In common with most International law practices, we collect, use and share information, including personal information, in connection with providing our services and running our business.

This is our main general privacy policy that applies across our business, although we may publish additional privacy statements that apply to:

• our operations in specific countries in order to help ensure our compliance with local data protection requirements
• specific services that we offer to our clients from time to time

If an additional privacy statement is relevant to you because of the way in which you engage with us and there is a conflict between the information set out in this notice and the additional privacy statement, then the additional privacy statement will take precedence over the information set out in this notice.

We have a separate privacy notice that sets out how we process the personal information of our staff, which current and former members of staff should refer to.

This notice may be updated from time to time. This version is dated 1st January 2024.

Personal information is information that relates to you or allows us to identify you. This includes obvious things like your name, address and telephone number but can also include less obvious things like your attendance at a board meeting or analysis of your use of our websites.

There are different types of personal information. The most important types for you to know about are:

• Special categories of personal information: these categories of personal information often have additional protection under data protection laws around the world. These categories include information about your health, racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership, your genetic data and biometric data, and information concerning your sex life or sexual orientation
• Criminal convictions information: this is information relating to your criminal convictions and offences. Local data protection laws may restrict the way in which we can use this information when compared to, for example, your name and address

We process your personal information in our capacity as a controller. This means that we are responsible for ensuring that we comply with relevant data protection laws when processing your personal information.

We have a data protection officer whose job is to oversee our data protection compliance. You can contact our data protection officer by sending an email to:

Compliance@meysan.com

We may collect or obtain Personal Data about you: (i) directly from you (e.g., where you contact us); (ii) in the course of our relationship with you (e.g., if we provide legal advice to you); (iii) when you make your Personal Data public (e.g., if you make a public post on social media); (iv) when you download, install, or use any of our Apps; (v) when you visit our Sites; (vi) when you register to use any of our services; or (vii) when you interact with any third party content or advertising on a Site or in an App. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities).

We may collect Personal Data about you from the following sources:

Data you provide: We may obtain your Personal Data when you provide it to us (e.g., where you contact us via email or telephone, or by any other means, or if you provide us with your business card).

Relationship data: We may collect or obtain your Personal Data in the ordinary course of our relationship with you (e.g., in the course of corresponding with you).

Data you make public: We may collect or obtain your Personal Data that you choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post).

App data: We may collect or obtain your Personal Data when you download or use any of our Apps.

Site data: We may collect or obtain your Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.

Registration details: We may collect or obtain your Personal Data when you use, or register to use, any of our Sites, Apps, or services.

Content and advertising information: If you choose to interact with any third-party content or advertising on a Site or in an App, we may receive Personal Data about you from the relevant third party.

Third party information: We may collect or obtain your Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

We may create Personal Data about you (e.g., records of your interactions with us).

We may also create Personal Data about you, such as records of your communications and interactions with us, including attendance at events we hold or interviews in the course of applying for a job with us. We may record telephone calls, meetings, depositions, and other interactions in which you are involved, in accordance with applicable law.

We may Process: (i) your personal details (e.g., your name); (ii) demographic data (e.g., your age); (iii) your contact details (e.g., your address); (iv) matter details (e.g., your instructions to us); (v) records of your consents to our Processing of your Personal Data; (vi) payment details (e.g., your billing address); (vii) information about your use of our Sites and Apps (e.g., the type of device you are using); (viii) details of your current employer; (ix) information about your interactions with our content or advertising; and (x) any views or opinions you provide to us.

We may Process the following categories of Personal Data about you:

Personal details: given name(s); preferred name; and photograph.

Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.

Identifier information: passport or national identity number; utility provider details; bank statements; tenancy agreements.

Contact details: correspondence address; telephone number; email address; and details of your public social media profile(s).

Matter details: details of individuals instructing Meysan; Personal Data included in correspondence, transaction documents, evidence or other materials that we Process in the course of providing services and legal advice.

Attendance records: details of meetings and other events organized by or on behalf of Meysan that you have attended.

Consent records: records of any consent you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).

Payment details: billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; and card expiry date; invoice records; payment records; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.

Data relating to our Sites and Apps: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; and other technical communications information; username; password; security login details; usage data; aggregate statistical information.

Employer details: where you interact with us in your capacity as an employee, the name, address, telephone number and email address of your employer, to the extent relevant.

Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (including mouse hover, mouse clicks, any forms you complete (including incomplete forms not submitted) and any touchscreen interactions).

Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

Where we need to Process your Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.

We may have to Process your Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);

Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);

Establishment, exercise, or defense of legal rights: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise, or defense of legal rights; or

Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing your Sensitive Personal Data (this legal basis is not used in relation to Processing that we are legally required to carry out).

We Process Personal Data for the following purposes: providing our Sites, Apps, and services to you; compliance checks; operating our business; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; improving our Sites, Apps, and services; fraud prevention; and recruitment and dealing with job applications.

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

We may disclose your Personal Data to: (i) legal and regulatory authorities; (ii) our external advisors; (iii) our Processors; (iv) any party as needed in connection with legal proceedings; (v) any party necessary for investigating, detecting or preventing criminal offences; (vi) any purchaser of our business; and (vii) any third-party providers of advertising, plugins or content used on our Sites or our Apps.

