PRIVACY POLICY

Implement Legal is committed to protecting your privacy. This notice describes how we collect and use your personal data. It also describes the rights you have and the control you can exercise in relation to it.

Who We Are

Implement Legal is a progressive law firm founded to help artists and creators safeguard their work and preserve their values.

If you have any questions about our use of your personal data, please use the following contact: hello@implementlegal.com

Data Collection And Usage

We will collect the following personal data:

• Contact information: your name, position, role, company or organization, telephone (including mobile phone number where provided) as well as email and postal address;

• Business information: data identifying you in relation to matters on which you instruct us or in which you are involved;

• Information from public sources: e.g. LinkedIn and similar professional networks, directories, or digital publications;

• Attendance records: to record your attendance at our offices for security purposes;

• Subscriptions/preferences: when you subscribe to receive briefings, updates, or newsletters as well as content preferences to help us identify which materials you are interested in receiving;

• Events data: attendance at and provision of feedback forms in relation to our events;

• Supplier data: contact details and other information about you or your company or organization where you provide services to Implement Legal;

• Social media: posts, Likes, tweets and other interactions with our social media presence;

• Technical information: when you access this website and our technology services being IP address, browser type and version (e.g. Chrome, Safari etc.), time zone setting, browser plug-in types and versions, operating system you are using (e.g. Windows XP, MacOS, etc), device type, hardware model, MAC address, unique identifiers and mobile network information;

• Online data: when you access this website and our technology services, information about your visit including URL clickstream to, through, and from our website (including date and time), information about your network such as information about devices, nodes, configurations, connection speeds and network application performance; pages viewed or searched for, page response times, download errors, length of visits and interaction information (such as scrolling, clicks, mouse-overs) and whether you click on particular links or open our emails.

Implement Legal does not collect personal data about your online activities across third-party websites or online services.

Your Communications With Us

Implement Legal may also collect information that you choose to provide in communications with us. Please do not send us confidential information until we have confirmed in writing that we act for you or your company or organization. Unsolicited emails from non-clients do not establish a relationship with us.

How We Use Your Personal Data

We use your personal data for the following purposes:

• Service provision: providing advice and services including extranets and other technology tools;

• Business relationship: managing and administering our relationship with you, your company, or organization including keeping records about business contacts, services, and payments so we can customize our offering for you, develop our relationship and target our marketing and promotional campaigns;

• Communication: sending emails, newsletters, and other messages to keep you informed of legal developments, market insights, and our services;

• Events: running briefings, roundtables, and other events;

• Client legal compliance: client due diligence (under anti-money laundering, sanctions screening, and other crime prevention and detection laws and regulatory requirements) which may involve automated screening checks to ensure that clients and contacts are genuine and to prevent fraud or crime and we may not be able to take instructions if you do not provide the information we need to do these checks;

• Website monitoring: to check the website and our other technology services are being used appropriately and to optimize their functionality;

• Site security: to provide security to our offices and other premises (normally collecting your name and contact details on entry to our buildings);

• Online security: protecting our information assets and technology platforms from unauthorized access or usage and monitoring for malware and other security threats;

• Regulatory: compliance with our legal and regulatory obligations and reporting requirements;

• Managing suppliers who deliver services to us;

• To pursue the legitimate business interests listed in the “Legitimate Interests” section of this policy below.

Our Reasons For Using Your Personal Data

We will process your personal data for a number of reasons:

• you have given us consent: for example where you share details for particular purposes;

• this is necessary to comply with legal or regulatory obligations, for example anti-money laundering and mandatory client screening checks or disclosure to law enforcement;

• this is necessary to deal with legal claims;

• processing is necessary for our legitimate business interests or those of a third party: provided this does not override any interests or rights that you have as an individual. Our legitimate interests are listed in the next section.

Legitimate Interests

We have legitimate business interests in:

• providing advisory services;

• managing our business and relationship with you or your company or organization;

• understanding and responding to inquiries and client feedback;

• understanding how our clients use our services and websites;

• identifying what our clients want and developing our relationship with you, your company, or organization;

• improving our services and offerings; 

• enforcing our terms of engagement and website and other terms and conditions;

• ensuring our systems and premises are secure;

• managing our supply chain;

• developing relationships with business partners;

• ensuring debts are paid;

• operating suppressors to exclude you from direct marketing if you unsubscribe; 

• sharing data in connection with acquisitions and transfers of our business. 

