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Privacy policy

Who we are and our privacy statement

Ogier is an international law firm and corporate services provider which operates through a number of separate legal entities, partnerships or representative offices in thirteen international locations being Beijing, BVI, Cayman Islands, Dubai, Guernsey, Hong Kong, Ireland, Jersey, London, Luxembourg, Shanghai, Singapore and Tokyo.  

Ogier is committed to protecting the privacy and security of your personal information (defined below). The following statement sets out our privacy statement which is issued on behalf of ogierproperty.com and explains how we process your data as part of conducting our business. 

References to "Ogier", "we", "our" "us" and "the firm" within this statement means the relevant entity or partnership in Ogier responsible for processing your data. The entity or partnership with which you contract will be set out in any engagement letter or email. A list of the Ogier entities within Ogier is set out within our legal notice

For the purposes of this statement, "Data Protection Legislation" means all applicable legislation relating to privacy or data protection in force from time to time including any statute or statutory provision which amends, extends, implements, consolidates or replaces the same, including without limitation, the EU General Data Protection Regulation 2016/679 ("GDPR"), and the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore, and a "controller" or "processor" shall have the same or equivalent meaning as given to it under applicable Data Protection Legislation. 

Where we are data controllers

Data controllers are the persons who are responsible for determining the purposes for which and the manner in which any personal information is, or is to be processed.

The data controller for this website is Ogier Legal Shared Services Limited. Certain other Ogier websites may be operated under separate agreements having additional terms and conditions.

Where necessary under applicable Data Protection Legislation, the relevant Ogier entity has been registered with the relevant authority as a "data controller".

To contact any of the data controllers directly, see our legal notice for contact details.

Who do we collect information on

This privacy notice applies to the following individuals whom we collect personal information from or about: 

  • visitors to our websites ogierproperty.com. 
  • those who request a quote through the website.

How we collect and use personal information about you

We collect personal information either directly from you when you request a quote from us through our website tool.

By using our website or otherwise contacting us, obtaining services from us or by providing your personal information to us via the forms or contact options on this website you acknowledge that you have read and understood this privacy notice.

General visitors to ogierproperty.com 

No personal information is collected about general visitors to our website. However, in addition to the information collected by us in accordance with this privacy notice, your browser supplies some basic information about your visit. The collection of this information is common practice and is used to analyse and understand how the website is being used.

Personal information provided via ogierproperty.com

You can choose to provide personal information by completing any of the following types of forms or using any of the email addresses on the site: 

 

The personal information we hold and why

Personal information means any information about you from which you can be identified.  

There are "special categories" of more sensitive personal information which may only be collected for specific reasons and/or require a higher level of protection under applicable Data Protection Legislation (for example where it is necessary to accurately establish or verify an individual's identity to a high degree of fidelity). These include information regarding race, health, genetic information and biometric data, religious beliefs, sexual orientation, criminal convictions, political opinions. 

For each of the purposes for which we process information, we rely on one or more of the following legal justifications: 

  • Contractual necessity. Personal information is processed in order for us to discharge our contractual relationship with our client. 
  • Legitimate interest and/or business improvement. Personal information is processed in circumstances which can balance our legitimate interests with your own legitimate interests and in accordance with applicable Data Protection Legislation. We consider our legitimate interests to include: (a) providing legal and corporate services; (b) carrying out such services effectively and efficiently; and (c) communicating with you in respect of those aspects of our services which we consider to be of relevance to you. 
  • Legal and regulatory requirement. Personal information is processed in order for us to comply with a legal obligation (other than one imposed by a contract). 
  • Consent. Personal information is processed on the basis of consent given by you (where legally required). We will only seek to rely upon your consent where no other legal justification is available to us. 
  • Legal proceedings, etc. Personal information is processed on the basis that it is necessary for (a) any legal proceedings; (b) obtaining legal advice; or (c) establishing, exercising or defending legal rights, and in accordance with applicable Data Protection Legislation. 
  • Explicit Consent. Special category data where used for identification purposes, is subject to additional controls and protections. We therefore obtain your explicit consent in order to process such data for the purposes of verifying your identity in order to comply with anti-money laundering, compliance screening and to prevent fraud and other crimes.  