We may disclose your Personal Data to other Meysan entities, for legitimate business purposes (including operating our Sites and our Apps, and providing services to you), in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality and professional secrecy. In addition, we may disclose your Personal Data to:

legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

accountants, auditors, lawyers and other outside professional advisors to Meysan, subject to binding contractual obligations of confidentiality;

third party Processors (such as providers of data hosting services and document review services), located anywhere in the world, subject to the requirements noted below in this Section (G);

any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defiance of legal rights;

any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security.

any relevant third-party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and

any relevant third-party provider, where our Sites and our Apps use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third-party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data, together with any additional requirements under applicable law.

We may transfer your Personal Data to recipients in other countries. Where we transfer Personal Data from the EEA or the UK to a recipient outside the EEA or the UK that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses.

Because of the international nature of our business, we may need to transfer your Personal Data to other Meysan entities, and to other third parties as noted in Section (G) above, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

Where we transfer your Personal Data from the EEA or the UK to recipients located outside the EEA or the UK who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. You may request a copy of our Standard Contractual Clauses using the contact details provided in Section (P) below.

Please note that when you transfer any Personal Data directly to a Meysan entity established outside the EEA, we are not responsible for that transfer of your Personal Data (and such transfer is not based on or protected by our Standard Contractual Clauses). We will nevertheless Process your Personal Data, from the point at which we receive that data, in accordance with the provisions of this Privacy Policy.

We implement appropriate technical and organizational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us are sent securely.

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.

We take every reasonable step to ensure that:

your Personal Data that we Process are accurate and, where necessary, kept up to date; and

any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.

We take every reasonable step to ensure that your Personal Data is retained for as long as it is needed.

We take every reasonable step to ensure that your Personal Data is only Processed for the minimum period necessary for the purposes set out in this Policy.

The criteria for determining the duration for which we will keep your Personal Data are as follows: we will retain copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.

Under applicable law, you may have a number of rights, including: (i) the right not to provide your Personal Data to us; (ii) the right of access to your Personal Data; (iii) the right to request rectification of inaccuracies; (iv) the right to request the erasure, or restriction of Processing, of your Personal Data; (v) the right to object to the Processing of your Personal Data; (vi) the right to have your Personal Data transferred to another Controller; (vii) the right to withdraw consent; (viii) and the right to lodge complaints with Data Protection Authorities. We may require proof of your identity before we can give effect to these rights.

Subject to applicable law, you may have a number of rights regarding our Processing of your Relevant Personal Data, including:

the right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our Sites, our Apps, or our services, if you do not provide us with your Personal Data);

the right to request access to, or copies of, your Personal Data, together with information regarding the nature, Processing and disclosure of those Personal Data;

the right to request rectification of any inaccuracies in your Personal Data;

the right to request, on legitimate grounds:

erasure of your Personal Data; or

restriction of Processing of your Personal Data;

the right to have certain Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;

where we Process your Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and

the right to lodge complaints with a Data Protection Authority regarding the Processing of your Personal Data by us or on our behalf.

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf; and

the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

Nothing in this Policy affects any of your other statutory rights.

To exercise one or more of the rights described in this Policy, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (Q) below. Please note that:

we may require proof of your identity before we can give effect to these rights; and

where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

We may Process your Personal Data by our use of Cookies and similar technologies.

When you visit a Site or use an App we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through Cookies and similar technologies, in accordance with our Cookie Policy.

All use of our Sites, our Apps, or our services is subject to our Legal Statements which is available on this website. We recommend that you review our Legal Statements regularly, in order to review any changes we might make from time to time.

We may Process your Personal Data to contact you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.

We may Process your Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our services and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

If you have any comments, questions or concerns about data privacy, including the processing of personal data carried out by us, or on our behalf, please email us at compliance@meysan.com

“Adequate Jurisdiction” a jurisdiction that has been formally designated by the European Commission or the United Kingdom Government as providing an adequate level of protection for Personal Data.

“App” means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).

“Controller” means the entity that decides how and why Personal Data are Processed.

“Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.

“Data Protection Authority” means an independent public authority that is tasked, by law, with overseeing compliance with applicable data protection laws.

“EEA” means the European Economic Area (the Member States of the European Union, together with Norway, Liechtenstein and Iceland).

“Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

“Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

“Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.

“Site” means any website operated, or maintained, by us or on our behalf.

“Standard Contractual Clauses” means template data transfer clauses approved by the European Commission or by a Data Protection Authority for the purpose of transferring data outside of the EEA or the United Kingdom.

At all times, we aim to provide our clients with a professional service of the highest quality.

Any client who is unhappy with any aspect of our service is entitled to complain. We treat all complaints seriously and are committed to investigating them promptly, fairly and free of charge.

If you have any complaint, including a complaint about your bill, you should raise it in the first instance with your relationship partner or the partner responsible for the relevant matter. If that is felt to be inappropriate, or if you feel that the response of the relationship partner or the partner responsible for the matter is inadequate, you can email our COO Mazen Zein, on mzein@meysan.com  or by using contactus@meysan.com email address.

It is the policy of Meysan Partners to deal with your personal information responsibly and in accordance with the requirements of applicable data protection laws, including the Abu Dhabi Global Market’s Data Protection Regulations of 2015 (the “GDPR”). This notice explains how we do that.

In this notice, “Meysan Partners” refers to Meysan Partners LLP and its affiliated partnerships from time to time. Meysan Partners LLP is a limited liability partnership registered under the laws of the Abu Dhabi Global Market.

