IMPORTANT INFORMATION AND WHO WE ARE

This privacy policy aims to give you information on how the Firm collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletters or fill in our contact form.

It is important that you read this privacy policy so that you are fully aware of how and why we are using your data.

Avery Law LLP is the controller and responsible for your personal data (collectively referred to as the "Firm", "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy or our privacy practices, please contact our us by email at data@avery.law.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• "Identity Data" includes first name, maiden name, last name, title, date of birth and gender.
• "Contact Data" includes address, email address and telephone numbers.
• "Transaction Data" includes details about services you have received from us.
• "Profile Data" includes services provided to you, feedback and survey responses.
• "Usage Data" includes information about how you use our website and services.
• "Marketing and Communications Data" includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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HOW IS YOUR PERSONAL DATA COLLECTED?

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We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: use our services; subscribe to our publications; request marketing to be sent to you; give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details. We receive Technical Data from the analytics providers such as Google based outside the EU.
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HOW WE USE YOUR PERSONAL DATA

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We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by clicking on the unsubscribe link in any marketing email or by contacting us.

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PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

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We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

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• To engage you as a new client (type of data: (a) Identity (b) Contact), lawful basis for processing including basis of legitimate interest: Performance of a contract with you.
• ‍To manage payments, fees and charges and collect and recover money owed to us (type of data: (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications), lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us).
• ‍To manage our relationship with you. (type of data: (a) Identity (b) Contact (c) Profile (d) Marketing and Communications), lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how our clients use our services).
• ‍To use data analytics to improve our website, services, marketing, client relationships and experiences. (type of data: (a) Technical (b) Usage, lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
• ‍To make suggestions and recommendations to you about our services that may be of interest to you (type of data: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications), lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our services and grow our business).

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing).You will receive marketing communications from us if you have requested information from us or engaged us for our services and you have not opted out of receiving that marketing.We will not share your personal data with any third party for marketing purposes.from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

OPTING OUT

You can ask us to stop sending you marketing messages at any time checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time by email to data@avery.law.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you engaging us for our services.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

TRANSFERS OF PERSONAL DATA

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We have adopted cloud-based systems and share your personal data with the operators of these systems. This will involve transferring your data outside the European Economic Area ("EEA"). In each case we and our processors employ mechanisms to safeguard your persona data, such that:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of or self-certified to the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory or other requirements.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• ‍Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• ‍Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• ‍Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• ‍Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data.
• ‍Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• ‍Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.