Privacy Policy

Last Updated: September 20, 2023

1. INTRODUCTION

1.1 Spice Route Legal (collectively, “SRL”, “we”, or “us”) is engaged in the provision of legal services. At SRL, we are committed to respecting the privacy and protecting the personal data of clients, staff, agents, lawyers, law students, job applicants and other third parties (“you”).

1.2 In order to engage with you or provide services, SRL needs to process personal data about you. This Privacy Policy (“Policy”) outlines our practices in relation to the processing of your personal data that may be accessed by us or you may have chosen to share with us when you engage with us or visit our website available at https://spiceroutelegal.com/ (“Platform”).

1.3 Please read this Policy carefully to understand our practices regarding your personal data and how we will treat it. This Policy sets out the basis on which any personal data we collect from you, we collect about you, or that you provide to us, will be processed by us.

2. THE DATA WE COLLECT ABOUT YOU

2.1 We collect or obtain data relating to you in a variety of ways, as described below. Such data may include personal data or information, that is, information relating to an identified or identifiable natural person. We may collect or receive the following categories of data about you:

(a) Identity Data: This includes data such as your first and last name, date of birth, job title, gender, educational qualifications and background, preferences and interests, employment status, organisation name and identification documents.

(b) Contact Data: This includes data such as your phone number, email address, and residential address.

(c) Financial Data: This includes data such as your financial information, bank account details, bank account statements, income details, etc., where you choose to make such data available to us.

(d) Technical Data: This includes data such as your internet protocol address, browser type and versions, website usage data, operating systems, device information, and data collected through cookies and other technologies.

(e) Client Data: This includes data provided to us by or on behalf of our clients or generated by us in the course of providing our services.

(f) Recruitment Data: This includes data such as your curriculum vitae, education and employment history, details of professional memberships, and other relevant information.

(g) Event Data: This includes data that you provide to us in course of registering for and attending events, meetings, and webinars hosted by SRL.

2.2 We are required to collect your personal data to engage with you or provide you with our services. If you fail to provide us that data as and when requested by us, we may not be able to engage with you or provide our services.

2.3 We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under applicable laws.

3. HOW WE COLLECT DATA ABOUT YOU

3.1 We use different methods, as permitted under applicable laws, to process personal data about you. This includes:

(a) Information you provide us: This is the information (such as Identity Data, Contact Data, Financial Data and Recruitment Data) you consent to give us when you use our services, or engage or correspond with us (for example, by email, voice call, or video call).

(b) Information we collect about you and your device: Each time you visit the Platform, we will automatically collect personal data using cookies and other analytical tools (including Technical Data).

(c) Information we receive from other sources including third parties and publicly available sources: We may receive personal data about you from various third parties such as analytics providers, advertising networks, search information providers, and other publicly available sources.

4. HOW WE USE YOUR PERSONAL DATA AND FOR WHAT PURPOSES

4.1 We will only use your personal data in accordance with applicable laws. Most commonly, we will use your personal data to engage with you or provide you with our services, or where we need to comply with a legal obligation.

4.2 In general, we use your personal data for the following purposes:

  • To engage with you or provide you with our services;
  • To manage our relationship with you, including notifying you of changes to any services;
  • To facilitate use of the Platform and to ensure that the content is relevant;
  • To conduct KYC compliance processes as required under applicable laws;
  • To administer and protect our business and the Platform, including troubleshooting, data analysis, system testing, and performing internal operations;
  • To monitor trends so we can improve our Platform and services;
  • To perform our obligations that arise out of the arrangement we are about to enter or have entered with you;
  • To recruit and provide internships to suitable candidates;
  • To undertake marketing and business development activities;
  • To respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims;
  • To carry screening or due diligence checks;
  • To detect and protect us against error, fraud, money laundering and other criminal activities;
  • To detect, respond, and recover from cybersecurity incidents; and
  • To ensure compliance with applicable laws.

