Privacy Policy

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This website (the “Site”) is owned and operated by Kibbe & Orbe LLP (“we”, “our”, and “us”).

We are committed to ensuring that your privacy is protected. Set out below is how we use the information we collect and how you can tell us if you would prefer us not to use the information, or to limit its use.

ABOUT US

Kibbe & Orbe LLP is the data controller of any personal data you provide to us and is subject to applicable data protection laws. 

Kibbe & Orbe LLP is registered with the Information Commissioner’s Office (“ICO”) under registration number Z9282548.

Kibbe & Orbe LLP is authorized and regulated by The Solicitors Regulation Authority.

CONTACTING US

If you have any questions about this data privacy policy or your information, or to exercise any of your rights as described in this policy or under applicable data protection laws, you can contact the Data Protection Contact at:

US Data Protection Contact: Julia Lu
Kibbe & Orbe LLP
215 Park Avenue South
New York, NY 10003
Email: jlu@kibbeorbe.com
Telephone: +1 212.530.1800

UK Data Protection Contact: Matthew Hughes
Kibbe & Orbe LLP
17th Floor, Dashwood House
69 Old Broad Street
London EC2M 1QS
Email: mhughes@kibbeorbe.com
Telephone: +44 (0) 20 7382 4800

DATA PROTECTION PRINCIPLES

Anyone processing personal data must comply with the principles of processing such data as follows:

  • Lawfulness, fairness and transparency - data must be processed lawfully, fairly and in a transparent manner.
  • Purpose limitation - data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
  • Data minimization - data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  • Accuracy - data must be accurate and, where necessary, kept up to date.
  • Storage limitation - data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
  • Integrity and confidentiality - data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage by using appropriate technical or organizational measures.

This Statement describes the personal information that we collect, and explains how we comply with these principles.

INFORMATION WE MAY COLLECT

You are not required to provide any personal information on any areas of this Site. However, you may choose to provide us with personal data about yourself by corresponding with us by phone, email, or otherwise, for example your name, postal address, email address, telephone number and/or other information regarding your preferences. 

We may also automatically collect, store and use information about your visits to the Site and about your computer, tablet, mobile or other device through which you access the Site. This includes the following:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and geographical location; and
  •  information about your visit and use of the Site, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), pages you viewed and searched for, page response times, download errors, and length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and website navigation and search terms used.

WHAT WE DO WITH YOUR INFORMATION

Your personal data will be used by us in order to:

  • process your request or application for business purposes;
  • carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
  • provide you with information about other goods and services we offer that are similar to those that you have already inquired about or engaged us to provide to you.

Where it is in our legitimate interest to do so, your personal data will be used by us in order to:

  • administer our Site including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • assist our efforts to keep our Site safe and secure;
  • notify you about changes to our service;
  • ensure that content from the Site is presented in the most effective manner for you and for your computer, mobile or other hardware device through which you access the Site;
  • use your information from time to time to contact you for market research purposes.

Where you have given us consent, we shall provide you with information about news, publications, and seminars which we think will be of interest to you. You can withdraw your consent at any time, but without affecting the lawfulness of processing based on consent before its withdrawal. You can update your details or change your privacy preferences at any time - see “Contacting us” above.

We may also use aggregate information and statistics for the purpose of monitoring usage in order to help us develop the website and our services. These statistics will not include information that can be used to identify any individual.

SHARING YOUR INFORMATION WITH THIRD PARTIES

We may share your personal data with any member of our group, including affiliated entities.  We may also share your personal data with our agents, consultants and sub-contractors which assist us in running this website and related services, and which are subject to security and confidentiality obligations.

We may also disclose your personal information to third parties where there is a legitimate reason to do so including for the following reasons:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
  • if all or substantially all of our assets are acquired by a third party, in which case personal information held by it about its employees will be one of the transferred assets;
  • if we are under a duty to disclose or share your personal information in order to comply with any legal obligation.

SECURITY OF YOUR INFORMATION

We store your information in hard copy and in electronic format. We use industry standard physical and procedural security measures to protect information from the point of collection to the point of destruction. Hard copy information files are restricted to authorized individuals. We use, as appropriate, encryption, firewalls, access controls, policies and other procedures to protect information from authorized access.

Where appropriate, we use pseudonymisation and / or encryption to protect your information.

The transmission of information via the internet is not completely secure and whilst we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted in this way and therefore any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Where data processing is carried out on our behalf by a third party, we will endeavor to ensure that appropriate security measures are in place including to prevent unauthorized disclosure of personal information.

INTERNATIONAL TRANSFERS

We operate internationally and, as such, your data may be transferred to, stored at, and processed by, any of our offices located in the United States of America (“USA”) and the United Kingdom ("UK").

We shall take appropriate or suitable safeguards in respect of the transfer of your data by implementing standard data protection clauses adopted by the European Commission and by the state of California. Details regarding these safeguards can be obtained from our Data Protection Contacts whose details are given in “Contacting us” above.

HOW LONG WE KEEP YOUR INFORMATION

Personal information received by us will only be retained for as long as necessary to fulfill the purposes described in this policy or for the maximum period of time as required by law, after which time it will be destroyed in a secure manner.

YOUR RIGHTS

Access to your information and updating your information

You have the right to access information which we hold about you. If you so request, we shall provide you with a copy of your personal information which we are processing.

You also have the right to receive your personal information in a structured and commonly used format so that it can be transferred to another data controller ("data portability").

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

Right to object

You have the right to object at any time to our processing of your personal information for direct marketing purposes.

Where we process your information based on our legitimate interests

You also have the right to object, at any time, on grounds relating to your particular situation to the processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Your other rights

You also have the following rights under data protection laws to request that we rectify your personal information which is inaccurate or incomplete.  In certain circumstances, you have the right to:

  • request the erasure of your personal information ('right to be forgotten');
  • restrict the processing of your personal information to which you have given your consent, or for the establishment, exercise or defense of legal claims or for the protection of the rights of others.

EXERCISING YOUR RIGHTS

You can exercise any of your rights as described in this policy and under data protection laws by contacting us as given in “Contacting us” above.

Save as described in this policy or provided under applicable data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested or (b) refuse to act on the request.  Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm that person’s identity.

COOKIES

A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) from the Site and is stored on your device’s browser or hard drive.

We only use "Google Analytics" on this Site. This cookie provides us with a visitor count and an understanding of how visitors move around and use the website.  We can then use this information to improve navigability and the Site generally.  The cookies we use on this Site will not collect personally identifiable information about you and we will not disclose information stored in cookies (that we place on your device) to third parties.

Visitors to our Site can adjust their browsers to refuse cookies but if not adjusted, the Site will deliver the cookie as soon as the Site is visited. You can find more information about how to manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org.  This website will also explain how you can delete cookies which are already stored on your device.

We are obliged by Google Analytics to state the following:

This website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site.  The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.  Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

LINKS

Any sites that may be linked from our Site are not endorsed by us and we do not assume any responsibility for the content of any such website.

You may not link the homepage or any other parts of this website without our prior written consent.

COMPLAINTS

The US Data Protection Contact is Julia Lu who can be contacted at jlu@kibbeorbe.com.  The UK Data Protection Contact is Matthew Hughes who can be contacted at mhughes@kibbeorbe.com.

In addition, you have the right to complain to the UK Information Commissioner’s Office (https://ico.org.uk/) about our data processing activities in relation to your personal information if you think they infringe applicable data protection laws (ICO helpline on 0303 123 1113).

UPDATES TO THIS POLICY

We may review and, if appropriate, update this policy from time to time. We will place a notice of any such amendments on our Site.

This policy was last updated on January 1, 2021.