These are a breakdown of the categories of personal information we process about you:

Client data

Data type:

Your contact details such as your full name, postal address, email or other electronic communication addresses and telephone numbers.

  • In certain circumstances we may also record your job title and other identification information to the extent permitted under relevant laws.
  • Any other personal information which you may provide to us. 

Our purpose:

  • Performing the service which we have been engaged to provide.
  • Facilitating effective client and matter management including collation of know-how materials, and generating internal financial and marketing reports; facilitate administrative or operational processes within our business, for example assessing legal and financial risks to our business and debt management including credit control and collecting debt.
  • Engaging other service providers to provide services to you in connection with the engagement.
  • Improving and developing our products and services including carrying out analysis on Ogier's performance to ensure that our client care is of the highest standard.
  • Providing access to our online services.

Our legal basis:

  • Contractual necessity and legitimate interest and/or business improvement.

Our legitimate interest explained:

  • Delivering our services to our clients, developing those services and managing, maintaining and developing our relationships with our clients.

Communication data

Data type

Any communication that you provide us whether that be through the contact forms on our website, through email, social media messaging or any other communication that you send us.

Our purpose

We process this data for the purposes of communicating with you, to respond to requests, enquiries or complaints received, for record keeping and for the establishment, pursuance, or defence of legal claims.

Our legal basis

Contractual necessity and legitimate interest and/or business improvement.

Our legitimate interest explained

Delivering our services to our clients, developing those services and managing, maintaining and developing our relationships with our clients.

Website user data

Data type

We collect information about your visit (for example, date and time of your visit), including the uniform resource locators (URLs) of websites that referred you to the website and the path you take through the website, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from the page, and any phone number used to connect with us.

Our purpose

  • To compile anonymous statistics, for example, website usage statistics.
  • Undertaking maintenance, testing or development of website, forms, or processes.
  • To protect our reputation and interests where it is appropriate to do so. We will for example use personal information collected though our website to block malicious actors or report them to the authorities.

Our legal basis

Legitimate interest and/or business improvement.

Our legitimate interest explained:

  • To enable us to properly administer our website and our business. To ensure its security and maintain back-ups of our website and/or databases and to enable publication.

Technical data

Data type

Technical data that includes internet protocol ("IP") address (the internet address of your computer) used to connect your computer to the internet, the type of computer you are using, the type and version of the browser, operating system and platform you are using, time zone setting, browser plug-in types and version.

Location data that is collected through our website as to your real time location. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to our website.

Delivery of location services will involve reference to one or more of the following:

  • The coordinates (latitude/longitude) of your location.
  • Look-up of your country of location by reference to your IP address against public sources; and/or your identifier for advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier.

Our purpose:

  • To provide location services, where requested or agreed to by you, in order to allow check-in.
  • To deliver content or advertising that are dependent on knowing where you are.

Our legal basis

Legitimate interest and/or business improvement.

Our legitimate interest explained

Delivering our services to our clients, developing those services and managing, maintaining and developing our relationships with our clients.

Our use of cookies

Cookies are small text files that many internet sites automatically download to a user's computer to store information. Our website uses cookies to collect anonymous information about how visitors use our website, for example which pages visitors go to most often. We use this aggregated information to manage the performance and design of the site. You do not have to accept cookies from our website.

Certain of the aforementioned technical and location data are also collected using our cookies and similar tracking technologies. See our cookie policy for more information on the use of cookies and device identifiers on our website, systems and applications (where applicable).

As a business regulated by the SRA, we are required to include a digital badge on our website so that you can check that we are regulated and that this website is operated by us. The digital badge is hosted by a business called Yoshki and as such, if you click on the digital badge, you will be subject to Yoshki's privacy policy.

If you would like to learn more about cookies you can visit www.allaboutcookies.org for more information.

