flexible technology-focused legal counsel
Last updated and effective date:
September 1, 2024
EU Regional Privacy Notice
Questions About Our Policies?
We are committed to safeguarding the privacy of Personal Data. This European Union Regional Privacy Notice (this “EU Privacy Notice”) provides additional information about how Right Arrow Legal, LLC and its subsidiaries and affiliated companies (“Right Arrow Legal,” “we,” “our,” or “us”) process Personal Data that is subject to GDPR when we are the controller of that information. In this EU Privacy Notice, we use the term “GDPR” to mean the EU General Data Protection Regulation, as implemented by associated national laws applicable to our processing of your Personal Data, including the laws applicable to data subjects located in Switzerland and the United Kingdom (herein collectively referred to as “EU Data Protection Laws”).
We strongly encourage you to read this EU Privacy Notice in its entirety. This EU Privacy Notice supplements our Privacy Policy. In the event of any inconsistency between this EU Privacy Notice and our Privacy Policy, this EU Privacy Notice shall govern, as to our processing of Personal Data of data subjects located in the EU. Capitalized terms used, but not otherwise defined herein, shall have the meanings given to them in our Privacy Policy, available at: https://www.rightarrowlegal.com/privacy-policy.
This EU Privacy Notice explains how we process the Personal Data that we: (1) collect directly from EU data subjects; (2) receive about EU data subjects; (3) collect through the Site; and (4) process through our Activities (collectively, our “EU Processing Activities”).
For purposes of this EU Privacy Notice, “Personal Data” means any information relating to you as an identified or identifiable person processed by us, subject to EU Data Protection Laws.
Updates
to this EU Privacy Notice
We may update this EU Privacy Notice from time to time. Any updated EU Privacy Notice will be effective when posted. If we decide to update this EU Privacy Notice, we will post the updated EU Privacy Notice on our website and update the “Last updated and effective date.” Please check back regularly to review any changes to this EU Privacy Notice.
Personal Data we may collect
From time to time, we may collect or receive Personal Data about you from public sources or third parties as described in our Privacy Policy.
Sensitive Personal Data
We do not request or require sensitive Personal Data regarding religion, health, sexual orientation, or political affiliation in connection with our EU Processing Activities.
Information from other third parties
From time to time, we may obtain information about you from public sources or third parties as described in our Privacy Policy.
Profiling and automated decision making
We do not use Personal Data for automated decision-making, including profiling, in connection with our EU Processing Activities.
Legal bases under which we process your Personal Data
Our processing of Personal Data under this EU Privacy Notice is justified by a “legal basis” in accordance with EU Data Protection Laws. We may use Personal Data for the following purposes, as outlined in our Privacy Policy, in each case as justified by the legal basis specified:
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Legal Basis: for instances in which we do not obtain your express consent, it is in our legitimate interests to use your Personal Data for the following categories of use, outlined in our Privacy Policy:
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Providing support and performing our Activities;
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Responding to your requests;
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Personalization;
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Newsletters, mailing lists, and marketing;
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Analytics and improvement;
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Protecting legal rights and preventing misuse;
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Complying with legal, contractual, and ethical obligations;
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General business operations; and
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Creating and using anonymous and de-identified information.
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If you have any questions about or need further information concerning the legal basis on which we process your Personal Data, please contact us at privacy@rightarrowlegal.com.
How long we retain your Personal Data
We will retain your Personal Data only for as long as necessary to fulfill the purposes for which the Personal Data was collected or received as described in our Privacy Policy and this EU Privacy Notice. At the end of the applicable period, or once you withdraw your consent as described below, whichever is later, your Personal Data will be deleted in accordance with our retention policies.
How we protect your Personal Data
We have implemented physical, technical, organizational, and administrative security measures designed for the purpose of protecting your Personal Data, in accordance with our Privacy Policy. If you have any questions on the security measures that we use to secure your Personal Data, you may contact us at privacy@rightarrowlegal.com.
International Transfers
We may process your Personal Data in countries outside of the European Economic Area (the “EEA”), the United Kingdom (the “UK”), and Switzerland, including United States and other countries, in the course of our EU Processing Activities.
