Last updated: 24 March, 2022
This policy explains what information we gather about you, what we use that information for and to whom we give that information. It also sets out your rights in relation to your information and who you can contact for more information or queries. Click on the links below to take you to the more detailed sections of this policy:
- you use “our Website” or
- we perform any other activities that form part of the operation of this Website.
What information do we collect?
We may collect personal information from you when you use this Website.
The personal information that we collect or obtain in such circumstances may include: your name; e-mail address; country of residence; employment and education details; your postings on any blogs, forums, wikis and any other social media applications that we provide; your IP address (when allowed); your browser type and language; your access times; complaint details; details of how you like to interact with us and other similar information.
The personal information we collect may also include so-called ‘sensitive’ or ‘special categories’ of personal information, such as details about your dietary requirements (for example, where we provide you with lunch during a meeting).
The types of personal information and special categories of personal information that we collect may vary depending on how you use our Website. In some rare circumstances, we might also gather other special categories of personal information about you because you volunteer that data to us or we are required to gather that data as a result of legal requirements imposed on us.
We understand the importance of protecting children’s privacy. Our website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children.
How we use information about you
Use of personal information collected via our Website
We may also use your personal information collected via our Website:
- to manage and improve our Website
- to tailor the content of our Website to provide you with a more personalized experience and draw your attention to information regarding services provided by entities within our business network that may be of interest to you
- to manage and respond to any request you submit through our Website.
Use of personal information for other activities that form part of the operation of our business
In addition to the purposes connected to the operation of our Website above, we may use your personal information for the purposes of, or in connection with:
- applicable legal or regulatory requirements
- requests and communications from competent authorities
- sending you thought leadership or details of products and services provided by entities within our business network that may be of interest to you; contacting you to receive feedback on these services; and contacting you for other market or research purposes
- protecting our rights.
The legal grounds we use for processing personal information
We use your personal information for the purposes outlined above because of:
- our legitimate interests in the effective delivery of our Website;
- our legitimate interests in the effective and lawful operation of our Website so long as such interests are not outweighed by your interests;
- the legal and regulatory obligations that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency.
To the extent that we process any sensitive personal information relating to you for any of the purposes outlined above, we will do so because either:
- you have given us your explicit consent to process that data;
- the processing is necessary for the establishment, exercise or defense of legal claims or
- you have made the data manifestly public.
Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you. If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function in the communication or e-mail.
To whom we disclose your information
In connection with one or more of the purposes outlined in the “How we use information about you” section above, we may disclose details about you to:
- other members of our business group, which include a sole proprietor Kostiantyn Krasnoukhoff, Krasnoukhoff & partners LLC and Krasnoukhoff Projects p.e.
- third parties that provide services to us and/or our business network
- competent authorities (including courts and authorities regulating us or another member of our business network) and other third parties that reasonably require access to personal information relating to you for one or more of the purposes outlined in the “How do we use information about you?” section above.
Please note that some of the recipients of your personal information referenced above may be based in countries outside of the European Union whose laws may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your personal information that comply with our legal obligations. The adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal information to third countries.
Further details of the transfers described above and the adequate safeguards used by us in respect of such transfers are also available from us by contacting our Privacy Office.
We may also need to disclose your personal information if required to do so by law, by a regulator or during legal proceedings.
We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.
Protection of your personal information
We use a range of physical, electronic and managerial measures to ensure that we keep your personal information secure, accurate and up to date. These measures include:
- education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal information
- administrative and technical controls to restrict access to personal information on a ‘need to know’ basis
- technological security measures, including fire walls, encryption and anti-virus software
- physical security measures, such as staff security passes to access our premises.
Although we use appropriate security measures once we have received your personal information, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal information, but we cannot guarantee the security of data transmitted to us or by us.
How long do we keep your information?
We will hold your personal information on our systems for the longest of the following periods:
- as long as is necessary for the relevant activity or services;
- any retention period that is required by law;
- the end of the period in which litigation or investigations might arise in respect of the services.
You have various rights in relation to your personal information. In particular, you have a right to:
- obtain confirmation that we are processing your personal information and request a copy of the personal information we hold about you
- ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete
- ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information
- object to our processing of your personal information.
To exercise any of your rights, or if you have any other questions about our use of your personal information, please contact us.
Right to complain
If you are unhappy with the way we have handled your personal information or any privacy query or request that you have raised with us, you have a right to complain to the EU Data Protection Authority (“DPA”) in your jurisdiction. If you would like to be directed to the appropriate DPA, please contact us.