2. Personal data we collect
2.1 If you wish to contact us about our professional practice (either through the Site or by phone, email or post), or become a client of the firm (or represent such a client), we ask you to supply essential contact details (your name, e-mail address, phone number, and country of residence, and (where applicable) the company you represent and your job title), which we need in order (if you instruct us, or the entity you represent does so) to perform the contract that we have with you (or the entity you represent) to identify you, as well as the firm’s professional services which may be of interest to you.
2.2 If you wish to become a client (or the entity you represent wishes to become a client) and, if you do so (or the entity you represent does so), in the course of providing our professional services, we may collect further personal information from you.
2.3 We may also need to ask you to provide personal information, and we will carry out background checks about you with credit reference agencies and fraud prevention agencies, for credit control purposes and in order to satisfy our obligations under applicable legislation. If you do not provide the information we require, we will not be able to provide our professional services for you or the entity you represent.
3. How we use your personal data
3.1 When you make an enquiry, we will process the personal data that you give us, or we collect from you, so that we can supply you with the information you request, on the basis that it is necessary for our legitimate interests in promoting and marketing our professional services and, if you instruct us (or the entity you represent does so), to perform the contract that we have with you (or the entity you represent).
3.2 We will also process your personal data for internal record keeping, billing and accounting, and to respond to any queries, complaints or requests for further information, on the basis that it is necessary for our performance of the contract we have with you, or it is necessary for our legitimate interests in managing our business and improving our professional services.
3.3 We also use the personal data that you provide or that we collect for market research purposes and to improve the content or lay-out of the Site, on the basis that it is necessary for our legitimate interest in promoting and marketing our goods and services, managing the Site and providing a better service for our customers, on the basis that it is necessary for our legitimate interests in promoting and marketing our professional services.
3.4 We may use collected information to enhance the visitor experience of the Site or professional services we may offer to you in the future (the “Service”), to operate and maintain the Site, to investigate and understand how our Service is used, to monitor and protect the security and integrity of the Site or the Service, and to otherwise analyze our business.
3.5 We may use the personal data that we collect from you to contact you by email with marketing information about services that are the same as or similar to those you have enquired about or ordered, unless you tick the relevant box situated on the form on which we collect your data. You can always opt-out of receiving marketing emails from us. All future marketing communications will also contain a simple way to opt out of receiving such further communications from us.
3.6 We may also contact you by email with marketing information about other goods and services we feel may interest you, on the basis that it is necessary for our legitimate interests in promoting and marketing our professional services, provided that you consent to receiving such emails by ticking the relevant box situated on the form on which we collect your data. You can always opt-out of receiving marketing emails from us. All future marketing communications will also contain a simple way to opt out of receiving such further communications from us.
3.7 If you provide us (or one of our employees or other personnel) with your professional or business contact details or other relevant personal data, we will use this in order to keep in touch with you and exchange information that we believe is, or may become, relevant to our and your business or profession, on the basis that it is necessary for our legitimate interests in promoting and marketing our professional services.
3.8 If you submit a job application or enquire about a potential position with a Group member, or another person does so on your behalf, we will ask you (or them) to provide relevant personal information about you. Further details of the personal data that we collect, and of the basis on which we will process your personal data, will be provided by our HR Department at the time.
3.9 Your personal data will not be used for any other purpose, or disclosed to any third party, unless we are required to do so by law, or as mentioned in the next paragraph.
4. Who we share your information with
4.1 We are part of the Bermello Ajamil + Partners, Inc. (for which see the Site page About Us) and may share your personal data with other members of the group on the basis that it is necessary for our legitimate interests in promoting and marketing the group and its professional services, and (if you instruct us, or the entity you represent does so) to perform the contract that we have with you (or the entity you represent). See also the paragraph below on where we store your data.
4.2 When we provide some of the services we may do so with the assistance of third party suppliers, who will need to have access to your personal data for that purpose. Such third party suppliers will be appointed on the basis that they provide sufficient guarantees to implement appropriate technical and organizational measures so that the processing will carry out processing only on our written instructions, ensure the protection of the rights of data subjects, and otherwise meet the requirements of the applicable Data Protection legislation.
4.3 We may disclose your personal data if it is necessary for us to do so in order to comply with any legal or regulatory obligation, or where we have a legitimate interests in doing so, such as in order to enforce or apply our contract with you, to investigate potential breaches, or to protect our property and rights or those of others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
4.4 External organizations may conduct audit or quality checks for us. These external organizations are required to maintain confidentiality in relation to your files. If you do not want your file to be part of this process, please tell us as soon as possible.
4.5 If another company acquires substantially all of our business or assets, that company will possess the same information and will assume the rights and obligations with respect to that information, and any transfer of your personal data will be made on the basis that it is necessary for our legitimate interests in transferring our business or assets.
4.6 Except as set out above or in accordance with the operation of law or lawful demand, we will never sell, distribute or disclose any of your personal data (except anonymous aggregate information) with any third party without your express consent.
5. How long do we keep personal data for
5.1 We normally retain contract information (including personal data) for a reasonable period after the end of the relevant contract, or for longer where we it is necessary for us to do so for the establishment, exercise or defense of legal claims or for compliance with legal obligations.
5.2 Personal data relating to our professional contacts will be retained for so long as is necessary, or until you indicate otherwise to us, but we will aim to update our contacts’ preferences on a periodic basis.
5.4 In certain case, it may not be physically possible to delete certain data (for instance, where it is stored on a secure external server), in which case we will take appropriate steps to ensure that it is not available for re-use or disclosure to third parties.
6. Your rights as a data subject
As a data subject you have certain legal rights subject to certain exceptions under the applicable Data Protection legislation) including:
- the right to access the personal data held about you;
- the right to ask us not to process your personal data for marketing purposes;
- the right to withdraw at any time any consent you have given to receive marketing material from us, or in any other case where we process your personal data on the basis of a consent that you have given (and not on some other legal basis);
- the right to ask us to rectify inaccurate personal data about you;
- the right to ask for the restriction of personal data concerning yourself that is inaccurate, unlawfully processed, or no longer required;
- the right to ask for the transfer of your personal data in a structured, commonly used and machine readable format where the processing is based on your consent;
- the right the right to ask for the erasure of personal data concerning yourself where processing is no longer necessary, or the legitimate interests we have in processing your personal data are overridden by your interests, rights and freedoms as the data subject;
- and the right to make a complaint about to the Information Commissioner’s Office.
7. Where we store your data
The personal data that we collect from you may be shared with other members of the Bermello Ajamil + Partners, Inc. (see the paragraph above on Who we share your information with) transferred to and stored at a destination outside the European Economic Area (“EEA”), in countries whose laws provide for a lower standard of protection for personal data than in the European Union. However, we will provide contractual or other safeguards are in place and provide that your personal data is appropriately protected, and that enforceable rights and effective legal remedies are available for data subjects, including by means of the EU Model Contract Clauses for the transfer of personal data to third countries (for which see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en).
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12. How to contact us
If you have any questions, comments or requests about the Site generally, please contact us by email to: firstname.lastname@example.org or write to us at Bermello Ajamil + Partners, Inc., 2601 S. Bayshore Drive, Suite 1000, Miami, FL 33133.