ASA GROUP Law Firm recognizes the importance of personal data and its protection in today’s realities. In this regard, we have adopted this Privacy Policy (hereinafter referred to as the “Policy”), which applies to the processing of personal data.
References in this Policy to “ASA GROUP Law Firm” and “we”, “us” or “our/our” are references to ASA GROUP Attorneys at Law and ASA GROUP Limited Liability Company. The legal entities are established in accordance with the laws of Ukraine and have their registered office at: 10 Poltavska St., Kyiv city, 01135.
Purpose of this Policy
This Policy has been developed to fully explain to you how we collect and further process your personal data.
This Policy provides information about what personal data we process, how and from whom we receive it, what actions are taken when processing your personal data, your rights as a data subject, our rights and obligations to you and other relevant information required by applicable laws and regulations.
We encourage you to read this Policy before providing us with your personal data.
Applicable laws and regulations
ASA GROUP Law Firm was established in Ukraine. Therefore, by default, Ukrainian laws and regulations apply to ASA GROUP Law Firm.
Since our services and products are aimed, among others, at foreign Clients, in particular, Clients from EU countries, our personal data processing activities may also be subject to the General Data Protection Regulation (EU) 2016/679, also known as GDPR.
The role of ASA GROUP Law Firm in the processing of personal data
For most purposes/activities, ASA GROUP Law Firm acts as a data controller. However, in some cases, we may act as a data processor (for example, when processing the data of job applicants received on employment portals).
What personal data we collect
Categories of personal data
Personal data is any information about an individual from which he or she is identified or can be specifically identified. Anonymous data is not personal data.
Types of confidential data with a special status (“vulnerable data”)
Vulnerable data includes personal data of the following types:
- racial, ethnic or national origin;
- political, religious or philosophical beliefs;
- membership in trade unions, political parties/organizations, religious or philosophical organizations;
- health status;
- sexual life or sexual orientation;
- genetic or biometric data;
- information on bringing the subject to justice;
- information about the facts of violence against the data subject; and
- information about the location and its changes.
We may process certain types of “vulnerable” data for certain special purposes (the number of which is limited), but only in accordance with the applicable laws of Ukraine.
Data on criminal records
We may also collect data about your criminal convictions and offenses committed, but only in cases where we have the appropriate authority or if you have voluntarily provided us with such data due to the specifics of the services we provide.
Personal data of children
Our services and products are not targeted at children, i.e. persons under the age of 18.
However, it is possible that in order to provide some of our services, we may need to process personal data of children. Therefore, we process personal data of children to the extent strictly necessary for such purposes and we process it on behalf of and with the permission of the child’s parents or guardians.
How we process your personal data
Sources of collection of your personal data
We may collect your personal data, if we have the appropriate legal basis for doing so, in one of the following ways:
You provide us with your personal data in hard copy or electronic form;
You provide us with your personal data through our website;
Your personal data is generated in the course of your interaction with us (for example, in the course of the performance of an employment contract);
We receive your personal data from our Clients or other third parties (e.g. recruitment agencies); and/or
We receive your personal data from public sources (e.g., social media, public registers, media reports).
If your personal data is provided to us by a third party and we are not entitled to inform you of this fact and how we process your personal data, we require that this third party ensure that you are informed in the prescribed manner about how your personal data will be used and that the collection of your personal data is carried out on a lawful basis.
Legal basis for processing your personal data
We process your personal data solely on the legal basis established by the applicable law.
The main legal grounds on which we process personal data are:
- consent of the data subject;
- performance of a contract with the data subject;
- our legal obligations;
- our legitimate interests, if they do not contradict the interests or fundamental rights and freedoms of the data subject.
If we process your personal data with your consent, you have the right to withdraw your consent at any time.
Depending on the specific circumstances, we may use different legal bases to process your personal data for certain purposes. You may contact us to obtain detailed information about the specific legal basis on which we rely to process your personal data.
It may be necessary to transfer your personal data to certain third parties in order to achieve the purposes for which your personal data was collected.
We may also provide your personal data to state authorities at their legal request and in order to comply with the requirements of the Law of Ukraine “On Prevention and Counteraction to Legalization (Laundering) of the Proceeds of Crime, Financing of Terrorism and Financing of the Proliferation of Weapons of Mass Destruction”.
If we transfer your data to third parties not listed in this Policy, we will notify you within 10 business days, unless such transfer is prohibited by the applicable laws of Ukraine.
We retain your personal data for the period necessary to achieve the purposes for which we collected it. In some cases, the storage period may depend on the requirements established by applicable law.
We ensure that your personal data is stored securely in accordance with best security practices. We take all measures reasonably necessary to prevent unauthorized access and/or loss and/or disclosure of personal data.
You can contact us for more information about the retention periods for your personal data.
We take all necessary measures, including technical and organizational, to ensure the secure processing of your personal data. Persons authorized to process your personal data on our behalf (e.g., our employees) have appropriate confidentiality obligations.
We are committed to processing your personal data accurately and up-to-date.
If you are aware that we are processing your personal data and the processing has changed, please notify us of these changes as soon as possible through our communication channels.