Nothing stated in this notice is intended to, nor will it, establish a client-attorney relationship with persons reading it. Information provided to us in the course of any attorney-client relationship enjoys a special status and may be protected by confidentiality, the attorney-client privilege, the attorney work product doctrine and other similar protections (whether in the United Arab Emirates or elsewhere). Nothing in this notice detracts from any of the protections that attach to such information.

We may collect personal information from you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage us to provide legal services or as a result of your relationship with any member of our personnel or our clients.

The personal information that we process includes:

• Basic identifying information, such as your name, your preferred form of address, the company you work for, your job title or position, your gender, and geolocation data
• Contact information, such as your postal and email addresses, and phone and fax number(s)
• Financial information, such as bank account information needed to process payments
• Technical information, such as information from your visits to our website or in relation to electronic communications we send to you, your unique personal identifier, your
• Information you provide to us in connection with meetings and events we organize, including access and dietary requirements
• Identification and background information we collect as part of our client acceptance procedures
• Personal information provided to us by or on behalf of our clients or generated by us in the course or providing legal services to them

The personal information we collect may include special categories of data.

• We collect information as part of our business acceptance procedures. Those procedures include anti-money laundering, conflict, sanctions and general reputational and financial checks. This information may be provided by you or by third parties
• We collect information as necessary in the course of providing legal services
• We collect information from monitoring use of our website
• We collect information from monitoring email communications we send and receive
• We receive personal information provided to us directly, for example when you speak on the telephone with any of our personnel or you register to receive communications from us
• We may collect or receive information about you from other sources. For example we may use publicly available sources or third-party vendors to allow us to maintain the accuracy of contact details we hold for you or provide missing information
• We collect information as part of our due diligence procedures when entering into contracts with suppliers or vendors

We use the information that we collect in a number of ways, including:

• To provide legal services to our clients
• To manage our business and our commercial relationships with our clients, suppliers and vendors
• To market our services. We do this in a variety of ways, including sending Meysan announcements, legal memoranda, publications and details of seminars and other events. You may choose at any time not to receive marketing materials from us by emailing us at publications@meysan.com
• To fulfill our legal and regulatory obligations, including reporting obligations and in connection with potential or actual legal or regulatory proceedings or investigations
• For the purposes of recruitment
• To provide and improve this website, including auditing and monitoring its use, to provide users with a customized experience, and
• To provide information requested by you
• In connection with the administration of events
• To analyze whether event invitations and other emails sent by Meysan have been successfully sent or have been opened

Other uses in the ordinary course of our business that are permissible under applicable law.

We process personal information on one or more of the following grounds:

• For the legitimate business purposes described above
• On the basis of consent from the relevant individual
• To perform a contract, including a contract to provide legal services
• For the establishment, exercise or defense of legal claims or proceedings
• To comply with legal and regulatory obligations

Other uses in the ordinary course of our business that are permissible under applicable law.

Meysan Partners has offices across the region.

Personal information that is given to a Meysan Partners office may be transferred to one or more other offices in our network (including any office we may open in the future).

We may also share your personal information with third parties in accordance with contractual arrangements in place with them, including:

• Other organizations involved in matters for our clients, including local counsel, accountants or auditors, and technology service providers such as data room and case management services
• Suppliers or vendors who provide support services to us, such as translation, photocopying or document review
• IT service providers
• Organizations who assist us or work alongside us in hosting or organizing events or seminars
• Our own professional advisers and auditors

In some circumstances, we may also pass information to regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. We may be required to disclose your information to comply with legal or regulatory requirements. Where possible, we will use reasonable efforts to notify you before disclosing your information, but we may be legally restricted from doing so.

The information sharing described above may involve a transfer of your information from a location within the ADGM to outside the ADGM, or from outside the ADGM to a location within the ADGM. The level of information protection in countries outside the ADGM may be less than that offered within the ADGM. We will implement appropriate measures to ensure that your personal information nevertheless remains protected and secure in accordance with applicable data protection laws. ADGM standard contractual clauses are in place between all Meysan Partners entities that share and process personal data.

Meysan Partners LLP uses a private cloud hosted service for its document management, practice management and accounting systems. The systems utilize state of the art security, encryption, and event monitoring.

We use a variety of technical and organizational measures to help protect your personal information from unauthorized access, use, disclosure, alteration or destruction consistent with applicable data protection laws. These measures are reviewed periodically by external assessors who confirm and certify our operations.

The GDPR and other applicable data protection laws provide certain rights for data subjects. Broadly speaking you have, or may have, the right (as more fully provided in applicable data protection laws):

• to request details of the information we hold about you and how we process it
• to have your personal information rectified if it is inaccurate or deleted
• to restrict our processing of your personal information
• to stop unauthorized transfers of your personal information to a third party
• to have your personal information transferred to another person
• to complain about our processing of your personal information to a local supervisory authority

It is important to be aware that these rights may not be absolute. For example, if you withdraw your consent to our processing of your personal information, we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.

Your personal information will be retained in accordance with our Data Privacy Policy.

We retain personal information of different types, or relating to different categories of people, for different periods, taking into account its business purpose. For example, information about individuals who have applied for employment with us will be retained for a shorter period than information about individuals who have actually worked for us.

