Privacy Policy
BOCK PARTNER is a law firm registered with the Luxembourg bar, having its registered office at 75, rue de Strasbourg, L-2561 Luxembourg (“BOCK PARTNER” or “we” or “us” or “our”). We are committed to safeguarding the protection of personal data in accordance with the laws applicable to us, in particular the European General Data Protection Regulation 2016/679 of 27 April 2016 (the “GDPR”).
This Privacy Policy aims to inform data subjects about our personal data processing, including, but not limited to, the purposes and legal bases of the personal data processing, the categories of personal data that we collect, the categories of recipients of personal data as well as data subjects’ rights in relation to the processing of their personal data.
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The terms used in this Privacy Policy shall have the meaning attributed to them under the GDPR.
Data controller
This Privacy Policy applies to the processing of personal data by BOCK PARTNER, a law firm, acting as data controller.
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Purposes and legal bases of personal data processing
The purposes of our personal data processing are as follows:
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provision of legal services by BOCK PARTNER, including external data protection officer services, and compliance with our legal obligations
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general communications, including response to enquiries, management of requests and complaints, communications about our firm, services and events (including newsletters, client alerts, invitations to events and other marketing materials) and organisation of conferences and events
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operation of our website
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processing of applications for employment with our firm (HR recruitment)
The legal bases of the processing are as follows:
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processing for the purpose of provision of legal services by BOCK PARTNER, including external data protection officer services, and compliance with our legal obligations:
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legitimate interests and performance of a contract to which the data subject is a party (individual clients and signatories): processing of personal data necessary for the provision of legal services, invoicing/processing of payments
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compliance with legal obligations: due diligence and know-your-customer obligations, conflict check rules, compliance with anti-money laundering and counter-terrorism financing rules, accounting record keeping obligations, data protection obligations, including the management of data subjects’ requests, compliance with any other legal and regulatory obligations applicable to us
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legitimate interests of BOCK PARTNER: record keeping, communications, organisation of meetings, management of the law firm and its staff, legal defence of our rights
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processing for general communications, including response to enquiries, management of requests and complaints, communications about our firm, services and events (including newsletters, client alerts, invitations to events and other marketing materials) and organisation of conferences and events:
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legitimate interests of BOCK PARTNER to respond to enquiries, requests or complaints addressed to us and to develop its business by providing information about our firm, services and events to clients and other professional contacts and by organising conferences and events
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processing for the operation of our website:
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legitimate interests of BOCK PARTNER to ensure the proper technical functioning of our website or, as the case may be, consent of the website user to use of non-essential cookies and similar technologies.
For detailed information about our use of cookies and similar technologies and on how to manage cookie preferences, please check our Cookie Policy.
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processing of applications for employment with our firm (HR recruitment):
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legitimate interests of BOCK PARTNER to process job applications
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Categories of data subjects and of personal data
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BOCK PARTNER processes personal data regarding the following categories of data subjects:
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the clients using our legal services, which include natural persons who are direct clients but also individuals related to client entities, such as client representatives (employees, directors, shareholders of the client), service providers acting on behalf of a client (such as representatives of correspondent law firm acting on behalf of the client), individuals linked to the client under know-your-customer, anti-money laundering and counter-terrorism rules (such as ultimate beneficial or economic owners, counterparties involved in the client matter and their representatives), individuals concerned by the client’s matter for which our legal services are engaged (such as individuals involved in a dispute, counterparties, appointed lawyers, bailiffs, judges, other case workers)
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professional contact persons that we may need to communicate with for the purpose of the execution of our legal services or for the purpose of the management and operation of the law firm, including individuals working for third-party service providers of the firm, for administrative, regulatory, governmental, judicial or other public authorities/bodies or for professional bodies, associations or clubs
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users of our website
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anyone who sends us an enquiry and any professional contact persons to whom we may provide marketing information or communications
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job applicants
‘Personal data’ is any information that relates to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to that natural person.
