This privacy policy (this “Policy”) describes how Andersen Law LLC collects, uses and shares the “personal information” (defined below) that you provide to us and that we otherwise collect in the course of our business, including via our website, e-mail communications, digital platforms and applications (together, our “online means”).

You have the right to be provided with information about (i) how we use your personal information (i) and your associated rights. This is why we are providing you with this Policy.

Who We Are

We are Andersen Law LLC, a U.S. law firm, and any entities it controls that carries out ancillary activities (collectively, “our,” “us,” “we” or “the Firm”).

As an independent law firm that deter-mines the purposes for which we process personal information, we will usually be the “data controller” (within the meaning of the European Union’s General Data Privacy Regulation (the “GDPR”)) in relation to that processing.

Our main address is 180 Elm Street, Suite 188, Pittsfield, MA 01201 USA, and all of our principals are admitted to, and in good standing with, the bar in one or more U.S. jurisdictions.

How You Can Contact Us

Should you have any questions about this Policy or our processing of your personal information, please contact us at info@andersenlaw.llc.

Personal Information We Hold

“Personal information” is information that can be used to identify you or that is about you. We collect and process the following personal information:

• identity, contact and background information such as your full name, address, title, telephone number, e-mail address, gender, business and personal, bio-graphical and background data, information about your employer or business and/or information about your directors, employees and officers, as relevant;
• financial information, such as the source of your net wealth, assets held, source of funds and bank account details;
• technical information, such as the number and frequency of visits you make to our website, your geographic location, your computer operating system and browser type and the search terms you use, which we receive via our online means; and
• marketing information, such as your marketing preferences.

We may process special categories of personal information, such as data concerning your health, personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, data concerning sexual orientation or data relating to a criminal record or alleged criminal activity.

We will only process and share special categories of personal information for marketing purposes, for example in relation to your dietary or access requirements, if necessary for a parti-cular event and we will not keep such data longer than is reasonably needed in connection with such an event.

Collection and Provision of Personal Information

We collect, or you provide, your personal information to us: when signing up for services and/or to receive information via our online means;

• in connection with our provision of legal services:
  • if you are a client of the Firm you or your intermediary may provide us with personal information about you and others and we may collect information about you and others, including your personnel, from other public and non-public sources, as necessary for our provision of legal services including carrying out our client/ matter intake procedures;
  • if you are not a client, we may collect or be provided with your personal information because you are involved with one or more of our clients’ matters;
• in connection with your provision of services to us; and
• in connection with an employ-ment application, including via virtual assessment centers.

Uses for Your Personal Information

We process your personal information:

• to provide legal, trustee and trust administration services to our relevant clients, which, if you are not a client, may involve our handling your personal information on behalf of our clients; we may disclose personal information to third parties if reasonably necessary in connec-tion with our provision of legal and other services;
• to manage and administer our relationships with our clients, their personnel and inter-mediaries and our other business contacts;
• to comply with our legal, regulatory and risk management obligations; our client and matter intake procedures may involve our processing copies of your or your personnel’s identification documents and other background information;
• to establish, exercise or defend our legal rights and/or for the purpose of legal proceedings;
• for employment application purposes;
• to promote our legal services, including sending you and your personnel newsletters, legal updates, marketing communications and other information that may be of interest, and inviting you to events; and
• to record and monitor your visits to our website and use of our online means.

You have the right to ask us not to not send you marketing messages by post, telephone or e-mail or any combination of these at any time.

You can do this:

• by replying directly to our marketing message;
• by unsubscribing from all marketing by clicking the appropriate link in any marketing message from us; or
• at any time by contacting us at info@andersenlaw.llc.

Grounds for Processing Personal Information

We rely on the following legal grounds to process your personal information:

• performance of a contract;
• compliance with applicable laws and regulations;
• our and others’ legitimate business interests, with due regard to appropriate safe-guards that protect your privacy; or

Where we process special categories of personal information we will do so on one of the following bases:

• your explicit consent;
• where necessary for the establishment, exercise or defense of legal claims; or
• in relation to employment, where necessary for carrying out our obligations and exercising specific rights as a data controller.