Automated decision making

Ogier does not have systems or procedures that make a decision without human intervention. Therefore there are no circumstances where decisions will be taken about you using fully automated means. 

Use of Hotjar

We use Hotjar in order to better understand our users' needs and to optimise this service and experience. Hotjar is a technology service that helps us better understand our users' experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don't like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users' behaviour and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymised user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. 

For further details, see the 'about Hotjar' section of Hotjar's support site.

Transfer of information within Ogier and with other third parties

We may transfer your personal information to others where it is necessary to fulfil one or more of the purposes outlined above and this may also include sharing your information with a third party as part of an outsourcing or other data processing arrangement. Where we share your personal information, whether internally or externally, we will ensure that the sharing of such data is kept to the minimum necessary. 

The following is a list of the potential recipients of your information: 

  • another member of Ogier. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose in accordance with any legal justification under applicable Data Protection Legislation (including but not limited to consent to the extent that such consent is required under applicable Data Protection Legislation); 
  • any sub-contractors, agents or service providers providing services to any member of Ogier, including without limitation, our information technology and telecommunications providers, auditors, consultants, insurers, providers of background checks and business risk screening, third parties for marketing or business development purposes and so on; 
  • any registrar of a public register where the data is to be held in a public registry; 
  • a regulatory, governmental or judicial authority with whom we are legally obliged to share your information; 
  • in relation to information obtained via our website and/or business systems/applications (where applicable), analytics and search engine providers that assist us in the improvement and optimisation of our website, subject to our cookie policy. 

To the extent permitted under applicable Data Protection Legislation, we reserve the right to share your information with other third parties in the context of a possible sale or restructuring of the business or part thereof. 

We will seek to ensure that our suppliers and service providers are contractually bound to process your personal information in line with our policies and in accordance with applicable Data Protection Legislation (including incorporating adequate contractual provisions under Data Protection Legislation into services or supply agreements) and ensure that they have adequate measures in place to protect your information from unauthorised access, disclosure, loss or destruction. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information only in accordance with our instructions. 

We have a data sharing agreement in place between Ogier partnerships and entities to enable information to be shared across the businesses in accordance with applicable Data Protection Legislation. In such circumstances, different Ogier entities may be joint controllers of your personal information. We have a robust Data Protection Policy to which all partners and employees of Ogier must adhere to ensure appropriate and legitimate data access and processing. 

Cross border transfers

As part of the transfer of information within the Ogier Group or with third parties, your personal information may be transferred to or accessed by the recipients described above from countries located anywhere in the world. 

These countries may have differing (and potentially less stringent) laws relating to the degree of protection afforded to personal information. 

Where your information is processed outside of your local jurisdiction or region, we (or our permitted third parties) will take steps to ensure that your personal information is protected in accordance with applicable Data Protection Legislation by ensuring that either: 

  • you have expressly consented to the cross border transfer (where legally required); or 
  • the recipient is in a country which has been deemed to have an adequate level of protection under applicable Data Protection Legislation or if the recipient is in the United States of America, that they are part of the privacy shield; or 
  • the recipient is contractually bound to protect the information to the same or higher standards under applicable Data Protection Legislation applicable to the data being transferred. 

Whilst we operate in jurisdictions which have not been deemed to provide an adequate level of protection under applicable Data Protection Legislation, we have a global Data Protection Policy which means all of our entities or partnerships operating in these jurisdictions are required to meet the same standard as our other offices. 

Where necessary, we may implement organisational, contractual and legal measures (for example through the implementation of an intra-group data transfer agreement) to ensure that your personal information is protected to the standard required in your local jurisdiction/region. 

Your rights

You may have certain legal rights in respect of the personal information which is processed by Ogier pursuant to applicable Data Protection Legislation. These include:

Your right

Explanation

Right to be informed

To know what personal data we process, how and why.

Right to access

To request access to your personal information and information about how we process it.

Right to rectification

To have your personal information corrected if it has changed, is inaccurate or incomplete.

Right to erasure (also known as the right to be forgotten.)

To have your personal information erased if it incorrect or no longer serves a valid purpose.

