PRIVACY POLICY

PRIVACY POLICY

Seiler LLP ("Seiler" / "we" / "our" / "us") is committed to protecting and respecting your privacy. This policy (together with our Website Terms of Use and any other documents referred to in them) sets out the basis on which any personal information that we collect from our clients (“you” / “your”) or that you provide to us, will be processed.

This policy applies to personal information we collect when you interact with us including when you engage our services, when you refer work to us, when you make an enquiry or request information from us or as a result of your relationship with our clients or staff.

This policy also applies to information we collect through your use of this website (www.seiler.com) or portal and any other online service created or hosted by us on which the privacy policy appears. If you engage us to carry out work for you, we will have client confidentiality obligations to you, as set out in our letter of engagement and, if applicable, our Master Service Agreement for Family Office services.

Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

1.
ABOUT US

Seiler LLP is a limited liability partnership incorporated in California with registration number 201997022004 whose registered office is at 3 Lagoon Drive, Suite 400, Redwood City CA, 94065. Seiler is the data controller in respect of your personal information. This means that we are responsible for deciding how we hold and use personal information about you.

2.
WHAT INFORMATION WE COLLECT AND HOW WE WILL USE IT
2.1

We collect personal information so that we can operate effectively and provide you with the best possible service. The information we collect depends on the context of your interactions with us, our website or portal and how you use our services. It also depends on the choices you make, for example the functions you use and your privacy settings. You may chose not to provide certain information but if you do, and that information is necessary to provide a particular feature, then you may not be able to use that feature. We will only use your personal information where we have a valid lawful basis to do so.

2.2

We have a duty to process personal data fairly, lawfully and in a manner that you would expect given the nature of our relationship with you. Where we have a legal basis to use your personal information without consent (as set out in the tables below), this policy fulfils that duty by giving you appropriate notice and explanation of the way in which your personal information will be used. Where consent is required for our use of your personal information we will ask you to positively opt-in. Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.

2.3

If you have any questions or require any further information regarding our use of your personal information please contact our Data Protection Manager at privacy@seiler.com.

2.4

The table below summarizes what information we collect about you, explains how we intend to use it and what our legal basis is for using it. Click on the links below to take you to the section which is relevant to you:

In the table below the following types of information include:

Identity information: name of company, organization and/or individual, title, position and user log-in details;

Contact information: postal addresses, email addresses and telephone numbers;

Financial information: tax and audit information, bank account details, payment information, mortgage information, personal financial details and insurance information;

Employment information: employment history, National Insurance number, salary and benefits details; and

Special category information:race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, biometric data, health and medical records, sex life or sexual orientation.

Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information from you? Legal basis for processing
To enable us to provide financial or other services to you or your organization Identity information

Contact information

Financial information

Other personal information you provide to us concerning your business and/or personal interests

We may collect additional categories of personal information (including special category personal information) if relevant to the particular type of financial services we are providing. For further information see the relevant section:
Collected by us through our provision of financial or other services to you or the organization you represent including:
  • information provided by you when you:
    • contact us (including by email, telephone, post, fax, SMS or other messaging service or in person)
    • complete our online enquiry or publications request form via our website
    • sign up for or attend one of our events or meet us at external events or provide us with your business card and
  • information received from third parties including:
    • when they refer you to us
    • other parties to matters on which we are instructed and
  • information collected by us from publicly available information about you or your organization
Necessary for the performance of a contract with you or your organization (letter of engagement and/or Master Services Agreement)
To carry out necessary identity checks before providing financial or other services to you or your organization Identity information