The periods for which we retain information are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used. We take into account legal and regulatory provisions which require information to be retained for a minimum period. We also consider the limitation periods for taking legal action and good practice in the legal industry.

If you have any questions on the matters covered in this policy, please contact our Compliance Officer, Khalifa Al-Khalidi at kalkhalidi@meysan.com

We regularly review this Privacy Policy and may make changes as our services or privacy practices change, or as required by applicable laws or regulations. Future versions of our Privacy Policy will be available on our website. We encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

This Policy applies to Meysan Partners websites:

https://meysan.com

https://meysan.co.uk

Cookies are small text files that may be stored on your computer or other device when you visit a website. They are generally used to make websites work, to keep track of your movements within the website, to remember your login details, and for similar activities.

There are different types of cookies, and they can be distinguished on the basis of their origin, function and lifespan. Important characteristics of cookies include the following:

• First party cookies are cookies that are stored by the website you are visiting, while third party cookies are stored by a website other than the one you are visiting. Please note that we do not control the collection or further use of your data by third parties.
• Necessary cookies are necessary to allow the technical operation of a website (e.g., they enable you to move around on a website and to use its features).
• Performance cookies collect data on the performance of a website such as the number of visitors, the time spent on the website and error messages.
• Functionality cookies increase the usability of a website by remembering your choices (e.g. language, region, login, and so on).
• Targeting/advertising cookies enable a website to send you personalized advertising.
• Session cookies are temporary cookies that are erased once you close your browser while persistent or permanent cookies stay on your device until you manually delete them or until your browser deletes them based on the duration period specified in the persistent cookie file.

More information on all aspects of cookies can be found on www.allaboutcookies.org. Please note that Meysan has no affiliation with, and is not responsible for, this third-party website.

We may use cookies to:

• distinguish between users.
• improve the use and the functionality of our websites.
• tailor our websites and services to your needs and preferences; and
• analyze how our website is used and compile anonymous and aggregate statistics.

We do not use the collected information to create user profiles.

Google Analytics

Our websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). The information generated by the Google cookies about your use of our websites (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 our websites, compiling reports on website activity 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, but please note that if you do this you may not be able to use the full functionality of our websites. By using our websites, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

For more information, please visit http://www.google.com/analytics/

Other technologies

In addition, we may also use web beacons (or clear GIFs) and other similar technologies in addition to, or in combination with, cookies. A web beacon is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site or in an email and it helps us to understand the behavior of visitors of our websites. More information on web beacons can be found on http://www.allaboutcookies.org/web-beacons/. Please note that Meysan has no affiliation with, and is not responsible for, this third-party website.

Most internet browsers are set to automatically accept cookies. Depending on your browser, you can set your browser to warn you before accepting cookies, or you can set it to refuse them. Please refer to the ‘help’ button (or similar) on your browser to learn more about how you can do this.

Disabling cookies may impact your experience on our websites.

If you use different devices to access our websites, you will need to ensure that each browser of each device is set to your cookie preference.

More information on how to manage cookies is available from: http://www.allaboutcookies.org/manage-cookies/. Please note that Meysan has no affiliation with, and is not responsible for, this third-party website.

In addition, you may opt-out from cookies by visiting the following sites and selecting which cookies you would like to opt-out from: http://www.aboutads.info/choices/#completed and http://www.youronlinechoices.com/. Please note that Meysan has no affiliation with, and is not responsible for, these third-party websites.

By continuing to use the web site of Meysan Partners LLP without changing your browser settings, you agree to our use of cookies as described above.

Legal and Regulatory Information

Meysan Lawyers and Legal Consultants WLL adheres to the rules and regulations outlined by the
Kuwaiti Ministry of Justice and the Kuwait Bar Association. These regulatory frameworks govern
the legal profession’s conduct, ethical standards, and operations within the country. Our
commitment to compliance with reporting requirements set by local authorities ensures that we
maintain the highest level of professionalism and transparency in our legal services in Kuwait.

Client Complaints Procedure

At all times, we aim to provide our clients with a professional service of the highest quality.

Any client who is unhappy with any aspect of our service is entitled to complain. We treat all complaints seriously and are committed to investigating them promptly, fairly and free of charge.

If you have any complaint, including a complaint about your bill, you should raise it in the first instance with your relationship partner or the partner responsible for the relevant matter. If that is felt to be inappropriate, or if you feel that the response of the relationship partner or the partner responsible for the matter is inadequate, you can email us on contactus@meysan.com

MP Lawyers and Legal Consultants is bound by the regulations and guidelines established by the
Beirut Bar Association. These regulatory measures govern the conduct and practices of legal
professionals within the country. As a law firm operating in Lebanon, we are committed to
upholding these professional standards and complying with all reporting requirements imposed
by local authorities. Our dedication to maintaining the highest ethical standards ensures that we
provide reliable and trustworthy legal services to our clients.

Client Complaints Procedure

At all times, we aim to provide our clients with a professional service of the highest quality.

Any client who is unhappy with any aspect of our service is entitled to complain. We treat all complaints seriously and are committed to investigating them promptly, fairly and free of charge.

