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Asters Law Firm Attorneys' Partnership (`Asters`) respects your privacy and commits to collect, maintain and use your personal data responsibly. This Privacy Policy (the `Policy`) applies to all of your use of www.asterslaw.com (the `Website`). 

This Policy describes what personal data we collect about you, how we obtain it, why we process your personal data, and how it will be treated and protected as you use the Asters Website. It also sets out your rights in respect of our processing of your personal data.

This Policy does not apply to information provided to us in the course of our attorney-client relationships or which is confidential or subject to any other applicable protection. 

Asters is a full-service independent national law firm that has maintained a strong presence in Ukraine since 1995. With offices in Kyiv, Brussels, London and Washington D. C., the Firm provides efficient transactional legal advice and represents clients on a broad spectrum of matters arising in the course of doing business in Ukraine. 

1. What personal data we collect about you 

1.1. If you wish to receive customized newsletters, legal alerts or publications, you can contact us directly via the contact form available in the `Newsroom` section or in the footer area of the Asters Website on a voluntary basis, and provide us with:

(i) your contact information, such as your email address 

We use personal data to understand whether you read the emails and other materials, such as legal publications, alerts, newsletters that we send to you, 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 cookies on your device, which tracks this activity and records it against your email address. Please see Art. 1.5 for more information about cookies and how to manage and remove them.   

1.2. If you are a potential new hire to join Asters, you need to complete a form available in the `Careers` section of the Asters Website and provide us with the following information:

(i) name and position;

(ii) contact information, including email address;

(iii) a cover letter;

(iv) curriculum vitae, if any, including your age and/or gender, education, employment history and similar matters that you may provide to us; and

(v) other information relevant to potential employment with Asters. 

1.3. You can contact us directly via the contact forms available in the `Team` section of the Asters Website, clicking on the profile of a relevant partner or counsel, and provide us with the following information:

(i) name and position;

(ii) contact information, including that of your current employer, and email address, if any;

(iii) information that you give to us as part of us providing our services for you; and

(iv) other information relevant to the provision of the services 

1.4. If you want to look more closely into our representative experience in certain area, you need to download marketing materials. 

1.5.  The Asters Website uses “cookies”. Cookies are small text files that are stored in the memory of your terminal via your browser. 

We differentiate between two categories of cookies: (1) functional cookies, without which the functionality of our Website would be reduced, and (2) optional cookies, which are used for Website analysis and marketing purposes. 

1.5.1. Functional cookies

When you call up our Website, your browser will transfer certain data to our web server. This is done for technical reasons and required to make the requested information available to you. 

Our server logs capture information regarding your IP address, the date and time of the access, the time zone difference to Greenwich Mean Time (GMT), the content of the request (a specific website), the status of the access/HTTP status code, the transferred volume of data, the Website requesting access, browser, and language settings, the version of the browser software, and the operating system and surface. 

To protect our legitimate interests, we will store such data for a limited period in order to be able to initiate a tracking of personal data in the event of actual or attempted unauthorized access to our servers. 

Functional cookies do not require your consent. You may refuse the use of cookies at any time by selecting the appropriate settings on your browser but please note that this may affect your experience of using our Website. By continuing to use our Website without changing your privacy settings, you are agreeing to our use of cookies. 

1.5.2. Optional Cookies  

We only use optional cookies if we have obtained your prior consent. Upon your first access to our Website, a banner will appear, asking you to give us your consent to the setting of optional cookies: 

“We would like to use cookies to better understand your use of this website. This enables us to improve your future experience on our website. Detailed information about the use of cookies on this website and how you can manage or withdraw your consent at any time can be found in our Privacy Policy. By continuing to browse this website, you agree to the use of such cookies.” 

If your consent is given, we will place a cookie on your computer and the banner will not appear again as long as the cookie is active. After expiration of the cookie’s lifespan, or if you actively delete the cookie, the banner will reappear upon your next visit to our Website and again ask for your consent. 

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 will analyze your use of our Website on our behalf. 

Google Analytics does this by placing ‘cookies’ on your device. The information that the cookies collect, such as the number of visitors to the Website, the pages visited and the length of time spent on the Website, is aggregated and is therefore anonymous. 

You may withdraw your consent to the use of web analysis at any time, either by downloading or installing a Browser Plugin offered by Google. This option will prevent the use of web analysis only as long as you use the browser on which you installed the plugin or if you do not delete the opt-out cookie. 

Further information on Google Analytics is available in the Google Analytics Terms of Use, the Privacy and Data Protection Guidelines of Google Analytics and in the Google Privacy Policy

2. How we obtain your personal data

A number of facilities on our Website invite you to provide us with personal data. We gather information about you when you provide it to us, or interact with us directly or indirectly, for example, by auditing and monitoring the use of the Website. 

