In the course of its business activities, FrontCap Asia Limited (the “firm”) collects and processes the personal data of its clients, partners, prospects, job applicants and users of its website (https://www.frontcap.com/) (the “Data Subjects” or “you”). FrontCap Asia Limited attaches great importance to the protection of the privacy and personal data of Data Subjects and is committed to offering a high level of security to any personal data processed, in compliance with applicable data protection legislation and with the rules of professional conduct applicable to the legal profession.
This Policy is effective as of May 25th, 2018.
The firm reserves the right to make changes to this Policy at any time. In such case, the firmwill post the revised version on its website (https://www.frontcap.com/) and indicate the date last revised. Data Subjects are accordingly invited to periodically check the website for any possible revisions to this Policy.
FrontCap Asia limited is a limited company incorporated in Hong Kong with certificate number 2458244 and registered address Unit 2A, 17/F, Glenealy Tower, No.1 Glenealy, Central, Hong Kong. You can contact the firm by email at email@example.com
Legal grounds for processing: firstname.lastname@example.org
PERSONAL DATA COLLECTED
- In what context can data be collected?
The firm may collect and process personal data in the context the provision of its services, whenever you contact or request information from it. Most personal data are provided voluntarily by Data Subjects or by authorized third parties.
The firm also collects the personal data of the users of its website, www.frontcap.com, whenever they send us a request using the Contact Us form or apply for a position with us using the online form.
When browsing on www.frontcap.com cookies may collect personal data about you under the conditions set forth in the “Cookies”·section below.
Whenever the firm requests you to provide personal data, the firm will indicate whether such information is mandatory or not as well as, if applicable, any possible consequences of failure to provide such information.
Any information requested when submitting an online job application on the firm’s website is mandatory.
The firm makes all reasonable efforts to ensure that personal data are accurate and complete. To ensure that the information the firm has about you is up to date, let us know if there is any change in your contact details or other information.
- What types of data are collected?
The firm collects the following types of personal data:
- your contact details (surname, name, email address, profession, postal code, phone number, etc.);
- information about your professional situation (name of employer, position, etc.) and, if you are a job applicant, your qualifications (résumé, etc.);
- financial information, in particular for payment purposes; and
- more generally, any personal data provided in connection with the provision of services by the firm.
PURPOSES OF THE PROCESSING
The firm processes data necessary to achieve the following purposes:
- The day-to-day management of our relationship with our clients and the provision of our services:
- Management of client matters (contacts with clients, case assessments, assistance, defense of rights, advisory services, negotiations, etc.);
- Billing, client account management, management of delinquent accounts receivable and litigation;
- Management of job applications and the recruitment process (administrative management of the application, assessment of match between the applicant’s abilities and the requirements of the job (person-job fit), contacts with the applicant, etc.);
- Management of registrations for events and training organized by the firm.
- The promotion of our services, including, by way of example, invitations to events organized by the firm, mailing of a newsletter on trending legal issues and to offer similar services;
- Compliance with our legal and regulatory obligations;
- Recruitment purposes;
- Processing any requests submitted to us using the “Contact Us” form on the website;
- Managing requests by Data Subjects for the exercise of their rights
LEGAL GROUNDS FOR PROCESSING
Personal data is processed on the following legal grounds:
- For the performance of the services and assignments entrusted to the firm or in which we are involved;
- To comply with legal requirements, for example to comply with anti-money laundering legislation, to carry out conflict of interest checks or identity checks with new clients;
- To pursue our legitimate interests, while strictly complying with your rights, for example, the firm uses your data to offer you services similar to those for which you have already registered;
- For the establishment, exercise or defense of legal claims.
If you have any question or would like more information about the legal grounds the firm relies on for the processing of personal data, you can write to us at email@example.com.
DISLOSURE OF PERSONAL DATA
The personal data of Data Subjects can be shared among the lawyers, employees and administrative staff at the firm, all of whom are under a strict confidentiality obligation.
Personal data can also be shared, to the extent necessary, with (i) any third-party providing services in connection with the matters entrusted to the firm (local counsels or consultants, experts, translators, process-servers, etc.); (ii) our service providers, including IT service providers, for the purposes of conducting audits or checks; (iii) our communication providers; and (iv) judicial bodies and authorities.