If you have any complaint, including a complaint about your bill, you should raise it in the first instance with your relationship partner or the partner responsible for the relevant matter. If that is felt to be inappropriate, or if you feel that the response of the relationship partner or the partner responsible for the matter is inadequate, you can email us on contactus@meysan.com

Meysan International Lawyers and Legal Consultants is subject to the regulations and rules set
forth by the Saudi Arabian Ministry of Justice and the Saudi Bar Association. These governing
bodies oversee the legal profession’s practice, ethical behavior, and compliance with local laws.
Additionally, we diligently fulfill reporting requirements as mandated by the Saudi Arabian
authorities. By adhering to these stringent standards, we aim to deliver exceptional legal
services while upholding the principles of integrity and accountability.

Client Complaints Procedure

At all times, we aim to provide our clients with a professional service of the highest quality.
Any client who is unhappy with any aspect of our service is entitled to complain. We treat all
complaints seriously and are committed to investigating them promptly, fairly and free of charge.
If you have any complaint, including a complaint about your bill, you should raise it in the first
instance with your relationship partner or the partner responsible for the relevant matter. If that is
felt to be inappropriate, or if you feel that the response of the relationship partner or the partner
responsible for the matter is inadequate, you can email us on contactus@meysan.com

Meysan Partners LLP abides by the legal and regulatory framework established by ADGM’s
Registration Authority and the ADGM Courts. The firm maintains the highest professional
standards, ensuring ethical representation and client confidentiality. Compliance with reporting
requirements, both financial and non-financial, is crucial to meet the regulatory expectations of
the ADGM authorities and ensure the firm’s continued operations within the jurisdiction.

The contact person in the area of AML/CFT compliance is Ghassan Badran, MLRO, Telephone
Number: +9715 0949 0605, email: gbadran@meysan.com

Client Complaints Procedure

At all times, we aim to provide our clients with a professional service of the highest quality.

Any client who is unhappy with any aspect of our service is entitled to complain. We treat all complaints seriously and are committed to investigating them promptly, fairly and free of charge.

If you have any complaint, including a complaint about your bill, you should raise it in the first instance with your relationship partner or the partner responsible for the relevant matter. If that is felt to be inappropriate, or if you feel that the response of the relationship partner or the partner responsible for the matter is inadequate, you can email us on contactus@meysan.com

Meysan Lawyers and Legal Consultants WLL adheres to the legal and regulatory framework established by the Dubai Financial Services Authority (DFSA) and the DIFC Courts. The firm upholds the highest professional and ethical standards, ensuring client confidentiality and integrity in all its dealings. Compliance with both financial and non-financial reporting requirements is integral to meet the regulatory expectations of the DFSA and maintain the firm’s continued operations within the DIFC. The designated contact for AML / CFT compliance is Ghassan Badran, MLRO, Telephone Number: +9715 6891 3733, email: gbadran@meysan.com

Client Complaints Procedure

At all times, we aim to provide our clients with a professional service of the highest quality.

Any client who is unhappy with any aspect of our service is entitled to complain. We treat all complaints seriously and are committed to investigating them promptly, fairly and free of charge.

If you have any complaint, including a complaint about your bill, you should raise it in the first instance with your relationship partner or the partner responsible for the relevant matter. If that is felt to be inappropriate, or if you feel that the response of the relationship partner or the partner responsible for the matter is inadequate, you can email us on contactus@meysan.com

Regulations

Meysan Partners UK LLP (“Meysan Partners”) is a limited liability partnerships registered in
England and Wales under number OC446496 with a registered office at The International Dispute Resolution Centre, 100 St. Paul’s Churchyard, London, EC4M 8BU. Meysan Partners UK LLP is authorized and regulated by the Solicitors Regulation Authority (“SRA”) under number 8004358 The SRA’s Rules can be found in its Code of Conduct, available through the following link, SRA Code of Conduct.
The term “partner” on this website and generally means a member of a Meysan Partners UK
LLP, or a consultant or employee with equivalent standing and qualifications. A list of the
members of Meysan Partners UK LLPs and their professional qualifications is available for
inspection at the registered office.

Professional Liability Insurance

Meysan Partners UK LLP, as a “recognized body” regulated by the SRA, have in place
professional indemnity insurance (the “Mandatory Policy”) which complies with the
requirements of the Solicitors’ Indemnity Insurance Rules 2019 (the “SII Rules”). The insurer
under the Mandatory Policy is Alchemy Underwriting Limited, whose registered office
is at 2 Seething Lane London EX3N 4AT. This insurance coverage is for
claims brought against the insured entities wherever arising and is not therefore subject to
territorial restriction.

Information about Dispute Resolution

The terms of engagement for Meysan Partners’ London office include specific information on
complaints handling. Meysan Partners’ London office follows a written mandatory procedure for
handling complaints from clients. A copy of this Complaints Handling Policy will be provided to
any client upon request. In summary, if you are a client and have a complaint about any aspect
of Meysan Partners’ services, you should first raise it with the partner responsible for the
relevant matter, as identified in your engagement letter. If you find it inappropriate to do so or
if you feel unsatisfied with the partner’s response, you may write to the firm COO Mazen Zein at
mzein@meysan.com

In certain circumstances (and as referred to in the Complaints Handling Policy) a complaint may
be referred by a client to the Legal Ombudsman (“LeO”) if, at the conclusion of our internal
complaints handling process, a client does not consider the outcome of the matter to be
satisfactory. In normal circumstances, the LeO will only investigate a matter if referred to it not
later than one year from the act or omission being complained about; or one year from when
you should have realized that there was cause for complaint; and within six months of the
conclusion of our complaints handling process (i.e., the date on which a final written response in
respect of the matter is received). Further information can be found at: legalombudsman.org.uk
Please note that not all clients will be entitled to have their complaints considered by the LeO,
as this service is available only to members of the public, very small businesses, charities, clubs,
and trusts. To clarify whether the LeO will hear a complaint, to notify a complaint, or to obtain
further information, you can find the LeO’s contact details at www.legalombudsman.org.uk.
If you have concerns about Meysan Partners’ behavior, you can raise these directly with the
Solicitors Regulation Authority. This may pertain to issues like dishonesty, mishandling of funds,
or unfair treatment based on age, disability, or other characteristics. Further information can be
found at SRA | Reporting an individual or firm | Solicitors Regulation Authority.