We respect your rights as a data subject as provided to you by the current legislation of Ukraine. You may exercise your rights if you believe it is in your best interest.
Candidates for vacant positions
Categories of personal data
We may collect and process the following personal data about you: Name; gender; date of birth; e-mail address, telephone number, postal address; previous jobs, previous employers, work experience; photographs; education.
We do not collect or process sensitive personal data. If you provide us with sensitive personal data (e.g., criminal record information) or consent to the processing of such personal data, we will apply additional security measures when processing such data and use it only for the purposes described below
Sources of personal data
We may receive your personal data directly from you (e.g., via e-mail) or from third parties (e.g., through job portals, recruitment agencies, etc.).
Purposes of processing
We collect and process the above categories of personal data for the following purposes:
- selection of candidates for vacant positions;
- checking the reputation/recommendations of candidates who have successfully passed the selection process.
Recipients of personal data
You are allowed to transfer your personal data to employees of ASA GROUP Law Firm.
Data retention period
We store your personal data for as long as necessary for the purposes of our activities and/or for the period established by applicable laws and regulations.
You can send us a request to delete your personal data through communication channels.
Employees
We may collect and further process the following categories of personal data for the following purposes:
- Hiring an employee and further management of their affairs: Full name, date of birth, gender, email address, telephone number, postal address, information about previous jobs (previous employers), previously held positions, photographs, details of identity documents (passport or residence permit), taxpayer registration number, whether the employee is liable for military service, education, information about children (full name and date of birth), health status (for employees with disabilities);
- Maintaining a payroll: Name, bank account details, amount of payment, taxpayer registration number;
- Maintaining sick leave certificates: Full name, information on the type of disability/type of disease, dates of sick leave;
- Conclusion of an insurance contract in favor of the employee: Name, address of residence, date of birth, phone number, health status;
- Processing insurance requests/applications to the insurance company: Name, health status, diagnoses;
- Organization of business trips: Full name, passport details, international passport details, company email address, travel dates, destination;
- Organization of a personal trip: Full name, passport details, passport details, service e-mail address, travel dates, destination;
- Organization of internal events for employees: Full name, passport details, video recordings, photos;
- Payment of taxes: Full name, position, amount of remuneration/salary, passport details, taxpayer registration number;
- Distribution of bonuses: Name, position, amount of remuneration/salary, amount of bonuses;
- Control over IT security: Name, position, IP address;
- Preparation of price proposals for Clients /potential Clients and information on the qualifications/level of professional training of persons who will participate in the project: Full name, position, professional experience, office e-mail address, office phone number, photos;
- Provision of services to Clients: Full name, office e-mail address, office phone number, position;
- Maintaining data on the place of work: Full name, position, office phone number, office e-mail address;
- Submission of information for electronic directories (ratings): Full name, official e-mail address, official telephone number, position, professional experience.
Sources of personal data
We may receive your personal data directly from you (for example, by e-mail), take it from our equipment that you use to perform your duties, or from third parties (for example, job portals, recruitment agencies). Some of your personal data may also be generated in the course of your work at ASA GROUP Law Firm.
Visitors to our website
We collect certain information about visitors to our website.
However, this information is not personal data.
We use cookies on our website. A cookie is a small piece of text that our website transfers to a cookie on your computer’s browser so that the website can remember your preferences. For more information about the Cookie Policy, please visit the website. We use cookie data to analyze the behavior of website visitors and improve the interaction with them. You can disable cookies in your browser settings or by following this link: https://tools.google.com/dlpage/gaoptout/.
Clients
Categories of personal data
In the process of attracting potential Clients or providing services to our existing Clients, we may process the following information:
For individual Clients: Full name, gender, email address, business email address, telephone number, business telephone number, postal address, business address, position, previous positions held, information about previous jobs (previous employers), professional experience, information about services purchased by the Client from us, passport details, taxpayer registration number, bank account details, information about payments made to or received from the Client;
For representatives of legal entities: full name, gender, work email address, work phone number, work address, position, professional experience.
Sources of personal data
We may receive your personal data directly from you (for example, by e-mail) or from third parties (for example, from our corporate Clients, from public sources).
Purposes of processing
We may process your personal data for one or more of the following purposes
- to resolve a conflict of interest with a Client or a Client’s counterparty/with another party to a legal proceeding
- providing services to Clients;
- managing our business relationship with the Client, including notifying you of changes to our proposed business terms and conditions and other internal processes;
- determining the Client’s interest in our services and providing the Client with our price quotations for our services;
- statistical purposes;
- inviting the Client to participate in our marketing or other activities and managing the Client’s participation in them;
- submitting information for electronic directories (ratings); and/or sending correspondence and holiday gifts.
Changes to the Policy
We will update this Policy in the event of any changes in the applicable law or in the event we change any of the described personal data processing activities.
Contact details
You can send us your inquiries or complaints to the following email address office.asagroup@gmail.com
You can also send your inquiries or complaints to our postal address: 10, Poltavska St., Kyiv, 01135, office 274.
However, we cannot guarantee that this method of communication will be faster than email correspondence.