If required, such data can be disclosed to the competent authorities or courts, in particular to comply with our legal and regulatory obligations. In case of legally required disclosure, the firm will make every effort to give you advance notice, unless the firm is prohibited by law from doing so.
As regards job applicants, their personal data will only be shared with those involved in the recruitment process (administrative staff involved in the recruitment, HR department staff, lawyers in the relevant department or team and the partners of the firm).
SECURITY OF PERSONAL DATA
The firm implements appropriate technical, organizational and software measures ensuring physical and software security to protect personal data against loss, unauthorized access, disclosure or alteration.
The firm may transfer your personal data to a service provider located outside the European Union. In such case, the service provider shall apply international binding corporate rules for processors and controllers authorizing the transfer of the personal data processed by the service provider on behalf of clients located in countries within the European Economic Area (EEA) to countries outside the EEA. These binding corporate rules have been validated by the competent European authorities.
You can obtain a copy of these rules by writing to the firm at the following postal address: FrontCap Asia Limited, 12 avenue d’Eylau 75116 Paris or at the following email address: firstname.lastname@example.org.
Cookies may be used when you browse the www.frontcap.com website. Cookies are text files saved on your connection terminal whenever you visit the firm’s website.
www.frontcap.com uses the following cookies:
- Google Analytics audience measurement cookies: these cookies are used to collect information anonymously about website users.
These cookies monitor your browsing on the website for statistical analysis purposes and help the firm get to know its audience better so as to improve its service.
You can obtain more information about the Google Analytics service by going here.
You can disable cookies at any time, free of charge, by changing the appropriate settings on your browser. The steps to be followed differing for each browser, you can find instructions in the “Help” menu of your browser, on the CNIL website at https://www.cnil.fr/fr/maitriser-mes-donnees (in French) or at https://www.allaboutcookies.org/ (in English and French).
However, if you disable cookies, you may not be able to use some of the features of the website.
The personal data processed by the firm are kept for as long as is strictly necessary to achieve the purpose for which such data were collected. Data in connection with the provision of legal services are kept for the duration of the contractual relationship between the firm and the client, after which time they will be securely archived for a period of five years, before being erased or anonymized, unless the applicable statute of limitation period is longer.
The personal data of job applicants will be kept by the firm for two years after the last contact between the firm and the job applicant, unless the applicant requests the erasure of his or her personal data records.
Cookie-related information is kept for a maximum of thirteen months.
RIGHTS OF CLIENTS AND JOB APPLICANTS
Data Subjects are informed that they have, in accordance with the law, a right of access, to rectification, to erasure and the right to the portability of their personal data, as well as a right to restrict processing and to object to the processing of their personal data.
Data Subjects also have the right to lodge a complaint with the CNIL (website: http://www.cnil.fr), 3 Place de Fontenoy, 75007 Paris.
When processing is carried out on the basis of consent, Data Subjects can withdraw their consent at any time.
Data Subjects can exercise these rights, free of charge, directly with the firm.
Find out more
In addition to reading the information provided below, the firm invites Data Subjects to consult the CNIL’s website at: https://www.cnil.fr/
- RIGHT OF ACCESS: Data Subjects have the right to obtain from the firm confirmation as to whether or not their personal data are processed and, if processed, to access such data and be informed of the purposes pursued by such processing (Art. 15 of Regulation 2016/679 on the protection of personal data (“GDPR”). No response may be forthcoming in case of requests that are manifestly unfounded, excessive, or repetitive.
- RIGHT TO RECTIFICATION: Data Subjects have the right to obtain from the controller, without undue delay, rectification of inaccurate personal data (Art. 16 GDPR).
- RIGHT TO ERASURE: Data Subjects have the right to obtain fromthe firm the erasure of their personal data, under the conditions set forth in Art. 17 GDPR.
- RIGHT TO DATA PORTABILITY: Data Subjects have the right to receive the personal data concerning them, which they have provided to the firm, in a structured, commonly used and machine-readable format (Art. 20 GDPR). This right only applies to data that has been provided by a Data Subject, when processing is based on consent or on a contract and is carried out by automated means.
- RIGHT TO RESTRICTION OF PROCESSING: Data Subjects may obtain from the firm the restriction of the processing of their personal data under the conditions set forth in Article 18 RPGD.