Client Money – Interest policy

The Interest Policy (the “Policy”) sets out the interest payment and banking arrangements that
apply to money held by the London office of Meysan Partners UK LLP on behalf of clients (“client
money”).

References in this Policy to “Meysan Partners” or “the Firm” are to Meysan Partners UK LLP, a
limited liability partnership with registered number OC446496 and registered office at The International Dispute Resolution Centre, 100 St. Paul’s Churchyard, London, EC4M 8BU.

The principal objective of this Policy is to achieve what Meysan Partners believes is a fair
outcome for both the client and the Firm in relation to interest payments on client money,
having regard to the particular circumstances and purpose for which such client money is held
by the Firm.

When Meysan Partners receives client money, it will be paid into a general client account with
HSBC London.

The rate of interest on client money held in the general client account is in line with HSBC
published rates on its client deposit manager accounts.

Interest is paid by HSBC to Meysan Partners on the aggregate of all client money held in the
general client account, is for the benefit of Meysan Partners, and will be applied by Meysan
Partners to client money in accordance with this Policy.

Interest on client money held in the general client account will be at a reasonable rate
determined by the Firm and applied in accordance with a client’s instructions where it is agreed
by the Firm and a client that interest will be paid to that client. In the absence of such
instructions, interest will be applied to the balance on closure of the matter for which the client
money was held.

Interest on client money held in the general client account will not be applied or paid to a client
if the interest calculated on the balance held for that client over the entire period is less than
£50.

Client money may be transferred from the general client account to a designated deposit
account by Meysan Partners (subject to a £1,000,000 minimum) or on client request in order to
achieve a better rate of interest where it is appropriate to do so, having regard to the particular
circumstances.

The rates of interest on a designated deposit account will be set at the rate negotiated by
Meysan Partners with that particular bank.

All interest on client money held in a designated deposit account is for the benefit of the client,
and interest can be paid monthly, quarterly, or on closure, as agreed with the client.
Any trust money held by the Firm will be placed either in the general client account or in a
designated deposit account and will be subject to the interest terms applicable to those
accounts as set out in this Policy.

Any client money held in a joint account by Meysan Partners with another account holder will
be held in a designated deposit account and subject to the interest terms applicable to such an
account as set out in this Policy, unless otherwise agreed.

Meysan Partners will ensure that client money is placed with a clearing bank authorized by the
Financial Services Authority to accept deposits and is held at a branch or head office in England
and Wales unless the Firm is instructed to hold the funds elsewhere.

All client money, whether held in the general client account or a designated deposit account,
will be held on instant access terms unless otherwise instructed by and agreed with the client.
This is consistent with the purpose for which client money will be held, namely as a necessary
part of the retainer and on a short-term basis to facilitate a transaction related to the matter on
which the Firm has been retained by the client (for example, payment of filing fees).
Accordingly, clients are unlikely to receive as much interest on client money as might have been
obtained had the client invested the funds itself.

The Financial Services Compensation Scheme (FSCS) operates a deposit protection scheme
providing up to £85,000 for an eligible claimant in the event of a bank failure. If the bank in
which Meysan Partners holds client money should fail, the Firm will, subject to a client meeting
the eligibility criteria, apply to the FSCS on the client’s behalf for compensation. The Firm is
required to obtain client consent before disclosing certain account information to the FSCS,

including the client’s full name and address. The FSCS will not pay compensation to an eligible
claimant unless the claimant has been properly identified to the FSCS.
Meysan Partners will not be liable to a client for any loss, damage, cost, or claim suffered or
incurred in connection with client money held by Meysan Partners as a result of any act,
omission, fraud, delay, negligence, insolvency, or default of any bank, financial institution,
clearing or payments system, nor as a result of any decision taken by the FSCS (including non-
payment of compensation).

UK Tax Policy

This policy describes the tax approach followed by Meysan Partners UK LLP, a limited liability
partnership registered in England and Wales for the current financial year in compliance withSchedule 19, Finance Act 2016.