Contact information

Financial information

ID documentation (including but not limited to passports, driving licenses and utility bills)
Signatures
Collected by us through our provision of financial or other services to you or the organization you represent including:
  • information provided by you when instructing us
  • information received from third parties (including when they refer you to us) and
Necessary steps prior to entering into a contract with you or your organization
Necessary to comply with our legal obligations
Services to individuals (including advice relating to domestic and international tax, audits, accounting, trusts and estates, wills and probate and real estate services)
To enable us to provide financial services to individuals Personal information that is relevant to your instructions including (where relevant):
  • employment information
  • date of birth
  • family information (including information regarding adoption, surrogacy, marriage, divorce, details of family and dependents, and child settlement arrangements)
  • mortgage information
  • personal financial information and taxation details
  • insurance information
  • immigration and travel information
  • wills and inheritance information
  • CCTV footage
  • photographs
  • transcripts
  • other personal information you provide to us concerning your business or personal interests
Collected by us through our provision of financial or other services to you including:
  • information provided by you
  • information received from third parties including
    • when they refer you to us
    • other parties to matters on which we are instructed and
  • information collected by us from publicly available information about you or your business interests
Necessary for the performance of a contract with you. To enable us to pursue legitimate interest to deliver our services to you.
In addition, we may collect the special category information if relevant to a your instructions including:
  • race or ethnic origin;
  • religious or philosophical beliefs;
  • biometric data;
  • health and medical records; and
  • sex life or sexual orientation.
Provided by you in circumstances where litigation is not contemplated Your consent
Provided by you and/or received from third parties in circumstances where litigation is contemplated (including other professionals when they refer you to us) Necessary for the establishment, exercise or defense of claims
Collected by us in the course of providing financial services where information has already been disclosed in court or public documents by you, or at the request of or on behalf of you Processing relates to personal data which are manifestly made public by the data subject
In addition we may process personal information relating to criminal convictions where permitted by law Provided by you in circumstances where litigation is not contemplated Your consent
Provided by you and/or third parties in circumstances where litigation is contemplated (including other professionals when they refer you to us) Necessary for the establishment, exercise or defense of claim
Services to businesses (including advice relating to domestic and international tax, audits, accounting and real estate services
To enable us to provide financial or other services to your business Personal information that is relevant to your business, our instructions and necessary for management of financial affairs including:
  • date of birth
  • employment information
  • mortgage information and financial details
  • insurance information
  • other personal information you provide to us concerning your business or personal interests
Collected by us through our provision of financial or other services to you or the organization you represent including:
  • information provided by you
  • information received from third parties including
    • when they refer you to us
    • other parties to matters on which we are instructed and
  • information collected by us from publicly available information about you or your organization
Necessary for the performance of a contract with you or your business
In addition, we may collect the following special categories of information if relevant to instructions from you including:
  • health and medical records
  • race/ethnic origin
Provided by you in the course of instructing us Your consent
Collected by us in the course of providing financial services where information has already been disclosed in court or public documents by you, or at the request of or on behalf of you Processing relates to personal data which are manifestly made public by the data subject
Services relating to litigation support
To enable us to provide services relating to litigation support Personal information that is relevant to instructions from you and necessary for litigation support services including:
  • date of birth
  • employment information
  • mortgage information and financial details
  • personal financial details
  • insurance insurance
  • photographs
  • transcripts
  • other personal information you provide to us concerning your business or personal interest
Collected by us through our provision of financial or other services to you or the organization you represent including:
  • information provided by you
  • information received from third parties including
    • when they refer you to us
    • other parties to matters on which we are instructed (and such other parties’ advisers, experts and witnesses in relation to litigation support) and
  • information collected by us from publicly available information about you or your organization
Necessary for the performance of a contract with you or your organization
In addition, we may collect the following special categories of information if relevant to litigation instructions including:
  • health and medical records
  • race/ethnic origin
Provided by you and/or third parties in circumstances where litigation is contemplated (including other professionals when they refer you to us) Necessary for the establishment, exercise or defense of legal claims
Collected by us in the course of providing financial services where information has already been disclosed in court or public documents by you, or at the request of or on behalf of you Processing relates to personal data which are manifestly made public by the data subject
In addition we may process personal information relating to criminal convictions where permitted by law and necessary for the establishment, exercise or defense of a legal claim Provided by you and/or third parties in circumstances where litigation is contemplated (including other professionals when they refer you to us) Necessary for the establishment, exercise or defense of legal claims
Services relating to employment, retirement and succession planning
To enable us to provide financial and other services on employment and retirement related matters Personal information that is relevant to instructions and necessary for management of financial affairs in relation to employment including:
  • date of birth
  • education and qualifications
  • employment information
  • pension arrangements
  • personal financial details
  • insurance information
  • photographs
  • transcripts
  • other personal information which you may volunteer
Collected by us through our provision of financial or other services to you or the organization you represent including:
  • information provided by you; and
  • information received from third parties including:
    • when they refer you to us
    • other parties to matters on which we are instructed on (and such other parties’ advisers, experts and witnesses in relation to litigation support) and
  • information collected by us from publicly available information about you or your organization
Necessary for the performance of a contract with you or your organization
In addition, we may process the following special categories of information if relevant to an instruction including:
  • health and medical records
  • sex life/sexual orientation
  • race/ethnic origin
  • religious or philosophical beliefs
  • biometric data
Provided by you in the course of instructing us in circumstances where litigation is not contemplated Your consent
Provided by you and/or third parties in circumstances where litigation is contemplated (including other professionals when they refer you to us) Necessary for the establishment, exercise or defense of legal claims
Collected by us in the course of providing services where information has already been disclosed in court or public documents by you, or at the request of or on behalf of you Processing relates to personal data which are manifestly made public by the data subject
In addition we may process personal information relating to criminal convictions where permitted by law and necessary for the establishment, exercise or defense of a legal claim Provided by you and/or third parties in circumstances where litigation is contemplated (including other professionals when they refer you to us) Necessary for the establishment, exercise or defense of legal claims
To enable us to provide financial or other services to our clients Identity information

