Privacy Policy

SESTEIN LTD aims to protect your privacy and cares about the way in which your personal information is treated..

This Privacy Policy describes our approach to the collection of personal information from you and the reasons for using them. This Policy also informs you of your rights in respect of our processing of your personal information.

In a nutshell it sets out:

what personal information we collect about you
how we obtain your personal information
how we use your personal information
use of our website
on what basis we use your personal information
how long we keep your personal information
who we share your personal information with
how we protect your personal information
which countries we transfer your personal information to
your rights regarding your personal information
our marketing policy
links to third party websites
children
changes to this Policy

What personal information we collect about you

Whether you are a visitor to our website, or an individual or corporate, prospective or an existing client, in receipt of our services, or a potential recruit, we may collect only the most relevant, proportionate for each purpose and the strictly necessary personal information from you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage our legal or other services or as a result of your relationship with one or more of our staff and clients.

The personal information that we collect and process includes:

Basic information including your name, surname (including name prefix or title), job title and/or position and/or role and your relationship to a person.
Contact information including the company you work for, telephone (s) (including mobile telephone number where provided) and email address.
Social media account, where appropriate, and likes, posts, tweets and other interaction with our social media presence.
Demographic information such as your postal and/or other addresses, preferences and interests.
Financial and/or payment information, such as payment-related information
Relevant information, such as identification and background information, as required by Know Your Client and/or Anti-Money Laundering regulations and as part of our client intake procedures and business acceptance processes. This may possibly include evidence of source of funds, at the outset of and possibly from time to time throughout our relationship with clients, which we may request and/or obtain from third party sources. The sources for such verification may comprise documentation which we request from you or through the use of online sources or both.
Areas or topics that interest you.
Other information relevant to potential recruitment to SESTEIN LTD
Curriculum vitae, including your age and/or gender if you provide it to us, your education, employment history and similar matters and information that you may provide to us.
Technical information: when you access this website and our technology services being IP address, browser type and version (e.g. Google Chrome, Internet Explorer, Firefox, Safari etc.), time zone setting, browser plug-in types and versions, operating system you are using (e.g. Vista, 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 as 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.

SESTEIN LTD does not collect personal data about your online activities across third party websites or online services.

Criminal record information: where permitted by national law and appropriate to do so, such as existence of prior criminal offences (or confirmation of clean criminal record).The above data will be provided to us by you, your employer, the company or organisation who is our client or screening providers who assist us with our legal obligations to conduct under anti-money laundering, sanctions screening and regulatory checks.
Information you provide to us for the purposes of attending meetings and events, including dietary requirements which may reveal information about your health or religious beliefs.
Other information relevant to the provision of our services, such as personal information identifying you in relation to matters on which you instruct us, (which depends in the nature of your instructions) or in which you are involved.

SESTEIN LTD is primarily engaged by corporate entities and as such those instructors are not data subjects. However, as part of such instructions personal information may be provided to us (e.g. personal information relating to any of our corporate clients’ or prospective clients’ officers or personnel, any opponent or vendor or purchaser or personal information relating to their legal advisors or personnel, as relevant or similar).

If you are an individual whose personal information is processed by us as a result of providing services to others (including individual clients and corporate clients) we will process a variety of different personal information depending on the services provided.

This may include personal information relating, without limitation, to any of our corporate clients’ or prospective clients’ officers or personnel, any opponent or vendor or purchaser personal information including personal information relating to their legal advisors, other advisors or personnel as relevant or similar.

We might also need to process personal information which may include special categories of data, in relation to other third parties instructed either by our own clients or other persons or companies involved with us providing the services to our client (for instance other law firms, accountants, auditors, consultants, experts etc.).

This is a non-exhaustive list which is reflective of the varied nature of the personal information processed as part of a law firm providing legal services.

The reason we collect personal information from you is to help us:

verify your identity
deliver our services
improve, develop and market new services and/or products
carry out requests made by you in relation to our services
investigate or settle inquiries or disputes
comply with any applicable law, court order, other judicial process, or the requirements of a regulator
enforce our agreements with you
protect the rights, property or safety of us or third parties, including our other clients and users of the website or our services
with recruitment purposes, and
use as otherwise required or permitted by law.

How we obtain your personal information

We collect information from you as part of our business acceptance processes and about you and others as necessary in the course of providing legal services.
We collect your personal information while monitoring our technology tools and services, including our website and email communications sent to and from SESTEIN LTD. We gather information about you when you provide it to us, or interact with us directly, for instance engaging with our staff or visiting our website.
We may collect or receive information about you from other sources, such as keeping the contact details we already hold for you accurate and up to date using publicly available sources.

