PRIVACY POLICY

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Who are we?

LIMITED LIABILITY COMPANY “ULYSSES LAW FIRM” is a legal entity incorporated and existing under the laws of Ukraine, identification code 37026380, having its registered office at 4-B Ivan Franko Street, Office 49, Kyiv, 01054, Ukraine (collectively, “Ulysses Law Firm,” “we,” or “our”). Ulysses Law Firm is a controller of your data. If you have any questions about your privacy or this policy, please contact us at office@ulysses.law.

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What personal information do we collect about you?

We may collect different kinds of personal information about you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage in our legal or other services, or as a result of your relationship with one or more of our staff and clients. The personal information that we process includes:

(1) basic information, such as your first name, middle name, maiden name, last name, marital status, title, date of birth, passport number, photographic identification, and gender;

(2) contact information, such as your postal address, email address, and telephone number;

(3) financial information, such as your billing address, bank account, and payment card details;

(4) technical information, such as information from your visits to our website or applications or concerning materials and communications we send to you electronically;

(5) professional information, such as your job title, the name of your employer, your previous positions, and professional experience;

(6) services information, such as payments to and from you and other details of services you have purchased from us or we have purchased from you;

(7) marketing and communications information, such as information you provide to us to attend meetings and events, your marketing and communication preferences, and your feedback and survey responses;

(8) special categories of data, such as your race and ethnicity, trade union membership, information about your health, political opinions, or religious beliefs; and

(9) any other information relating to you that you may provide to us.

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How we obtain your personal information?

We use different methods to collect personal information from and about you, including through the channels below.

(1) Direct interactions: we gather information about you when you interact with us directly (i) by corresponding with us by email or post, (ii) by speaking to us in person or over the telephone, and (iii) through electronic portals and platforms, or (iv) by filling in forms on our website.

(2) Website: when you visit our websites, we automatically collect, store and use technical information about your equipment and interaction with our website. We collect this personal data using cookies, server logs, and other similar technologies. The personal data includes your preferences, operating systems, browser software, IP addresses, and the URL clickstreams to, through, and from our website, including location, date, and time. If you want to block cookies, you may be able to do this through the settings in your browser for each browser you use and each device you use to access the internet. However, please be aware that some areas of our website may not work if your browser does not accept cookies.

(3) Third-party sources: we may receive personal information about you from third parties when we provide our client with services or other parties send us your data to enable the provision of those services; we conduct our “know your customer” and further background checks; you provide your data to a third party to share it with us; we interact with governmental or regulatory bodies or other about you or on your behalf.

(4) Publicly available sources: we may collect information about you from public registers and databases, online social media, and social networking services.

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How we use your personal information?

We will only use your personal information reasonably and where we have a lawful reason to do so. We will, therefore, only use your data to:

(1) consider whether we can pursue specific business development initiatives;

(2) comply with our legal obligations to identify and verify the identity of our clients and their beneficial owners and to identify and assess the risks of money laundering and terrorist financing which may apply to our business;

(3) deliver legal services to you and the organization you work for if you are a client;

(4) run our business (e.g., carry out administrative or operational processes, including recruitment);

(5) maintain and develop our business relationship with you;

(6) improve our services and products to you if you or the organization you work for are a client or prospective client;

(7) identify services you may be interested in;

(8) send you marketing and invite you to events;

(9) monitor and analyze our business; or

(10)process and respond to requests, inquiries, or complaints received from you.

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On what basis we use your personal information?

We use your personal information on the following basis:

(1) it is necessary for the performance of a contract with you or the organization you work for;

(2) it is necessary to comply with legal and regulatory obligations;

(3) you have provided your consent to processing your data; or

(4) if we (or a third party) have a legitimate interest, provided that your fundamental rights do not override such interests. The legitimate interests include providing legal services, running our business, and marketing relevant services directly to you.

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How long we keep your personal information?

We will only retain your personal information for as long as is necessary for the purpose for which it was collected, including to comply with any legal, regulatory, accounting, or reporting requirements.

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Who we share your personal information with?

We may share your personal information with:

(1) our professional advisers and auditors;

(2) third parties engaged in the course of the services we provide to clients, such as barristers, local counsel, mediators, arbitrators, consultants, or experts;

(3) suppliers to whom we outsource certain support services such as word processing, translation, photocopying, and document review;

(4) service providers including IT, cloud storage, data room, case management service providers, and event organizers; or

(5) regulatory authorities, courts, tribunals, government agencies, law enforcement agencies, and any other third party to honor a legal, regulatory or professional obligation.

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How we protect your personal information?

We protect your data and implement appropriate technical and organizational security measures to protect it from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction, or accidental loss. All partners, staff, and third-party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations. However, the transmission of information via the internet is not completely secure. Therefore, although we take appropriate and proportionate steps to manage the risks posed, we cannot guarantee the security of your information transmitted to our email systems and online services.

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Which countries we transfer your personal information to?

To provide our services, we may need to transfer your personal information to locations outside the jurisdiction in which you provide it or where you are viewing this website for the purposes set out in this privacy policy. This may entail a transfer of your information from a location outside the European Economic Area (the “EEA”) to a location within the EEA, within locations within the EEA, from a location within the EEA to a location outside the EEA, or within locations outside the EEA. The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will take reasonable steps to ensure that your information is treated securely and that the means of transfer provide adequate safeguards.

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Your rights regarding your personal information

You have certain rights that you may exercise under certain circumstances concerning the personal information that we hold. These rights are to:

(1) request access to your personal information (known as a subject access request) and request certain information concerning its processing;

(2) request the rectification of your personal information;

(3) request the erasure of your personal information;

(4) request that we restrict the processing of your personal information; and

(5) object to the processing of your personal information.

In the limited circumstances where you may have provided your consent to collect, process, and transfer your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purposes you originally agreed to unless we have another legitimate basis for doing so in law. If you would like to exercise any of these rights, please get in touch with us at office@ulysses.law. Before assessing your request, we may request additional information to identify you. If you do not provide the requested information and, as a result, we are not in a position to identify you, we may refuse to action your request.