Contact information

Financial information

Other personal information you provide to us concerning your business and/or personal interests
Collected by us through our provision of financial or other services to our clients including:
  • information received from you including:
    • when you refer clients to us
    • when you are the other party to a matter on which we are instructed
    • when you are the adviser, expert or witness to the other party to a matter on which we are instructed and
  • information collected by us from publicly available information about you or your organization
To enable us to pursue our legitimate interest to deliver financial or other services to our clients
Financial services relevant to non-profit organizations and foundations
To enable us to provide services to non-profit organizations and foundations Personal information that is relevant to instructions and necessary for management of financial affairs including:
  • date of birth
  • information regarding family and dependents
  • other personal information you provide to us concerning your business or personal interest
Collected by us through our provision of financial or other services to you or the organization you represent including:
  • information provided by you
  • information received from third parties including
    • when they refer you to us
    • other parties to matters on which we are instructed
    • information collected by us from publicly available information about you or your organization
Necessary for the performance of a contract with you
In addition, we may collect the following special categories of information if relevant to your instructions including:
  • health and medical records
  • trade union membership
  • political opinions
  • race/ethnic origin
  • religious or philosophical beliefs
  • sex life or sexual orientation
Provided by you in the course of instructing us Your consent
Collected by us in the course of providing services where information has already been disclosed in court or public documents by you, or at the request of or on behalf of you Processing relates to personal data which are manifestly made public by the data subject
4.
Response to enquiries and requests for information
Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information from you? Legal basis for processing
To deal with enquiries, correspondence or complaints Identity information

Contact information

Any other personal information you provide to us relevant to the enquiry or issue raised
Collected by us in the course of dealing with enquiries or other requests made by you or the organization you represent including:
Information provided by you when you:
  • contact us (including by email, telephone, post, fax, SMS or other messaging service or in person)
  • complete our online enquiry or publications request form via our website
  • sign up for or attend one of our events or meet us at external events or provide us with your business card
Information received from third parties (including other professionals when they refer you to us)

Information collected by us in the course of providing our services (including information collected by us from publicly available information about you or your organization)
To enable us to pursue our legitimate interests to provide information or services requested; or to deal with complaints
To decide if someone else can assist with your enquiry (including experts, advisers and suppliers) Identity information

Contact information

Any other personal information you provide to us relevant to the enquiry or issue raised
Collected by us in the course of dealing with enquiries or other requests raised by you or the organization you represent including:
Information provided by you when you:
  • contact us (including by email, telephone, post, fax, SMS or other messaging service or in person)
  • complete our online enquiry or publications request form via our website or
  • sign up for or attend one of our events or meet us at external events or provide us with your business card
Information received from third parties (including other professionals when they refer you to us)