1. Tax Compliance
   Meysan Partners UK is committed to fully complying with UK tax legislation and ensuring the
   accurate payment of taxes at the appropriate time. We submit timely and accurate tax returns,
   engaging qualified professional advisors as needed, and disclose all relevant facts and
   circumstances to the UK tax authorities. We have established policies and procedures, including
   internal training, to meet our obligations under the Criminal Finances Act 2017.
2. Tax Planning
   In structuring our business activities, we consider the tax laws of all the countries in which we
   operate. We apply eligible reliefs and avoid engaging in artificial arrangements. Our aim is to
   prevent double taxation in accordance with existing double taxation agreements.
3. Risk Management
   We proactively identify, monitor, and manage all risks related to the interpretation of tax law in
   the jurisdictions where we operate. When faced with significant uncertainty, we seek
   professional advice from specialists or engage in discussions with the relevant tax authorities.
4. Dealings with HMRC
   We maintain a transparent and constructive relationship with HMRC, engaging in regular
   meetings and communication. We promptly inform HMRC of any relevant changes in our
   business or structure and disclose inadvertent errors, if any, to HMRC.
5. Governance
   Our Chief Financial Officer manages our UK tax arrangements, which are approved by Meysan
   Partners Executive Committee.

Data Privacy – UK

(A) This Policy

This Policy explains how we may Process your Personal Data. This Policy may be amended or updated from time to time, so please check it regularly for updates.

This Policy is issued by Meysan Partners UK LLP a limited liability partnerships registered in England and Wales under number OC446496 with a registered office at The International Dispute Resolution Centre, 100 St. Paul’s Churchyard, London, EC4M 8BU

(“Meysan”, “we”, or “us”).

This Policy is addressed to individuals outside our organization with whom we interact, including individual clients, representatives of client organizations, visitors to our Sites, users of our Apps, and other users of our services (together, “you”). Defined terms used in this Policy are explained in Section (R) below.

For the purposes of this Policy, Meysan is the controller. Contact details for any enquiries or other correspondence relating to this Policy are provided in Section (Q) below.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make to the terms of this Policy.

(B) Collection of Personal Data

We may collect or obtain Personal Data about you: (i) directly from you (e.g., where you contact us); (ii) in the course of our relationship with you (e.g., if we provide legal advice to you); (iii) when you make your Personal Data public (e.g., if you make a public post on social media); (iv) when you download, install, or use any of our Apps; (v) when you visit our Sites; (vi) when you register to use any of our services; or (vii) when you interact with any third party content or advertising on a Site or in an App. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities).

We may collect Personal Data about you from the following sources:

Data you provide: We may obtain your Personal Data when you provide it to us (e.g., where you contact us via email or telephone, or by any other means, or if you provide us with your business card).

Relationship data: We may collect or obtain your Personal Data in the ordinary course of our relationship with you (e.g., in the course of corresponding with you).

Data you make public: We may collect or obtain your Personal Data that you choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post).

App data: We may collect or obtain your Personal Data when you download or use any of our Apps.

Site data: We may collect or obtain your Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.

Registration details: We may collect or obtain your Personal Data when you use, or register to use, any of our Sites, Apps, or services.

Content and advertising information: If you choose to interact with any third-party content or advertising on a Site or in an App, we may receive Personal Data about you from the relevant third party.

Third party information: We may collect or obtain your Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

(C) Creation of Personal Data

We may create Personal Data about you (e.g., records of your interactions with us).

We may also create Personal Data about you, such as records of your communications and interactions with us, including attendance at events we hold or interviews in the course of applying for a job with us. We may record telephone calls, meetings, depositions, and other interactions in which you are involved, in accordance with applicable law.

(D) Categories of Personal Data we may Process

We may Process: (i) your personal details (e.g., your name); (ii) demographic data (e.g., your age); (iii) your contact details (e.g., your address); (iv) matter details (e.g., your instructions to us); (v) records of your consents to our Processing of your Personal Data; (vi) payment details (e.g., your billing address); (vii) information about your use of our Sites and Apps (e.g., the type of device you are using); (viii) details of your current employer; (ix) information about your interactions with our content or advertising; and (x) any views or opinions you provide to us.

We may Process the following categories of Personal Data about you:

Personal details: given name(s); preferred name; and photograph.

Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.

Identifier information: passport or national identity number; utility provider details; bank statements; tenancy agreements.

Contact details: correspondence address; telephone number; email address; and details of your public social media profile(s).

Matter details: details of individuals instructing Meysan; Personal Data included in correspondence, transaction documents, evidence or other materials that we Process in the course of providing services and legal advice.

Attendance records: details of meetings and other events organized by or on behalf of Meysan that you have attended.

Consent records: records of any consent you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).

Payment details: billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; and card expiry date; invoice records; payment records; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.

Data relating to our Sites and Apps: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; and other technical communications information; username; password; security login details; usage data; aggregate statistical information.

Employer details: where you interact with us in your capacity as an employee, the name, address, telephone number and email address of your employer, to the extent relevant.

Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (including mouse hover, mouse clicks, any forms you complete (including incomplete forms not submitted) and any touchscreen interactions).

Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

(E) Sensitive Personal Data

Where we need to Process your Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.

We may have to Process your Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);

Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);

Establishment, exercise, or defense of legal rights: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise, or defense of legal rights; or

Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing your Sensitive Personal Data (this legal basis is not used in relation to Processing that we are legally required to carry out).

(F) Purposes of Processing and legal bases for Processing

We Process Personal Data for the following purposes: providing our Sites, Apps, and services to you; compliance checks; operating our business; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; improving our Sites, Apps, and services; fraud prevention; and recruitment and dealing with job applications.

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

(G) Disclosure of Personal Data to third parties

We may disclose your Personal Data to: (i) legal and regulatory authorities; (ii) our external advisors; (iii) our Processors; (iv) any party as needed in connection with legal proceedings; (v) any party necessary for investigating, detecting or preventing criminal offences; (vi) any purchaser of our business; and (vii) any third-party providers of advertising, plugins or content used on our Sites or our Apps.