How we use your personal information

We collect and process personal information about you in many ways, including through your use of our website and during the provision of services by us. We use that information:

To provide and improve this website, including auditing and monitoring its use
To provide and improve our services to you and to our clients, including handling the personal information of others on behalf of our clients
To perform our obligations in accordance with any contract that we may have with you for the provision of our services
To provide information requested by you
To promote our services, including sending legal updates, publications and details of events
To manage and administer our relationship with you and our clients
To fulfil our legal, compliance & regulatory and risk management obligations, including establishing, exercising or defending legal claims
To comply with any legal obligations imposed upon us.
For the purposes of recruitment of the Firm’s personnel

Use of our website

Our website uses Google Analytics, a web-based analytics tool that tracks and reports on the manner in which the website is used to help us to improve it. Google Analytics does this by placing small text files called ‘cookies’ on your device. The information that the cookies collect, such as the number of visitors to the site, the pages visited and the length of time spent on the site, is aggregated and therefore anonymous. Please also see “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/) and our Cookies Policy.

You may refuse the use of cookies or withdraw your consent at any time by selecting the appropriate settings on your browser but please note that this may affect your use and experience of our website. By continuing to use our website without changing your privacy settings, you are agreeing to our use of cookies. To find out more about cookies, including how to manage and delete them, visit www.allaboutcookies.org.

On what basis we use your personal information

It is necessary for us to use your personal information;

To perform our obligations in accordance with any contract that we may have with you to provide you with legal and/or other services
To represent a client in the establishment, exercise or defend of legal claims, proceedings and/or negotiations inside and outside the courtrooms.
As t is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the services in the best way that we can.
As it is our legal obligation to use your personal information to comply with any legal, compliance or regulatory obligations imposed upon us.

How long we keep your personal information

For visitors to our website, we will retain relevant personal information for at least five (5) years from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation, or for longer if we are required to do so according to our regulatory and/or compliance obligations or professional indemnity obligations.

For service provision to any client, we will retain relevant personal information for at least (5) five years from the date of our last interaction with that client and in compliance with our obligations under the EU General Data Protection Regulation, or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations. We may then destroy such files without further notice or liability.

Who we share your personal information with

We may share personal information with a variety of the following categories of third parties as necessary:

Our professional advisors such as our affiliated corporate services and administration providers, lawyers and accountants.

Government or governmental agencies, regulatory authorities, courts and law enforcement agencies. We may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.
Professional indemnity or other relevant insurers.
Regulators/tax authorities/corporate registries.
Appropriate parties in the event of emergencies: in particular to protect health and safety of our clients, staff and organisations.
Screening service providers: so that we can comply with legal and compliance obligations in relation to the prevention or protection of crime, anti-money laundering, sanctions screening and other required checks.
Advertising networks: to support and display ads on our website, apps and other social media tools.
Third parties to whom we outsource certain support services such as, without limitation, document processing and translation services, photocopying and document review, confidential waste disposal, IT systems and/or software and/or storage providers, IT Support service providers, document and information storage providers.
Third parties engaged in the course of the services we provide to clients such as counsel, arbitrators, mediators, officers, witnesses, court, opposing party and their lawyers, document review platforms and experts such as tax advisors or valuers.
Third parties involved in hosting or organising events or seminars.
Third party service providers to assist us with client insight analytics, such as Google Analytics.
Third party postal or courier providers who assist us in delivering our postal marketing campaigns to you, or delivering documents related to a matter.
Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide our services as effectively as we can.

We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.

Which countries we transfer your personal information to

In order to provide our services we may need to transfer your personal information to locations outside the jurisdiction in which you provide it or where you are viewing this website for the purposes set out in this privacy policy. This may entail a transfer of your information from a location within the European Economic Area (the “EEA”) to outside the EEA, or from outside the EEA to a location within the EEA. The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this happens, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws and the EU General Data Protection Regulation.

Your rights regarding your personal information

You have the following rights in relation to the personal information we hold about you. Please note that some of these rights will only apply in certain circumstances and some of them may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of confidentiality obligations.

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 is 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 us to help you request the transfer certain of your personal data to another party;
Objection: where 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;
Automated decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.
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 us at info@sestein.tech. You also have a right to lodge a complaint with a Data Protection Supervisory Authority, in Cyprus, where you are habitually resident, or where an alleged infringement of Data Protection law has taken place.

How we protect your personal information

We use a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with the applicable data protection laws and the EU General Data Protection Regulation. We have also implemented appropriate information security policies, rules and technical measures to secure your personal information collected by us. Your personal information is saved in an encrypted form.

All of our partners, employees, consultants, workers and data processors (i.e. those who process your personal information on our behalf,), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information.

Our Marketing Policy

You have the right to object where we are processing your personal information for direct marketing purposes. This means 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 legal developments, market insights and of 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 contacting us at info@sestein.tech.

We use personal information to understand whether you read the emails and other materials, such as legal publications, that we send to you (where you have given your consent to be sent such materials), click on the links to the information that we include in them and whether and how you visit our website after you click on that link (immediately and on future visits). We do this by using software that places a cookie on your device which tracks this activity and records it against your email address. Removal of this cookie will not affect your experience on our websites.

Links to third party websites

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 in any case subject to this Privacy Policy and the treatment of your personal data by such websites is not our responsibility.

You should consult the other websites’ Privacy Policy notices which will set out how your information is collected and processed when visiting those websites, as we have no control over information that is submitted to, or collected by, these third parties.

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 Policy

We may make changes to this Privacy Policy from time to time. To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.