4.3 Where applicable laws permit us to, we rely on your consent as a ground to process your personal data.

4.4 If you are based in the European Economic Area (or where applicable law does not permit us to rely on your consent to process personal data), we rely on the following legal bases for processing your personal data:

(a) Legitimate interest, which means our interest in conducting and managing our business to enable us to provide you with the best services, and the best and most secure experience. We ensure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

(b) Performance of a contract, which means we process your data where it is necessary for the performance of a contract to which you are a party or to take steps before entering into such a contract.

(c) To comply with a legal obligation, which means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

4.5 If you are based in the European Economic Area, we generally do not rely on consent as a legal basis for processing your personal data.

4.6 We may process your personal data under more than one lawful ground depending on the specific purpose for which we are using your personal data.

4.7 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

4.8 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. HOW WE SHARE YOUR PERSONAL DATA

5.1 You hereby agree and acknowledge that any and all information pertaining to you, may be shared by us with third parties (such as service providers who provide information technology services) in accordance with your consent where required under applicable laws.

5.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5.3 You agree and acknowledge that we may share data where we are required by law, any court, government agency, or authority to disclose such information. Such disclosures are made in good faith and belief that it is reasonably necessary to do so for enforcing this Policy, or in order to comply with any applicable laws and regulations.

6. DATA SECURITY  

6.1 We have put in place appropriate security measures to prevent your personal data being accidently lost, used, or accessed in an unauthorised way, altered, or disclosed.

6.2 We have put in place procedures to deal with any actual or suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. DATA RETENTION AND DESTRUCTION 

7.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

7.2 Upon completion of the retention period for each category of personal data as described above, we shall delete or destroy, to the extent technically possible, personal data in our possession or control, or render the personal data into anonymised data, so that it no longer constitutes personal data.

8. YOUR LEGAL RIGHTS

8.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. Subject to the data protection laws that apply to you, you may have the right to:

(a) Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

(b) Request confirmation as to whether or not your personal data is being processed.

(c) Request the correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

(d) Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. However, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

(e) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

(f) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

(g) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, and machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

(h) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to engage with you or provided our services to you. We will advise you if this is the case at the time you withdraw your consent.

8.3 If you wish to exercise any of the rights set out above, please write an email to the Grievance Officer, whose details are mentioned in Section 13 of this Policy.

8.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

8.5 We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. TRANSFER OF PERSONAL DATA 

9.1 The personal data that we process may be transferred to countries other than where you are based. We undertake such transfers in accordance with applicable laws.

10. COOKIES

10.1 Cookies are small data files that are stored on your device. We use cookies and other tracking technologies to distinguish you from other users of the Platform and to remember your preferences. This helps us provide you with a good experience when you use our Platform and also allows us to improve the services.

10.2 We identify you by way of using cookies. The cookies shall not provide access to data in your device such as email addresses or any other data that can be traced to you personally. The data collected by way of cookies will allow us to provide you with a tailored and user-friendly experience. The cookies shall enable you to access certain features of the Platform. Most devices can be set to notify you when you receive a cookie or prevent cookies from being sent. If you prevent cookies from being sent, it may limit the functionality that we can provide when you visit the Platform.

10.3 Additionally, you may encounter cookies or other similar technologies on certain pages of the Platform that are placed by third parties. We do not control the use of cookies by such third parties.

11. BUSINESS TRANSITIONS

You agree and acknowledge that in the event we go through a business transition, such as a merger, acquisition by another organisation, or sale of all or a portion of our assets, your personal data may be among the assets transferred.

12. CHANGE IN PRIVACY POLICY

12.1 We keep our Policy under regular review and may amend it from time to time, at our sole discretion.

12.2 The terms of this Policy may change and if they do, these changes will be posted on this page and, where required by applicable laws, notified to you.

13. GRIEVANCE OFFICER

You may contact our Grievance Officer with any inquiry relating to this Policy or your personal data at contact@spiceroutelegal.com.