The categories of personal data that we process include the following:
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processing for the purpose of provision of legal services by BOCK PARTNER, including external data protection officer services, and compliance with our legal obligations:
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contact details of the data subjects involved in the client matter, including first name, last name, job title and function, company name, email address, physical address, telephone numbers, and other similar identifiers;
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know-your-customer information, anti-money laundering and counter-terrorism financing related information, including KYC information about the client, its representatives and ultimate beneficial owners, contact details, activities and source of funds, links to other relevant individuals under applicable laws, place and date of birth, residency, citizenship, passport details, judicial/criminal convictions, status as a politically exposed person
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information related to the client matter which is necessary to provide our legal services and to comply with legal obligations
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payment and contractual data regarding the execution of our legal services, including invoicing information
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other information as necessary for BOCK PARTNER to provide the requested legal services
The personal data is collected from the client and/or its representatives as well as from third-party sources involved in the client’s legal matter, such as from counterparties, their representatives and lawyers ; from administrative, regulatory, governmental, judicial or other public authorities/bodies ; from third-party service providers and other public sources used by the firm to perform the necessary checks under know-your-customer, anti-money laundering and counter-terrorism financing rules.
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processing for general communications, including response to enquiries, management of requests and complaints, communications about our firm, services and events (including newsletters, client alerts, invitations to events and other marketing materials) and organisation of conferences and events:
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contact details, including first name, last name, job title and function, company name, email address, physical address, business telephone numbers and other similar identifiers, professional social media account details, and professional activities/areas of interest
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other information as necessary for BOCK PARTNER to respond to a specific enquiry, request or complaint
The personal data is collected from the person making the enquiry, request or complaint, from clients and their representatives and/or from other professional contact persons of the firm.
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processing for the operation of our website:
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technical and other data collected automatically through cookies and similar technologies, including Internet Protocol (IP) address, browser type and version, device type, browser plug-in types and versions, operating system and platform, information collected during the data subjects’ visits to our website
For detailed information about our use of cookies and similar technologies and on how to manage cookie preferences, please check our Cookie Policy.
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processing of applications for employment with our firm (HR recruitment):
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contact details, including first name, last name, physical address, telephone numbers, email address and other similar contact details
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professional and employment-related information, including career history, work experience, education, qualifications, training, language abilities as well as information collected from the recruitment process, such as CV, cover letter, reference letters, copies of diplomas or certifications, interview information, pre-hire interactions and communications
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citizenship, work authorisation and visa status
The personal data is collected from the job applicant. Former employers and/or references may be contacted with prior consent of the job applicant.
Failure to provide personal data, updates and third-party data
Where we have to collect personal data by law or in order to perform a contract and if such data is not provided when requested, we may not be able to enter into a contract to provide legal services or we may have to cease providing services.
We request that data subjects and clients inform us in writing and without undue delay about any changes in the personal data and information provided to us so that we can keep it up-to-date and provide services based on accurate information.
If a person provides information to us about other persons, such person must ensure that s/he is permitted to do so and that such persons understand how their personal data will be processed, notably by directing them to this Privacy Policy and by informing them about their rights as data subjects.
Disclosure of personal data
For the purposes referred to in this Privacy Policy and without prejudice to professional confidentiality rules, we may share the required personal data with the following categories of recipients:
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our clients and such clients’ representatives in the course of providing legal services to them
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our lawyers and staff
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authorised third-party service providers: We may disclose your personal data to processors that provide us with the services necessary for the achievement of the purposes described above, i.e. our third-party services providers that provide various types of professional services to the firm, including IT, accounting, invoicing, auditing services and companies that provide software for anti-money laundering and counter-terrorism financing checks, web analytics, marketing support or other services. These third parties are permitted to use personal data to the extent necessary to enable them to provide their services to us.
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other third parties as necessary to achieve the purpose of the data processing or when required by law: We may disclose personal data to other entities acting as independent controllers, such as administrative, regulatory, governmental, judicial or other public authorities or bodies or other relevant third parties involved in the client matter or in claims, disputes, litigation or investigations where disclosure is required by law or pursuant to legal process or is necessary to establish, exercise or defend legal claims, including to protect or defend clients’ rights or ours.
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other third parties subject to consent: There may be instances where we disclose personal data to other third parties based on your consent to such sharing, such as when we provide professional contact details of client representatives to legal directories for legal services’ ranking purposes.
