Privacy notice

1.1 Cirio Advokatbyrå AB, org. nr. 556953–0008, (“Cirio”) is committed to protecting and respecting your privacy. We want you to feel safe when we process your personal data. This Privacy Notice (“Privacy Notice”) explains how we ensure that your personal data is handled in compliance with applicable legislation. It applies to all our processing of personal data relating to our clients and clients’ representatives and to other contacts, such as representatives of potential clients. It also applies to our suppliers and partners; event attendees; web site visitors; newsletter subscribers and other business contacts.

1.2 We need to process your personal data to be able to operate our business and meet our obligations and responsibilities in relation to our clients and other actors, applicable legislation and good industry practice.

2.1 Cirio is the data controller for the processing of your personal data and is responsible for ensuring that the processing is carried out in accordance with applicable legislation. If you have any questions regarding the processing of your personal data, you will find our contact details at the end of this Privacy Notice.

We use your personal data for the following purposes 

• To analyse the use of our web page;
• To defend our clients’ legal interests and otherwise prepare, deliver and evaluate our legal services;
• To market our services e.g., through newsletters, social media, webinars, publications and events;
• To avoid conflicts of interest;
• To manage our relationship and contracts with our clients and other external actors such as partners and vendors, including maintaining and managing our contact lists regarding such actors;
• To comply with legal obligations;
• To enable mergers, divestitures, restructuring, reorganization, dissolution and other sale or transfers of Cirio’s’ assets; and
• To establish and defend legal claims vis a vis Cirio.

Below you can find more information about our processing of your personal data.

 

PURPOSES

1. To analyse the use of our web page
2. To defend our clients’ legal interests and otherwise to prepare, deliver and evaluate our legal services
3. To market our services e.g., through newsletters, social media, webinars, publications and events
4. To avoid conflicts of interest
5. To manage our relationship and contracts with our clients and other external actors such as partners and vendors, including maintaining and managing our contact lists regarding such actors
6. To comply with legal obligations
7. För att möjliggöra fusioner, avyttringar, omstruktureringar, omorganisationer och annan försäljning eller överföring av Cirios tillgångar
8. För att fastställa och försvara rättsliga anspråk gentemot Cirio

 

To analyse the use of our web page

Why we process your data: We analyse and process your personal data to improve, develop, maintain and manage our website and services. For this purpose, we also use third party tracking services that employ to collect aggregated data about visitors to our websites. For more information about our use of cookies and similar techniques, please read our cookie notice.

Categories of personal data: Usage data such as cookie information and behaviour on web site. Device data such as IP-number.

Legal basis: When processing personal data in the form of cookies which is necessary for the functioning of the website, we base such processing on our legitimate interest of promoting, evaluating, and developing our business. However, when processing personal data in the form of non-necessary cookies to analyse the use of our website we base the processing on your consent.

Retention time: Please see our cookie notice for more information about for how long we process your information for this purpose.
 

To defend our clients’ legal interests and otherwise to prepare, deliver, and evaluate our legal services

Why we process your data: We process our client’s personal data to be able to engage in matters relating to the legal services that we provide. This includes inviting and performing meetings as well as contacting clients. We also need to offer or retrieve information of our clients or of other persons (counterparts and their legal representatives, witnesses, persons affected by the legal matters etc.) which relate to our client matters, or else to Cirio’s legal services. Cirio may also, in the light of legislative requirements, process sensitive data such as data relating to criminal convictions and offences. This pertains especially when we are performing our obligations to comply with regulations intended to, for example, prevent money laundering and terrorist financing as well as to comply with international sanctions.

Categories of personal data: Contact information such as name, address, email address, phone number. Payment information, if the data subject for example is a sole proprietorship or a private person. Work related data such as employer, title, competences, and skills. Identification documentation or background information that we have received from you or collected as a part of our client onboarding process. This includes e.g., birth dates, social security numbers and photos in identity documents. Data related to performance of checks concerning money laundering- or international sanctions including data relating to criminal convictions and offences. This includes information of nationality, ultimate beneficial ownership or data relating to being a PEP or a person affiliated with PEPs. Other matter-related data meaning data provided to or collected by us to handle client matters.