We transfer your Personal Data only as not prohibited by EU Data Protection Laws. Certain EU Data Protection Laws require data controllers to put in place safeguards to protect Personal Data transferred across borders. In order to comply with these requirements when we transfer Personal Data from the EEA, the UK, and Switzerland, we: (1) have in place contractual arrangements (where appropriate) with our group companies that cover these transfers;. and (2) have in place appropriate safeguards for such Personal Data, which may include:
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Ensuring that the Personal Data is transferred to countries recognized by the European Commission, the UK Secretary of State, or Swiss authorities (as applicable) as offering an equivalent level of protection; or
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Ensuring that such transfer is to a third party that uses appropriate safeguards in respect of the processing in question, which may include the standard contractual clauses (including as amended in compliance with requirements under UK and Swiss law), which are recognized as offering adequate protection for the rights and freedoms of data subjects, as determined by the European Commission, the UK Secretary of State, or Swiss authorities (as applicable).
We may transfer your Personal Data to, or store your Personal Data in, the following locations:
EEA
For processing and transfers of UK/Swiss Personal Data, this jurisdiction is recognized as offering an equivalent level of protection by the UK Secretary of State and Swiss authorities.
Japan
For processing and transfers of EEA/UK Personal Data, this jurisdiction is recognized as offering an equivalent level of protection by the European Commission and the UK Secretary of State.
For processing and transfers of Swiss Personal Data, Standard Contractual Clauses, as amended in compliance with requirements under applicable Swiss law.
United Kingdom
For processing and transfers of EEA/Swiss Personal Data, this jurisdiction is recognized as offering an equivalent level of protection by the European Commission and Swiss authorities.
United States
For processing and transfers of EEA Personal Data, Standard Contractual Clauses and/or transfers to recipients certified under the EU-U.S. Data Privacy Framework.
For processing and transfers of UK Personal Data, Standard Contractual Clauses, as amended by the UK Addendum, and/or, as applicable, transfers to recipients certified under the UK Extension to the EU-U.S. Data Privacy Framework.
For processing and transfers of Swiss Personal Data, Standard Contractual Clauses, as amended in compliance with requirements under applicable Swiss Law, and/or, as applicable, transfers to recipients certified under the Swiss-U.S. Data Privacy Framework.
You have a right to obtain details of the mechanism under which your Personal Data is transferred outside of the EEA; you may request such details by contacting us as set forth in the “How to Contact Us” section below.
Rights of Data Subjects in the EEA
In the EEA and some other countries, you may have certain rights available to you under applicable data protection laws, which may include the following rights:
Right to Access:
The right to request information about how we process your Personal Data and to obtain a copy of that Personal Data. If permitted under applicable EU Data Protection Laws, we may charge you a small fee for this service.
Right to Rectification:
The right to request the rectification of inaccurate Personal Data about you and for any incomplete Personal Data about you to be completed.
Right to Object:
The right to object to the processing of your Personal Data.
Right to Erasure:
The right to request the erasure of your Personal Data, under certain circumstances.
Right regarding Automated Decision-Making:
The right not to have a decision made about you that is based solely on automated processing, including profiling if that decision produces legal effects about you or significantly affects you.
Right to Restrict Processing:
The right to ask us to restrict our processing of your Personal Data under certain circumstances, so that we no longer process that Personal Data until the restriction is lifted.
Right to Data Portability:
The right to receive your Personal Data, which you have provided to us, in a structured, commonly-used, and machine-readable format and to have that Personal Data transmitted to another controller in certain circumstances.
You retain the right to lodge a complaint with a supervisory authority in your country of residence if you believe that we have infringed your rights under applicable EU Data Protection Laws.
Your additional rights
If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time by contacting privacy@rightarrowlegal.com. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data on lawful processing grounds other than consent.
Upon receipt of a request from you, we may need to request additional information about you to verify your identity or to understand the scope of your request.
If you wish to exercise any of your rights or if you have any questions about these rights, please contact our Privacy Team at privacy@rightarrowlegal.com.
Timing:
To the extent not prohibited by applicable EU Data Protection Laws, we will respond to requests within 45 days unless we need more time, in which case we will notify you and may take up to 90 days total to respond to your request.
How to Contact Us
If you have questions or concerns about this EU Privacy Notice or our processing of your Personal Data, please contact us at:
privacy@rightarrowlegal.com.