- RIGHT TO WITHDRAW CONSENT: Data Subjects have the right to withdraw their consent to the processing of their data when such processing is based on consent. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
- RIGHT TO OBJECT TO PROCESSING: Data Subjects have the right to object, on grounds relating to their particular situation, to the processing of their personal data, when such processing is based on the legitimate interest of the firm (Art. 21 GDPR).
- RIGHT TO GIVE INSTRUCTIONS ON WHAT SHOULD BE DONE WITH THEIR PERSONAL DATA AFTER THEIR DEATH: Data Subjects can give instructions regarding the storage, erasure and disclosure of their personal data after their death (Data Protection Act 78-17 dated January 6th, 1978, as amended, Art. 40, II).
- RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY: without prejudice to any other administrative or judicial remedy, Data Subjects have the right to lodge a complaint with a supervisory authority if they consider that the processing of personal data relating to them infringes data protection legislation (Art. 77 GDPR).
1. Legal Notice
The www.frontcap.com website (the “website”) is published by “FrontCap” (the “publisher), a French société d’exercice libéral à responsabilité limitée with share capital of €20,000, having its registered office at: 12 avenue d’Eylau 75116 Paris – electronic mail address: email@example.com.
This website is hosted by O2Switch, having its registered office at Clermont-Ferrand.
1.3. Publication Director
The website publication director is Gilles de Dumast.
2.1. – Proprietary Rights
This website (https://www.frontcap.com/), taken as a whole, as well as each of its components taken individually, including specific software and developments and contents including data, texts, still or animated images, logos, sounds, graphs, and files, are and shall remain the exclusive property of the publisher or its licensors. Any total or partial reproduction of the website or any of its components without the express consent of the publisher is strictly prohibited and constitutes infringement punishable under sections L.335-2 et seq. of the French Intellectual Property Code.
The trademarks and logos featured on the website are registered trademarks of the publisher or of third parties. Any reproduction, imitation or use, in whole or in part, of these distinctive signs without express authorization and in breach of the prohibitions laid down in sections L.713-2 et seq. of the French Intellectual Property Code shall be actionable.
Other distinctive signs, such as corporate names, trade names, signs and domain names featured on the website are the property of the publisher or of third parties and any reproduction without express authorization may constitute actional usurpation of identity punishable under section 1382 of the French Civil Code.
2.2. Management of website
For the proper management of the website, the publisher may at any time:
- Suspend, interrupt or restrict access to the website in whole or in part, or reserve access to the website, in whole or in part, to a specific category of users;
- Remove any information or materials that might impair the operation of the website or infringe national or international laws;
- Suspend the website in order to make updates.
The publisher agrees to make all reasonable efforts to ensure users have access this website at all times. However, it disclaims any and all liability in case of the unavailability of the website for any reason whatsoever.
By using this website, you agree that you have read and understood these ToU and agree to abide by the terms set forth herein.
You recognize having the necessary skills and equipment necessary to access and use the website and having checked that the IT configuration and equipment you use to access the website is error-free and virus-free.
The publisher makes no representations or warranties, express or implied, as to the completeness or accuracy of the information or materials contained on this website or as to its continued, error-free operation or that its use is completely secure.
The publisher makes all efforts to provide users with available and verified information and resources, but disclaims any liability for any errors or omissions, or for the unavailability of information and/or the presence of viruses or other worms, logic bombs or other malicious software on its website.
The content of this website is provided for information purposes only. The publisher cannot give any assurances that the information contained on the website is accurate, complete and/or up to date.
You agree that any use made by you of the information and materials available on the website shall be strictly at your own risk.
ALT: You agree that any use of, or reliance on, information and materials available on the website is strictly at your own risk.
2.4. Hypertext links
All hypertext links directing to this website, or any part of it, require express prior authorization from the publisher, which authorization may be revoked at any time. All links must be taken down promptly at the publisher’s request.
ALT: If users wish to place hypertext links directing to this website, or any part of it, they must obtain express prior permission from the publisher. All links must be taken down promptly upon request by the publisher.
2.5. Governing law
This website and any use made of this website is governed by and shall be construed in accordance with the laws of France. The courts of the location where the publisher has its registered office shall have jurisdiction over any claim or dispute in connection with this website or any use made of this website.
The publisher reserves the right to make changes to the content of this legal notice and to these ToU at any time and without prior notice. You are invited to consult this document from time to time to check whether any changes have been made.
2.7. Contact Us
If you have any question or would like more information about the website, you can write to us at: firstname.lastname@example.org.