We may disclose your Personal Data to other Meysan entities, for legitimate business purposes (including operating our Sites and our Apps, and providing services to you), in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality and professional secrecy. In addition, we may disclose your Personal Data to:

legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

accountants, auditors, lawyers and other outside professional advisors to Meysan, subject to binding contractual obligations of confidentiality;

third party Processors (such as providers of data hosting services and document review services), located anywhere in the world, subject to the requirements noted below in this Section (G);

any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defiance of legal rights;

any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security.

any relevant third-party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and

any relevant third-party provider, where our Sites and our Apps use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third-party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data, together with any additional requirements under applicable law.

(H) International transfer of Personal Data

We may transfer your Personal Data to recipients in other countries. Where we transfer Personal Data from the EEA or the UK to a recipient outside the EEA or the UK that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses.

Because of the international nature of our business, we may need to transfer your Personal Data to other Meysan entities, and to other third parties as noted in Section (G) above, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

Where we transfer your Personal Data from the EEA or the UK to recipients located outside the EEA or the UK who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. You may request a copy of our Standard Contractual Clauses using the contact details provided in Section (P) below.

Please note that when you transfer any Personal Data directly to a Meysan entity established outside the EEA, we are not responsible for that transfer of your Personal Data (and such transfer is not based on or protected by our Standard Contractual Clauses). We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Privacy Policy.

(I) Data security

We implement appropriate technical and organizational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us are sent securely.

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

(J) Data accuracy

We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.

We take every reasonable step to ensure that:

your Personal Data that we Process are accurate and, where necessary, kept up to date; and

any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

(K) Data minimization

We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.

(L) Data retention

We take every reasonable step to ensure that your Personal Data are only retained for as long as it is needed.

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Policy.

The criteria for determining the duration for which we will keep your Personal Data are as follows: we will retain copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.

(M) Your legal rights

Under applicable law, you may have a number of rights, including: (i) the right not to provide your Personal Data to us; (ii) the right of access to your Personal Data; (iii) the right to request rectification of inaccuracies; (iv) the right to request the erasure, or restriction of Processing, of your Personal Data; (v) the right to object to the Processing of your Personal Data; (vi) the right to have your Personal Data transferred to another Controller; (vii) the right to withdraw consent; (viii) and the right to lodge complaints with Data Protection Authorities. We may require proof of your identity before we can give effect to these rights.

Subject to applicable law, you may have a number of rights regarding our Processing of your Relevant Personal Data, including:

the right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our Sites, our Apps, or our services, if you do not provide us with your Personal Data);

the right to request access to, or copies of, your Personal Data, together with information regarding the nature, Processing and disclosure of those Personal Data;

the right to request rectification of any inaccuracies in your Personal Data;

the right to request, on legitimate grounds:

erasure of your Personal Data; or

restriction of Processing of your Personal Data;

the right to have certain Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;

where we Process your Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and

the right to lodge complaints with a Data Protection Authority regarding the Processing of your Personal Data by us or on our behalf.

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf; and

the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

Nothing in this Policy affects any of your other statutory rights.

To exercise one or more of the rights described in this Policy, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (Q) below. Please note that:

we may require proof of your identity before we can give effect to these rights; and

where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

(N) Cookies and similar technologies

We may Process your Personal Data by our use of Cookies and similar technologies.

When you visit a Site or use an App we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through Cookies and similar technologies, in accordance with our Cookie Policy.

(O) Legal Statements

All use of our Sites, our Apps, or our services is subject to our Legal Statements which is available on this website. We recommend that you review our Legal Statements regularly, in order to review any changes we might make from time to time.

(P) Direct marketing

We may Process your Personal Data to contact you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.

We may Process your Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our services and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

(Q) Contact details

If you have any comments, questions or concerns about data privacy, including the processing of personal data carried out by us, or on our behalf, please email us at compliance@meysan.com

(R) Definitions

“Adequate Jurisdiction” a jurisdiction that has been formally designated by the European Commission or the United Kingdom Government as providing an adequate level of protection for Personal Data.

“App” means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).

“Controller” means the entity that decides how and why Personal Data are Processed.

“Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.

“Data Protection Authority” means an independent public authority that is tasked, by law, with overseeing compliance with applicable data protection laws.

“EEA” means the European Economic Area (the Member States of the European Union, together with Norway, Liechtenstein and Iceland).

“Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

“Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

“Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.

“Site” means any website operated, or maintained, by us or on our behalf.

“Standard Contractual Clauses” means template data transfer clauses approved by the European Commission or by a Data Protection Authority for the purpose of transferring data outside of the EEA or the United Kingdom.

CLIENT COMPLAINTS PROCEDURE

At all times, we aim to provide our clients with a professional service of the highest quality.

Any client who is unhappy with any aspect of our service is entitled to complain. We treat all complaints seriously and are committed to investigating them promptly, fairly and free of charge.

If you have any complaint, including a complaint about your bill, you should raise it in the first instance with your relationship partner or the partner responsible for the relevant matter. If that is felt to be inappropriate, or if you feel that the response of the relationship partner or the partner responsible for the matter is inadequate, you can email John Reynolds, our UK Managing Partner, on jreynolds@meysan.com  or by using contactus@meysan.com email address.