Overview of Cirio’s use of personal data

Cirio Advokatbyrå AB is committed to protecting and respecting your privacy. We want you to feel safe when we process your personal data. Our Privacy Notice explains how we process your personal data compliance with applicable legislation and applies to all of our processing of personal data relating to our clients and clients’ representatives and to other contacts, such as representatives of potential clients suppliers and partners; event attendees; web site visitors; newsletter subscribers and other business contacts.

We only use your personal data for the purposes specified in the Privacy Notice. Kindly see our Privacy Notice for further information about our use of personal data and your rights related thereto.

Do not hesitate to contact us at email hidden; JavaScript is required if you have any questions about this Privacy Notice, our processing of your personal data or if you wish to exercise your rights.


Cirio Advokatbyrå AB, org. no. 556953-0008
Postal address: Box 3294, 103 65 Stockholm
Visiting address: Mäster Samuelsgatan 20, Stockholm
E-mail: email hidden; JavaScript is required

Privacy notice – clients and other contacts

  • 1. GENERAL

    1.1 Cirio Advokatbyrå AB, reg. no. 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 and applies to all of our processing of personal data relating to our clients and clients’ representatives and to other contacts; such as representatives of potential clients suppliers and partners, event attendees, web site visitors, newsletter subscribers and other business contacts

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

  • 2. DATA CONTROLLER AND DATA PROTECTION OFFICER

    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.

    2.2 We have designated a data protection officer (”DPO”) who will monitor our compliance with applicable data protection legislation. You can contact the DPO on the contact details provided at the end of the Privacy Notice.

  • 3. OUR USE OF YOUR PERSONAL DATA

    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 service
    • To market our services e.g. through newsletters, social media, publications and events
    • To avoid conflicts of interest
    • To manage our relationship with you and our clients, and maintaining our contact lists
    • To comply with legal obligations
    • To establish and defend legal claims.

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

    PURPOSES

    To analyse the use of our web page

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

    Legal basis:
    Processing is necessary for the purposes of our legitimate interests to provide and develop our web site.

    To defend our client´s legal interests

    Categories of personal data:
    Contact information such as name, address, email address, phone number.
    Payment information.
    Work related data such as employer and title.
    Information that you share relating to meetings or events, such as availability demands to our facilities or allergies.
    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:
    Processing is necessary for the purposes of our legitimate interests to engage in matters relating to the legal services that we provide, and your, or the client’s, legitimate interests in the matter in which Cirio is engaged.

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

    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 availability demands to our facilities or allergies.
    Pictures taken at seminars, events or similar occasions.

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

    To avoid conflicts of interest

    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.

    To manage our relationship with you and our clients, and maintaining our contact lists

    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

    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.

    To comply with legal obligations

    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:
    We need to process personal data to comply with our legal obligations under applicable legislation, such as the Anti-Money Laundering Act, the Accounting Act and to respond to your request to exercise your rights under the GDPR.

    To establish and defend legal claims

    Categories of personal data:
    All of the above.

    Legal basis:
    Processing is necessary for the purposes of our legitimate interests of the establishment, exercise or defence of legal claims.

  • 4. COLLECTION OF PERSONAL DATA

    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 business relationship. We collect data

    • When we initiate a business relationship or throughout the course of handling a matter on behalf of our client
    • Through our web site
    • Through email 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)
    • Other third-party service providers.
  • 5. AUTOMATED DECISION-MAKING

    We do not use processes for automatic decision-making.

  • 6. RETENTION OF PERSONAL DATA

    6.1 We retain your personal data only for as long as is necessary for the purposes for which we originally collected the data in accordance with this Privacy Notice. When we no longer need to save your data, we will remove it from our systems. The retention time depends on the context and cannot in all cases be specified in advance.

    6.2 Data processed as part of our performance of a client matter is stored for ten years or for such longer period required by the Swedish Bar Association Code of Conduct with regards to the nature of the client matter.

    6.3 Data processed as part of our marketing is stored to contact you for marketing purposes during a 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.

    6.4 Data processed to fulfil legal obligations in the Accounting Act will be stored for seven years and to fulfil the Anti-Money Laundering Act for five to ten years depending on the circumstances.

  • 7. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

    7.1 We may share personal data with third parties that are trusted recipients and with whom we have an agreement ensuring that your personal data is processed in accordance with this Privacy Notice. We may therefore share data with:

    • Other professional advisers
    • Accountants
    • IT-suppliers
    • Third party service providers, such as translation, document review and other support functions;
    • Third parties as part of our performance of legal services related to client matters, such as courts, authorities, counterparties, counterparty counsel, suppliers of data rooms
    • Third parties involved in organising events, such as hotels, restaurants, lecturers and other organisers
    • Social media providers, such as Instagram, Facebook, LinkedIn and YouTube. We kindly refer to the policy of each service provider for information on their processing of personal data.


    7.2 In certain circumstances, we may also need to disclose data upon the request from authorities or to third parties in connection with court proceedings or business acquisition or combination processes or other similar processes.

    7.3 We will not sell your personal data.

  • 8. WHERE DO WE USE YOUR PERSONAL DATA?

    8.1 Cirio will mostly only process your personal data within the EU/EEA. However, as part of our performance of client matters, we may in individual cases need to transfer personal data to third countries. If we engage in such transfer, we will ensure that there is a legal basis for the transfer and that the level of protection is equivalent to that applicable within the EU/EEA, either by ensuring that the country has an adequate level of protection, that we have taken adequate protective measures, that you have given your explicit consent or that the transfer is necessary with regards to the purposes set out in article 49 of the GDPR.