You are not required to provide any information to the Asters Website. 

You may choose to do so:

(i) by completing online forms available in several sections of the Asters Website, including: `Team`, `Newsroom`, `Careers`;

(ii) by email queries;

(iii) by downloading marketing materials from our Website;

(iv) by sending us your consent to collect your cookies. 

3. How we use your personal data 

We may use your personal data to:

(i) handle requests made on the Website ;

(ii) contact you with new services and details, which might be of interest to you;

(iii) provide/deliver the services requested by individuals;

(iv) improve, develop and market new services;

(v) invite and register individuals for events;

(vi) improve the Asters Website by measuring any errors that occur;

(vii) manage our relationship with individuals who access our Website;

(viii) deliver targeted advertising and marketing;

(ix) for the purposes of recruitment;

(x) for any such other purposes as may be required or permitted by law. 

4. Legal basis for processing your personal data 

The majority of personal data collected by Asters is provided by you voluntarily on the Asters Website. The remaining personal data is collected for Asters legitimate business purposes, for example to monitor and improve the quality of the Asters Website and our services, and to protect and defend our rights, properly or safety or that of our clients and other users of the Asters Website. 

5. Who we share your personal data with 

Asters may disclose and/or transfer your personal data: 

(i) to its trusted party service providers: companies that provide web hosting, IT services; service providers to assist us with client insight analytics, such as Google Analytics; suppliers to whom we outsource certain services as, without limitation, document processing and translation services; postal or courier providers; providers involved in hosting or organizing events or seminars etc.;

(ii) if required by applicable law;

(iii) in connection with a reorganization or combination of our firm with another one;

(iv) in order to comply with a court order;

(v) with your consent. 

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 the services as effectively as we can or to protect and defend the Asters rights and safety or that of our clients and other users of the Website. 

Whenever we share personal data about users of the Asters Website with our trusted third parties, we will put in place appropriate contracts containing standard data protection clauses to protect the rights of individuals.

Based on respective data processor agreements, they will only process personal data upon our instruction and strictly in accordance with our directives. 

6. Where do we transfer your data to 

In order to provide the services we may need to transfer your personal data to locations outside the jurisdiction in which you provide it or where you are viewing this Website for the purposes set out in this Policy.

If you are based within the European Economic Area (EEA), please note that where necessary to deliver the services we will transfer personal data to countries outside the EEA. For example, the information collected by Google Analytics will be transmitted to a server of Google in the US, where it will be stored and analyzed. 

The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal data remains protected and secure in accordance with applicable data protection laws.   

7. How long we keep your personal data 

We retain information that is collected through the Asters Website only for as long as needed for the purposes for which it was provided, or as otherwise required for our legitimate business purposes. Your information may be retained for longer periods if there are valid legal grounds, for example if required by law or court order or to defend or pursue legal claims. 

Your personal data will be retained in accordance with the requirements of applicable data protection laws and the purposes for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practices and Asters's business purposes.

8. How we protect your personal data 

The Asters Website uses measures that are appropriate to protect your personal data against unauthorized access, improper use or disclosure, unauthorized or unlawful destruction or accidental loss, and all our employees and any third parties that process your personal data on our behalf are obliged to respect the confidentiality of your information. However, we cannot and do not provide any assurance that these measures will be sufficient to protect the information you choose to transmit to our Website. 

9. Information regarding your rights 

The following rights are in general available to you according to applicable data privacy laws: 

(i) Right of access to your personal data stored by us;

(ii) Right to request the correction, deletion or restricted processing of your personal data;

(iii) Right to object to a processing for reasons of our own legitimate interest, public interest, or profiling, unless we are able to prove that compelling, warranted reasons superseding your interests, rights and freedoms exist, or that such processing is done for purposes of the assertion, exercise or defense of legal claims;

(iv) Right to data portability;

(v) Right to object;

(vi) Right to withdraw your consent; and

(vii) Right to lodge a complaint with the supervisory authority. 

10. Changes to this Policy 

We may make changes to this Policy from time to time. To ensure that you are always aware of how we use your personal data we will update this Policy from time to time to reflect any changes to our use of your personal data. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We encourage you to review this Policy periodically to be informed of how we use your personal data. 

11. Data Controller 

The data controller for this Website is: 

ASTERS LAW FIRM ATTORNEYS' PARTNERSHIP

Leonardo Business Center, 14th floor

19-21 Bohdana Khmelnytskoho St.

Kyiv, 01030, Ukraine 

12. Data Protection Officer 

Should you have any questions regarding data privacy, please contact our corporate data protection officer at the following address: 

Vitaliy Manokhin 

Data Protection Officer at Asters

vitaliy.manokhin@asterslaw.com   

The Website and its content are governed by Ukrainian law. Any dispute over this Website and its content must be referred to a Ukrainian court.

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