Legal basis: Processing is necessary for the purposes of our legitimate interests to engage and perform our legal duties in matters relating to the legal services that we provide. This also includes the client’s or other persons legitimate interests in the matter in which Cirio is engaged. Processing is also necessary for Cirio to be able to comply with legal obligations to which the controller (Cirio) is subject. This relates to complying with onboarding requirements such as performing checks concerning KYC- or international sanctions and the legal basis also applies to. processing of data related to criminal convictions and offences. Cirio refers in this matter to its obligations deriving from the Swedish AML-regulations and international/national regulations regarding international sanctions. When we process social security numbers this is done based on the fact that this is necessary according to the criteria stated in Chapter 3 Section 10 § in the Swedish “lag (2018:218) med kompletterande bestämmelser till EU:s dataskyddsförordning”. This applies to the onboarding process as well as to the deliverance of legal services as it is vital that such tasks are performed vis a vis the persons concerned.

Retention time: Data processed as part of our engagement in a client matter is stored for ten years or the longer period required by the Swedish Bar Association Code of Conduct with regards to the nature of the client matter. As a rule, and if the managing of the case does not require it, Cirio does not store client data for more than twenty years.

 

To market our services e.g., through newsletters, social media, webinars, publications and events

Why we process your data: We process your personal data to market Cirio and our services. We may use your data to, for example, send you our newsletters and invites to events and to manage such events. You can easily opt out from such communication. Information about how to opt-out will be given in each communication to you. Further, we conduct marketing activities on social media platforms, such as Facebook, LinkedIn and Instagram.

In addition, we will record, store and publicly disseminate recording of events performed by Cirio such as webinars and podcasts. As such, participation in such events might entail that we process your personal data and then for the end to market our services.

Categories of personal data: Contact information such as name, address, email address, phone number. Work related data such as employer and title. Information that you share relating to meetings or events, such as food preferences. Pictures and recording of sounds and images from seminars, events, or similar occasions. Information connected to your social media account, such as profile pictures, profile name and other information you choose to provide when you interact with us on social media.

Legal basis: Processing is necessary for the purposes of our legitimate interests to be able to market our services.

Retention time: Data processed as part of our marketing is stored to contact you for marketing purposes during one year from the date, we collected your data or the date when we last used your data to contact you. You may at any time unsubscribe from our mailings. If you unsubscribe, you will no longer receive mailings.

Recordings from events such as webinars and podcasts will be retained for a period of five years from the recording.

 

To avoid conflicts of interest

Why we process your data: As is stipulated in the Swedish Bar Association Code of Conduct, Cirio is obligated to avoid conflicts of interest. When conducting such conflict checks, Cirio must process personal data.

Categories of personal data: Identity documentation or background information that we have received from you or collected as a part of our client intake process Work related data such as employer and title. Contact information such as name, address, email address, phone number.

Legal basis: Processing is necessary for the purposes of our legitimate interests of avoiding conflicts of interest in accordance with the Swedish Bar Association Code of Conduct.

Retention time: Data processed as part of our engagement in a client matter is stored for ten years or the longer period required by the Swedish Bar Association Code of Conduct with regards to the nature of the client matter. As a rule, and if the managing of the case does not require it, Cirio does not store client data for more than twenty years.

 

To manage our relationship and contracts with our clients and other external actors such as partners and vendors, including maintaining and managing our contact lists regarding such actors

Why we process your data: We process your personal data to manage our relationship with you. We will also process personal data when managing contracts with our partners and vendors. We will also process personal data to manage our contact list, as for example to add or remove addresses.

Categories of personal data: Contact information such as name, address, email address, phone number. Work related data such as employer and title. Matter related data, such as data provided to us to handle client matters and contracts.

Legal basis: If we have a contract with you, the processing is necessary for the performance of that contract. If we have a contract with a legal person that you represent, the processing is necessary for the purposes of our legitimate interests of managing the relationship with you or the legal person that you represent.