    8.2 Furthermore, some of our IT-suppliers may in some cases transfer personal data provided by us to the USA. If so, the IT-supplier is required to be certified to the EU-US Privacy Shield Framework for all personal data received from within the EU and also implements the EU Model Clauses. Privacy Shield is available here and the EU Model Clauses, which are available here.

  • 9. YOUR RIGHTS

    9.1 Our responsibility for your rights

    9.1.1 In capacity of data controller, we are responsible for ensuring that your personal data is processed in compliance with the law and that you can exercise your rights. You may contact us at any time if you wish to exercise your rights. You will find the contact details at the end of this Privacy Notice.

    9.1.2 We have an obligation to respond to your requests to exercise your rights within one month of receiving your request. If your request is complex or if we have received many requests, we have the right to extend this deadline by two more months. If we are unable to take the action you request within one month, we will inform you of the reason for the delay and of your right to lodge a complaint with a supervisory authority and to seek a judicial remedy.

    9.1.3 You will not be charged for any information, communication or measures that we implement. However, if your request is manifestly unfounded or excessive, we may charge an administrative fee for providing the information or taking the action requested, or refuse to act on your request altogether.

    9.2 Your rights to access, rectification, erasure and restriction

    9.2.1
    You have the right to request

    a) Access to your personal data. This means that you have the right to request access to personal data that we hold about you. You also have the right to be provided, at no cost to yourself, with a copy of the personal data that we are processing. We have the right to charge a reasonable administration fee if you request further copies. If you make a request in electronic form, e.g. via email, we will provide you with the information in a commonly used electronic format.

    b) Rectification of your personal data. At your request or on our own initiative, we will correct, anonymise, delete or complete data that we know to be inaccurate, incomplete or misleading. You also have the right to complete any incomplete personal data if something relevant is missing.

    c) Erasure of your personal data. You have the right to request that we delete your personal data if there is no compelling reason for us to continue processing the data. Personal data should therefore be erased if:

    (i) they are no longer needed for the purpose for which we collected them,

    (ii) we process your data based on consent provided by you and you withdraw your consent,

    (iii) you object to us processing your data after a legitimate interest assessment and we have no compelling interest that overrides your interests and rights,

    (iv) we have processed the personal data unlawfully, or

    (v) we have a legal obligation to erase the personal data.

    However, there may be legal requirements or other compelling reasons that prevent us from immediately erasing your personal data. We will then stop processing your personal data for purposes other than compliance with the law or where there are no compelling legitimate grounds for doing so.

    d) Right to restrict processing. This means that we temporarily restrict the processing of your data. You have the right to request restriction when:

    (i) you consider your data to be inaccurate and you have requested rectification as defined in paragraph 9.2.1 a), while we establish the accuracy of the data,

    (ii) the processing is unlawful and you do not want the data to be erased,

    (iii) as the personal data controller, we no longer need the personal data for our processing purposes, but you need them to be able to establish, exercise or defend a legal claim, or

    (iv) you have objected to processing as defined in paragraph 9.3.1, while waiting for us to consider whether our legitimate interests override yours.

    9.2.2 We will take all reasonable measures possible to notify everyone who has received personal data as stated in Section 7 above if we have rectified, erased or restricted access to your personal data after you have requested us to do so. If you request information on recipients of your personal data, we will inform you about the recipients.

    9.3 Your right to object to processing

    9.3.1 You have the right to object to the processing of your personal data if our processing is based upon legitimate interests or public task (see Section 3 above). If you object to such processing, we will only continue to process your data if we have compelling reasons for doing so that override your interests.

    9.3.2 If you do not wish that we use your personal data for direct marketing you have the right to object to such processing by contacting us. We will cease to use your data for that purpose when we have received your objection.

    9.4 Your right to data portability

    You have the right to data portability. This means the right to receive your personal data in a structured, commonly used and machine-readable format, and to request that these data are transferred to another personal data controller. The right to data portability only applies when the processing is being carried out by automated means and our lawful basis for processing your data is your consent or for the performance of a contract between you and us.

    9.4 Your right to data portability

    You have the right to lodge a complaint with the Swedish Data Protection Authority (Datainspektionen) if you are not satisfied with our processing of your personal data.

  • 10. PROTECTION OF YOUR PERSONAL DATA

    We want you to feel confident about providing us with your personal data at all times. We have therefore taken appropriate security measures to protect your personal data against unauthorised access, alteration and erasure. Should a security breach occur that may materially impact you or your personal data, e.g. risk of fraud or identity theft, we will contact you to explain what action you can take to mitigate potential adverse effects of the breach.

  • 11. COOKIES

    We use cookies that may include personal data to improve our website and other web services and your experience of them. You can find more information in our cookie policy.

  • 12. CHANGES TO THE PRIVACY NOTICE

    We have the right to make changes to this Privacy Notice at any time. When we make changes that are not purely editorial, such as formatting, typographical error corrections or other changes that do not materially affect you, we will inform you of these changes and what they mean for you before they become effective.

  • 13. CONTACT DETAILS

    Do not hesitate to contact us if you have any questions about this Privacy Notice, our processing of your personal data or if you wish to exercise your rights.

    Cirio Advokatbyrå AB, org. no. 556953-0008
    Postal address: Box 3294, 103 65 Stockholm
    Visiting address: Mäster Samuelsgatan 20, Stockholm
    E-mail: email hidden; JavaScript is required