Our Reasons For Using Special Category Data

Special category data in the EU and certain other jurisdictions refers to sensitive data such as your racial or ethnic origin, religious beliefs or health data. We may also collect data about criminal convictions. We will process this data where:

• we have your explicit consent for the particular processing; 

• this is necessary to protect your vital interests or those of another person, for example, in medical emergencies; you have manifestly made the data public, for example, where you have published it on social media;

• this is necessary to deal with legal claims, for example, involving court proceedings;

• this is necessary for substantial public interest, for example to prevent or detect unlawful acts;

• as permitted by applicable law.

With Whom Do We Share Your Data?

We share your information with others as follows:

• Implement Legal and related entities including their management, staff, and contractors in order to provide advisory services;

• Suppliers who support our business, including IT and communication suppliers, outsourced business support, marketing and advertising agencies, back-up and DR suppliers. Our suppliers have to meet minimum standards as to information security and they will only be provided data in line with their function;

• Shared service centers operated by Implement Legal or third parties including for client on-boarding, IT services, marketing, risk management, and office support services;

• Law enforcement bodies, regulators, or other competent authorities in accordance with legal requirements or good practice;

• Appropriate parties in the event of emergencies, in particular to protect the health and safety of our clients, staff, and organizations;

• Your company or organization in relation to us providing advisory services;

• Screening service providers so that we can comply with legal obligations in relation to the prevention or protection of crime, anti-money laundering, sanctions screening, and other required checks;

• Advertising networks and analytics service providers to support and display ads on our website, app, and other social media tools;

• Third parties in the context of the acquisition or transfer of any part of our business or in connection with the business reorganization;

• Other delegates where your name will appear on the attendee list for events where you have told us you plan to attend.

Personal Data About Others

In some cases, you may provide personal data to us about other people (such as your customers, directors, officers, shareholders, or beneficial owners). You must ensure that you have given those individuals appropriate notice that you are providing their information to us and have obtained their consent to that disclosure.

Security

We will hold your information securely in line with physical, technical and administrative security measures. However, the transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal information, we cannot guarantee the security of your information transmitted and any transmission is at your own risk.

Where Will Your Information Be Held?

We are a global advisory firm, your information may be transferred out of your local jurisdiction or region. Data protection laws vary by country and those applicable in the USA and elsewhere are not equivalent to those applicable in, for example, the EU or certain other jurisdictions. Implement Legal will take steps to protect your information in line with locally applicable data protection requirements.

How Long Do We Keep Your Data?

We generally keep your information as needed to provide our advisory services and to deal with claims. This will depend on a number of factors such as whether you or your company or organization are an existing client or have interacted with recent client mailings or bulletins or attended recent events. We will retain your information as necessary to comply with legal, accounting, or regulatory requirements. 

Your Rights

You have certain rights in relation to your information. The availability of these rights and the ways in which you can use them are set out below in more detail.

Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact hello@implementlegal.com.

• Access: you are entitled to ask us if we are processing your data and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and certain other information about it;

• Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you be corrected;

• Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims;

• Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example, if you want us to establish its accuracy or the reason for processing it;

• Transfer: you may request the transfer certain of your personal data to another party;

• Objection: we are processing your personal data based on legitimate interests (or those of a third party) and you may challenge this. However, we may be entitled to continue processing your information. You also have the right to object where we are processing your personal information for direct marketing purposes;

• Consent: where we are processing personal data with consent, you can withdraw your consent.

If you want to exercise any of these rights, please contact hello@implementlegal.com.

Right To Object

You may have a right to object to us processing your information in certain circumstances. This applies where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes. 

Rights of European Union Residents
Pursuant to the European Union’s General Data Protection Regulation and other applicable data protection laws, data subjects within the European Union have certain rights that we are obliged to protect. You are entitled to request details of the information we hold about you and how we process it.

In certain circumstances, you also may have the right to have the information that we hold about you rectified or deleted, restrict our processing of that information, request that we stop unauthorized transfers of your personal information to a third party, and request that we do not transfer information relating to you to another organization.  You also may have the right to lodge a complaint in relation to Implement Legal’s processing of your personal information with a local supervisory authority. 

Where you object to our processing of your personal information, or where you withdraw consent previously given, we may not be able to achieve the purposes set out above or you may not be able to use our services and products.

Where you object to our processing of your personal information, or where you withdraw consent previously given, it is important to understand that we may be able to continue to process your personal information to the extent required or otherwise permitted by law, particularly in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations. 

