR.

5. Retention period

The Law Firm will process and store the relevant personal data for the duration of its legal services or for the duration of the business relationship.
In addition, we are subject to various storage and documentation obligations.
With regard to the general data protection regulation provisions and time limitations provided by Art. 2276 of the Luxembourg Civil Code and Regulations relating to anti money laundering policy, the Law Firm has to retain, the relevant personal data for a period of five (5) years after the termination of the services or the business relationship.

6. Your rights

Under certain circumstances, you may assert the following data protection rights against us:
Each data subject has the right of access in accordance with Art. 15 GDPR, the right to rectification in accordance with Art. 16 GDPR, the right to erasure in accordance with Art. 17 GDPR, the right to restrict processing in accordance with Art. 18 GDPR, as well as the right to data portability under Art. 20 GDPR. In addition, you have a right to complain to a data protection supervisory authority Art. 77 GDPR.
At the end of each digital mailing that you receive from the Law Firm, you can always change your mailing preferences via the ‘unsubscribe’ or ‘subscribe’ link. In short, you can always withdraw your consent.
If you wish to exercise any of the above rights, you can contact the Law Firm, via the following email: info@praxiolegal.com.

7. Participation of third parties in your data collection

We share your personal information with:

  • our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advice;
  • any other third party if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or to protect the rights, property and/or safety of the Law Firm, our personnel or others;
  • any other third party for the purposes of acting in accordance with the requirements of a court, regulator or government agency, for example, complying with a search warrant or court order or acting in accordance with an applicable law or regulation; or
  • investors and other relevant third parties in in the event of an actual potential sale or other corporate transaction related to the Law Firm.
    Our Website provides sharing buttons that you can click on in order to share content from our Website on social media channels, e.g., Facebook. We do not use these buttons to share your personal information with social media providers. When you click on a sharing button, the relevant social media provider will gather personal information directly from you. Please read the privacy notice of any social media provider with which you intend to share content before clicking on the corresponding sharing button.
8. Protection from loss of your personal data

The Law Firm has taken appropriate technical and organisational measures to protect your personal data against loss or any form of unlawful processing.

9. Website

The Law Firm is owner of the website www.praxiolegal.com (the “Website”). Please note that the Law Firm does not process the private data through it.

10. Use of cookies and other applications

Please note that our website does not use cookies, social media plug-ins nor other applications to collect your personal data.

11. Changes to this Privacy Statement

The Law Firm reserves the right to change this Privacy Statement from time to time and at its discretion to reflect changes in the law, our data collection and used practices, and to ensure it is accurate, complete and up-to-date. We advise you to periodically review current Privacy Statement available on the website www.praxiolegal.com to be informed how the Law Firm is protecting your privacy.

12. Relation to other websites

Please be aware that the statement does not apply to other websites, which you may find on our website or on which you may find the link to our web site.

13. Contact

If you have any questions, comments, concerns or complaints in relation to this Privacy Statement, the Law Firm is processing of your personal data or if you wish to exercise any of your rights, please contact our data protection office, via the following email: info@praxiolegal.com.