International transfers
To provide legal services, we may transfer the personal information we collect to countries outside of the EEA which do not provide the same level of data protection as the country in which you reside and are not recognised by the European Commission as providing an adequate level of data protection. We only transfer personal information to these countries when it is necessary for the services we provide you, or it is necessary for the establishment, exercise or defence of legal claims or subject to safeguards that ensure the protection of personal data, in particular European Commission approved standard contractual clauses and other safeguards. For further details, please contact us at contact@bockpartner.com.
Data retention periods
BOCK PARTNER will retain personal data for no longer than is necessary to achieve the purposes of the relevant data processing extended by the applicable legal limitation periods. On expiry of the applicable data retention period, BOCK PARTNER will delete or anonymise the relevant personal data. The data retention periods are in principle as follows:
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processing for the purpose of provision of legal services by BOCK PARTNER, including external data protection officer services, and compliance with our legal obligations:
Data relating to a client matter will be kept for five years after end of the accounting year of completion of the matter to which the data relates. Accounting data will be kept for ten years after the end of the accounting year to which it relates.
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processing for general communications, including response to enquiries, management of requests and complaints, communications about our firm, services and events (including newsletters, client alerts, invitations to events and other marketing materials) and organisation of conferences and events:
Data will be kept for as long as required to respond to enquiries and to manage requests and complaints, plus the applicable legal limitation period. Data regarding communications about our firm, services and events will be updated from time t time unless a data subject exercises his/her an opt-out right.
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processing for the operation of our website:
Please refer to our Cookies Policy for the specific data retention periods applicable to cookies and similar technologies on our website.
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processing of applications for employment with our firm (HR recruitment):
Personal data collected from job applicants who do not receive an employment offer will be deleted at the latest six months after the termination of the relevant recruitment process. For applicants who are hired by the firm, BOCK PARTNER will continue to process personal data in accordance with the applicable employee data protection policy.
Data subjects’ rights
Subject to the conditions set out in the GDPR, data subjects have the following rights in relation to the processing of their personal data:
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Right of access: right to request confirmation as to whether or not a data subject’s own personal data is being processed and to receive a copy
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Right of rectification: right to request the rectification of inaccurate or incomplete personal data
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Right of erasure: right to request the erasure or deletion of personal data under the conditions defined in the GDPR. For example, this right does not apply if the processing is necessary to establish, exercise, or defend legal claims
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Right of restriction: right to request the restriction of processing of personal data under the conditions defined in the GDPR
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Right of data portability: for processing carried out by automated means and under the conditions defined in the GDPR, right to request a copy of the personal data in a structured, commonly used, and machine-readable format
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Right of objection: right to object, on grounds relating to a data subject’s particular situation, to the processing of your personal data. For example, a data subject can object at any time to the processing of personal data for direct marketing purposes
Right to withdraw consent
If a data subject has given consent for the processing of personal data, such data subject has the right to withdraw consent at any time. Once we receive notification of consent withdrawal, we will acknowledge receipt and stop processing the relevant personal data, unless another legal ground applies to such data processing and without prejudice to the lawfulness of the processing preceding the withdrawal of consent.
In particular, to opt-out of receiving marketing communications from us, please send us a message to contact@bockpartner.com. Opting out of receiving marketing communications will not affect the processing of personal data for other legitimate purposes, such as for the provision of legal services or compliance with legal obligations.
Questions and complaints
To exercise a data protection right and for any other question or complaints about our data processing, please email us at contact@bockpartner.com or write to:
BOCK PARTNER law firm
75, rue de Strasbourg
L-2561 Luxembourg
If - after having contacted us and received our explanations – a data subject still believes his/her data protection rights may be infringed, the latter may lodge a complaint with the National Data Protection Commission (www.cnpd.lu).
Third-party website links
The website may contain hyperlinks to websites of third parties. This Privacy Policy does not apply to such third-party content or websites for which BOCK PARTNER does not take any responsibility.
Revisions to this Privacy Policy
BOCK PARTNER reserves the right to change or update this Privacy Policy at any time. The applicable version of this Privacy Policy will be published on our website, which data subjects are invited to regularly consult, and an information about the update may also be sent in a separate communication.
Last Updated: 7 February 2024