Right to data portability

To electronically move, copy or transfer your personal information in a standard form.

Right to restrict processing

To restrict the processing of your personal data in a specific way.

Right to withdraw your consent

To withdraw your consent previously given to the processing of your data.

The rights set out above are subject to certain exemptions and conditions. We may decline to comply with any request to access, correct, delete or restrict the use of your information if there is a specific legal ground or exemption.

Where we are processing your information on the basis of contractual necessity or legal and regulatory requirement, it is likely that the provision and processing of such information will be mandatory. In addition, where the provision of your personal information is generally a contractual or legal requirement, or is a requirement in order for us to enter into a contract, in the event that you choose not to provide any personal information or to exercise one or more of the rights above to restrict the processing of your information, this may restrict the services which Ogier is able to provide or we may have to decline to act on your behalf.

You may also withdraw consent to the processing of your personal information. However, if there is another legitimate basis for processing your personal information or if there is another legitimate basis for processing information in accordance with Data Protection Legislation, the same information may be processed without your consent. Do note that you may be allowed to withdraw consent for any optional purposes that your personal information is collected, processed and transferred without concurrently withdrawing consent for the necessary purposes that your personal information is collected, processed and transferred (for example for the provision of products/services that we offer).

Should you wish to exercise any of your rights you should send your request to dpo@ogier.com. We will respond to your request in accordance with Data Protection Legislation.  

We reserve the right to ask for proof of your identity and address (such as a copy of your driving licence or passport - please do not send any original documents) and we also further reserve the right, in accordance with Data Protection Legislation, to request for additional information reasonably required to identify the specific information being requested or referred to, or any additional information reasonably required to confirm your identity.

To the extent permitted by Data Protection Legislation, we further reserve the right to charge you a reasonable fee for you to access your Personal Information, and for any additional copies of the materials provided, or to refuse to comply with the request.

Security

Ogier takes its responsibility to secure your information very seriously. We have put in place robust systems and policies and procedures to prevent and detect any incidents where your information may be subject to an unauthorised access, use or disclosure.

All third-party service providers and other entities within our group are required to take appropriate security measures to protect personal information in line with our policies. They are only permitted to process personal information for specified purposes and where appropriate, in accordance with our instructions.

In the unlikely event that there is a security breach, we will take all necessary steps to identify the cause and mitigate the effects. Where necessary, we will also notify you of such a breach in accordance with our obligations under the applicable Data Protection Legislation.

Retention

Ogier will keep your personal information for at least as long as necessary to fulfil the purpose for which we have collected it or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate and up-to-date and still required. In relation to client matters, it is Ogier's policy to retain data for 7 - 11 years depending on amongst others, the nature of the personal information and applicable laws pertaining to the retention of such personal information from the conclusion of the matter subject to the following exceptions:

  • where the matter relates to trust, wills and probate, or property in which case the personal information may be kept indefinitely;
  • where we consider it necessary to protect ourselves from a legal claim or potential dispute in connection with any services we have provided, we will keep the personal information for the relevant limitation period; or
  • where the personal information cannot be deleted for legal, regulatory or technical reasons.

Queries and complaints

If you have any questions in respect of this privacy notice, or the processing of your personal information, or you wish to exercise any of your rights referred to above please contact us by email to dpo@ogier.com.

If you are dissatisfied with our response and you wish to make a formal complaint to the data protection authority of the country where the relevant Ogier entity is located:

Guernsey

Supervisory Authority: Data Protection Authority (ODPA)

Website: https://odpa.gg

Address: Block A, Lefebvre Court, Lefebvre Street; St Peter Port, Guernsey, GY1 2JP

Jersey

Supervisory Authority: Office of the Information Commissioner (JOIC)

Website: https://oicjersey.org

Address: 2ND Floor, 5 Castle Street, St Helier, Jersey, JE2 3BT

Changes to this privacy notice

This privacy notice may be updated from time to time and any updates will be published on our website at ogierproperty.com.

This privacy notices was updated in November 2024.

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