Sharing Personal Information

We may share your personal information with trusted third parties both within and outside the European Economic Area (the “EEA”) pursuant to contractual arrangements or regulatory obligations we have with or owe to them, including:

• third-party professionals and advisers;
• our bank;
• suppliers to whom we may outsource certain support services such as word processing, translation, photocopying, data hosting and document review;
• suppliers of good and services to the Firm;
• our auditors, insurers, brokers and other advisers;
• third parties involved with the services we provide to clients such as counterparties and their lawyers, accountants, surveyors, family offices and other intermediaries and courts, tribunals, public registrars and stock exchanges; and
• third parties involved in organizing events or seminars.

On occasions we may need to share your personal information with regulatory authorities, government agencies and law enforcement agencies. If so, we will use reasonable efforts to notify you before we do this, unless we are legally restricted from doing so.

The level of information protection in countries outside the EEA may be lower than that offered within the EEA. Where third parties with whom we share your personal information process it outside the EEA, our written agreement with them will include appropriate contractual clauses to ensure that your personal information remains protected and secure in accordance with applicable data protection laws.

We may use social media sites such as LinkedIn, Facebook and Twitter and you are directed to such sites’ own privacy policies in relation to how they may process your personal information.

Storage of Personal Information

In the course of our business, including where we share information as set out above and when our personnel are working overseas, we may need to transfer your personal information to locations outside England and Belgium, where we have offices, including to countries outside the EEA.

Maintenance of Personal information

We will keep your personal information on our various systems, for the periods specified in relation to the relevant system in our data protection policy.

When determining relevant retention periods, we take into account factors including:

• our contractual and business relationships with you and the purpose for which we hold your personal information;
• legal obligations to retain data for a certain period of time;
• relevant statutes of limitations;
• potential disputes;
• best practice; and
• guidelines issued by our regulator and relevant supervisory authorities.

Information Security

We ensure that the personal information we hold is secured by appropriate technical and organizational security measures. We have put in place and trained all our personnel on procedures to deal with data breaches. We will notify you and any applicable regulator of a breach where we are legally required to do so.

Your Rights in Connection With Your Personal Information

Under certain circumstances, by law you may have the right to:

• request access to your personal information and information about how we process it (known as a “subject access request”); should you wish to make a subject access request, then please contact us at info@andersenlaw.llc; we may need to refuse your request for your personal information, if it is the subject of legal professional privilege belonging to one or more of our clients;
• object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground; you also have the right to object where we are processing your personal information for marketing purposes;
• request rectification or deletion of the personal information that we hold about you;
• request the restriction of processing of your personal information; or
• request the transfer of your personal information to another party in a machine-readable, commonly used and structured format.

If you want to exercise any of these rights, other than a subject access request, then please contact us at info@andersenlaw.llc. The above rights are not absolute and each is subject to exceptions and qualifications. We will respond to your request within one month of its receipt. In some cases we may not be able to fulfill your request before this date, and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.

If your provision of your personal information to us is a legal or contractual requirement or necessary for us to fulfill a contract with you and you choose not to provide it, we may not be able to provide legal or other services to you.

Informing Us of Changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your business relationship with us.

Cookies

Our website may use cookies. A “cookie” is a small file of letters and numbers that is sent to your computer by a website and automatically saved on your computer by your web browser. Each time you request a page from the website, your web browser may send this cookie back to the website server.

We may use the information collected from our use of cookies to estimate our audience size, analyze trends and general usage patterns of our website, optimize our website, and for other research and marketing purposes. This is statistical information and does not identify any individual.

You are not obliged to accept cookies. If you wish, you can set your browser to notify you before you receive a cookie so you have the chance to accept it and you can also set your browser to refuse to receive or send all cookies. The website http://www.allaboutcookies.org/ (run by the Interactive Marketing Bureau) contains step-by-step guidance on how cookies can be switched off by users.

By using our website without disabling cookies, you are consenting to our use of cookies as described in this policy.

More information on cookies is available at http://www.allaboutcookies.org/.

Complaints

If you wish to request further information about any of the above rights, or if you are unhappy with how we have handled your information, please contact us at info@andersenlaw.llc.

Changes to this Policy

We may update this policy at any time without notice; any changes will be notified to you using the email address you have given us and/or by an announcement on this website. Your continued use of this website, following the posting of changes to these terms, will mean you accept these changes.

Last modified. October 3, 2023