Retention time: Data processed as part of our engagement in a client matter is stored for ten years or the longer period required by the Swedish Bar Association Code of Conduct with regards to the nature of the client matter. As a rule, and if the managing of the case does not require it, Cirio does not store client data for more than twenty years.

When the personal data otherwise represents or is included in documents Cirio is required to store for reasons of accounting the data will be stored and retained until the seventh year following the end of the calendar year in which the financial year ended.

 

To comply with legal obligations

Why we process your data: Cirio may process your personal data to comply with our legal obligations under applicable law, e.g., legislation regarding accounting, audit, and tax. Cirio may also, due to legislative requirements, process sensitive data such as data relating to criminal convictions and offences when we are acting as a receiver in bankruptcy matters.

Categories of personal data: Contact information such as name, address, email address, phone number. Payment information. Work related data such as employer and title. Identity documentation or background information that we have received from you or collected as a part of our client intake process Matter related data, such as data provided to us to handle client matters Sensitive data, including data relating to criminal convictions and offences.

Legal basis: We need to process personal data to comply with our legal obligations under applicable legislation.

Retention time: Your personal data is kept for as long as necessary to comply with applicable legal obligation, for example seven years with regards to our obligations in the Accounting Act and five to ten years, depending on the circumstances, to fulfil the Anti-Money Laundering Act.

 

To enable mergers, divestitures, restructuring, reorganization, dissolution and other sale or transfers of Cirio’s assets

Why we process your data: In case of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of Cirio’s’ assets we may need to process your personal data to enable such transfer.

Categories of personal data: Contact information such as name, address, email address, phone number. Payment information. Work related data such as employer and title. Identity documentation or background information that we have received from you or collected as a part of our client intake process Matter related data, such as data provided to us to handle client matters

Legal basis: The processing is necessary for the purposes of our legitimate interests of enabling mergers, divestitures, restructuring, reorganization, dissolution and other sale or transfers of Cirio’s’ assets.

Retention time: Personal data that is transferred to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Cirio’s’ assets will not be stored by Cirio after such transfer unless required to fulfil any of the other purposes set out above.

 

To establish and defend legal claims vis a vis Cirio

Why we process your data: In case of a dispute, we are entitled to process your personal data to establish, exercise or defend the legal claim.

Categories of personal data: Contact information such as name, address, email address, phone number. Payment information. Work related data such as employer and title. Identity documentation or background information that we have received from you or collected as a part of our client intake process Matter related data, such as data provided to us to handle client matters Sensitive data, including data relating to criminal convictions and offences.

Legal basis: In case of a dispute, we are entitled to process your personal data with legitimate interest as legal basis to be able to safeguard our business interests. Processing of data relating to criminal convictions and offences will either be based on 5 § förordningen (2018:219) med kompletterande bestämmelser till EU:s dataskyddsförordning or 2 § Föreskrifter (DIFS 2018:2) om behandling av personuppgifter som rör lagöverträdelser.

Retention time: Your personal data is kept for as long as necessary for us to exercise or defend a legal claim in case of a dispute.

4.1 The personal data that we process about you are data that you have provided us with or that we have otherwise acquired during our relationship. We collect data e.g.,

• From you or your representatives;
• From our web site and third-party vendors that assist us in collecting data for our marketing purposes; 
• From our clients when we initiate a business relationship or throughout the course of handling a matter on behalf of our client;
• From our business contacts, such as suppliers and vendors;
• Through emails and letters sent to and from Cirio;
• When you share information with us through other means, such as meetings, conversations, social media, events or online forms.

4.2 We may also collect or receive information about you from other sources, such as 

• Public registers;
• Bisnode Infotorg;
• Bolagsverket (Swedish Companies Registration Office); 
• Swedish authorities and courts: 
• Other third-party service providers. 

5. OBLIGATION TO PROVIDE PERSONAL DATA

 

6. AUTOMATED INDIVIDUAL DECISION-MAKING, INCLUDING PROFILING

 

7. RETENTION OF PERSONAL DATA

 

8. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

9. WHERE IS YOUR PERSONAL DATA PROCESSED?

 

10. YOUR RIGHTS IF STANDARD CONTRACTUAL CLAUSES ARE APPLIED