Please inform us of any changes to your information by emailing us at hello@implementlegal.com so that we can keep your information up to date.

Direct Marketing 

As described above, you can opt out of receiving direct marketing from us at any time.

We may use the information you give us on our website or other means for direct marketing purposes to provide emails, newsletters, and other messages to keep you informed of industry developments, market insights, and our services including events that we think may interest you.

You can opt out of receiving direct marketing from us at any time. You can do this by clicking on the “unsubscribe” link included at the end of any marketing email we send to you or by emailing us at hello@implementlegal.com

Cookies

We use cookies that identify your browser. They collect and store information when you visit our website about how you use it through which it is possible to record your use of the website, as well as provide you with a better service and experience when browsing and for analytics. The personal data we collect through these technologies will also be used to manage your session.

For more information about cookies and how we use them, please see our Cookie Policy (below).

Our website, newsletters, email updates, and other communications may, from time to time, contain links to and from the websites of others. The personal data that you provide through these websites is not subject to this privacy notice and the treatment of your personal data by such websites is not our responsibility. 

If you follow a link to any other websites, please note that these websites have their own privacy notices which will set out how your information is collected and processed when visiting those sites.

Children

We do not knowingly collect information from children or other persons who are under 16 years old. If you are under 16 years old, you may not submit any personal data to us. 

Changes To This Notice

This notice may be changed from time to time. 

If we change anything important about this notice (the information we collect, how we use it or why) we will highlight those changes at the top of the notice and provide a prominent link to it for a reasonable length of time following the change. 

How To Contact Us 

If you would like more information about the way we manage personal data that we hold about you, please contact us at hello@implementlegal.com.

What are cookies?

Cookies are small text files that are stored in your computer’s memory and hard drive when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website. A cookie cannot read data from your hard disk or read cookie files created by other sites.

Why do we use cookies?

Our websites (www.implementlegal.com or www.implementtools.com) use cookies to distinguish you from other site users. This helps us to provide you with a good experience when you browse our sites and also allows us to improve our sites. By continuing to browse the sites, you are agreeing to our use of cookies.

In broad terms, we use the following cookies:

Session management cookies. The software that runs our sites uses cookies for technical purposes needed by the internal workings of our servers and applications. For instance, we use cookies to keep track of information about a user’s session and determine which options or pages to display in order for the sites to function.

Strictly necessary cookies. These are cookies that are required for the operation of our sites. They include, for example, cookies that enable you to log into secure areas of our sites, such as (if applicable to you) the membership area of Implement Tools.

Analytical/performance cookies. These cookies allow us to recognize and count site visitors and to see how visitors move around our sites when they are using them. This helps us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily. For these purposes, we may store the following information:

• your browser type

• the name of the domain from which you accessed the internet

• the date and time you accessed our sites

• the advert or internet address of the site from which you linked directly to our sites

• the pages you accessed while visiting our sites and the links you followed

• the device from which you accessed our sites

• the location from which you accessed our sites

• the search terms you used

In addition, we use third-party service providers to provide certain analytics services to us in connection with the operation of the sites, including (without limitation) the collection and tracking of the data and information listed above. We may disclose visitor data, including personal data, to enable those third-party service providers to provide their services. This data may be sent to those third-party service providers and their local overseas suppliers, where the standard of data protection may be lower than the country in which you reside.

Targeting cookies. These cookies record your visit to our sites, the pages you have visited and the links you have followed. We use this information to make our sites and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose. For example, if you click through to one of our sites from one of our emails or landing pages, we use cookies to connect the marketing you have received with your website journey. This helps us to provide you with the best user experience and relevant content.

Functionality cookies. These cookies are used to recognize you when you return to our sites and enable us to remember the choices you make when using our sites.

Third party cookies

Please note that, when you visit our sites, you may also receive cookies set by third parties (including, for example, advertising networks and providers of external services such as web traffic analysis services). We have no control over these cookies; however, they are likely to be analytical/performance cookies or targeting cookies.

Amending cookie preferences

If you prefer not to receive cookies through our sites, you may set your browser to warn you before accepting cookies and refuse the cookies when your browser alerts you to their presence. You may also delete cookies that have already been placed on your device or refuse all future cookies by turning them off in your browser. You do not need to have cookies turned on to use any pages within our site at www.implementlegal.com or www.implementtools.com.

The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. But you may find further guidance, together with more information on cookies, at: www.allaboutcookies.org.

Last Update: November 2023