Information collected by us in the course of dealing with enquiries or other requests (including information collected by us from publicly available information about you or your organization)
To enable us to pursue our legitimate interests to provide information or services requested
5.
Organization of meetings, seminars and other hosted events
Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information from you? Legal basis for processing
To enable us to host a meeting, seminar or other event Identity information
Contact information
Provided by you when you:
  • contact us (including by email, telephone, post, fax, SMS or other messaging service or in person)
  • complete our online enquiry or publications request form via our website or
  • sign up for or attend one of our events or meet us at external events or provide us with your business card
Received from third parties (including other professionals when they refer you to us)
Necessary for the performance of a contract with you
To enable us to pursue our legitimate interest to deliver financial or other services requested
Where you provide it to us, information about your dietary requirements and allergies Provided by you Your consent
Images captured by our offices’ CCTV Images captured when you visit our offices To enable us to pursue our legitimate interest to maintain the safety and security of our premises
6.
Operation of our business
Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information from you? Legal basis for processing
To manage our relationship with you or your organization and to exercise our contractual rights and meet our contractual obligations Identity information

Contact information

Other personal information you provide to us concerning your business and personal interests

Details of your attendance at meetings or other events we host
Through our provision of financial or other services to you or the organization that you represent (for further information see section 3 above)

Collected by us in the course of dealing with enquiries or other requests raised by you or the organization that you represent (for further information see section 4 above)

Collected by us in the course of arranging a meeting or other event (for further information see section 5 above)
To enable us to pursue our legitimate interest to manage our business relationships
Necessary for the performance of a contract with you
To enable us to run our business in an efficient and proper manner including to:
  • carry out data analysis
  • manage our financial position and business capability
  • manage risk
  • meet our professional obligations
Identity information

Contact information

Financial information

Other personal information you provide to us concerning your business and personal interests
Details of your attendance at meetings or other events we host
Through our provision of financial or other services to you or the organization that you represent (for further information see section 3 above)

Collected by us in the course of dealing with enquiries or other requests raised by you or the organization that you represent (for further information see section 4 above)

Collected by us in the course of arranging a meeting or other event (for further information see section 5 above)
To enable us to pursue our legitimate interest to run our business in an efficient and proper manner
To comply with our legal obligations Identity information

Contact information

Financial information

Other personal information you provide to us concerning your business and personal interests
Through our provision of financial or other services to you or the organization that you represent (for further information see section 3 above)

Collected by us in the course of dealing with enquiries or other requests raised by you or the organization that you represent (for further information see section 4 above)

Collected by us in the course of arranging a meeting or other event (for further information see section 5 above)
To comply with our legal obligations
7.
marketing and business development
Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information from you? Legal basis for processing
Where you have provided us with your consent to send you marketing communications, newsletters, information about events and updates that may be of interest to you (for further information see section 14 below) Identity information

Contact information

Where provided by you, your areas of interest
Provided by you directly. Your consent (for further information see section 14 below)
To send you, unless you have opted out, marketing communications, newsletters, information about events and updates. Where we are using a personal email address (or you are a sole trader or a partner in a partnership that is not a limited company or a limited liability partnership (LLP)) we will only send information relating to similar services to those provided to you in the past. Identity information

Contact information

Where provided by you, your areas of interest
Collected by us in the course of providing or negotiating the provision of services to you (for further information see section 3 above) To enable us to pursue our legitimate interest to maintain contact with our clients, third party contacts and to grow our business (for further information see section 14 below).
To keep records and maintain contact with clients and third party contacts in order to grow our business Identity information

Contact information

Where provided by you, your areas of interest
Provided by you when we instruct you to provide a service

Provided by you when you introduce yourself to use for future work

Provided by other professionals, agencies or other bodies when they recommend you to us

Collected by us in the course of providing our services (including information collected by us from publicly available information about you or your organization)
To enable us to pursue our legitimate interest to maintain contact with our clients and third party contacts and to grow our business
8.
Use of our website AND PORTAL

You do not need to provide us with any information in order to access most of our website, however to access the portal you need to set up an account to login. We collect information that you provide to us via our website and portal, for example when you make an online enquiry. How we use it depends on the context. Click on the following links for further information on how we process information obtained via the website and portal in the following circumstances:

We also collect some information automatically when you use our website and portal. Further information is set out in the table below.

Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information from you? Legal basis for processing
To ensure that the content on our website and portal is presented in the most effective manner for you and for your device Device and usage data (including IP addresses and device identifiers)
Device event information (including crash logs, hardware settings, browser type and browser language) Location information
Automatically collected and stored in our server logs when you interact with our website and/or portal To enable us to pursue our legitimate interest to present our website and portal in the most effective way
Cookies and similar technologies For further information see our use of cookies Your consent
For our internal operations, including analysis of the traffic to our website and portal
  • Device and usage data (including IP addresses and device identifiers)
  • Device event information (including crash logs, hardware settings, browser type and browser language
  • Location information
Automatically collected and stored in our server logs when you interact with our website and/or portal To enable us to pursue our legitimate interest to better understand visitors to our website and portal
Cookies and similar technologies For further information see our use of cookies Your consent
To protect the security of our website and portal
  • Device and usage data (including IP addresses and device identifiers);
  • Device event information (including crash logs, hardware settings, browser type and browser language)
  • Location information
Automatically collected and stored in our server logs when you interact with our website and/or portal Legitimate interests – to maintain the security of our website and portal
Cookies and similar technologies For further information see our use of cookies Your consent
9.
SHARING YOUR INFORMATION
9.1

We will only share personal data with third parties if we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

9.2

You acknowledge that we may share your personal information with third parties where:

9.2.1

You have consented to us sharing your personal information in this way;

9.2.2

We are under a legal, professional or regulatory obligation to do so (such as to comply with money laundering requirements); or.

9.2.3

it is necessary in order to perform our obligations under the letter of engagement and Master Services Agreement (if applicable) or where we have another legitimate interest in doing so that is not overridden by your interests and fundamental rights. For example, to protect our clients or to operate and maintain the security of our computer systems.

9.3

We use third party service providers to support us in the performance of the activities set out in the table above including: Disaster recovery, Password Recovery, Encrypted Emails, Analytics, Task management, Marketing, Client Portal and Payment Transaction Processing.

9.4

Further information on how client information may be shared and processed can be found in our letter of engagement and/or Master Services Agreement (if applicable). We have identified key third party service providers above; if you require further information regarding the identity of other third parties we use please e-mail privacy@seiler.com.

9.5

We may also share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or otherwise to comply with the law.

9.6

We require all our third party service providers to take appropriate and stringent security measures to protect your personal information in line with our policies. We do not allow our third party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes in accordance with our instructions.

9.7

In the course of providing our services and operating our business it will be necessary for us to share personal information with our offices in Redwood City, San Francisco and San Jose, USA. By agreeing to this Privacy Policy and signing our letter of engagement and/or Master Services Agreement, which refer to this Privacy Policy, you are consenting to this transfer of data.

9.8

In addition, some of the third parties with whom we share personal information may need to transfer your personal information outside the jurisdiction in which you provide it or from which you access our website and portal. This may also involve a transfer of your information to a locations outside the European Economic Area (EEA). The level of protection in countries outside the EEA may be less than that offered within the EEA. To ensure that your personal information receives an adequate level of protection, we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection. Where our third party service providers process personal data outside the EEA in the course of providing services to us, our contractual arrangements with these will include appropriate measures to meet EU-approved data protection obligations, usually standard contractual clauses. If you require further information about these protective measures, please e-mail privacy@seiler.com.

10.
STORING YOUR INFORMATION
10.1

The personal information that we hold about you will be transferred outside of the EEA to be processed and stored within the USA. We will take all steps reasonably necessary to ensure that storage of your personal information receives an adequate level of protection and is treated in a way consistent with EU and UK laws on data protection. If you require further information about these protective measures, you can request it from privacy@seiler.com.

10.2

Your personal information will be retained in accordance with our data retention policy which categorizes the information we hold and provides appropriate retention periods for each category, based on the purpose for which the information is processed and taking into account legal and regulatory requirements, limitation periods for taking legal action, good practice and business requirements.

10.3

In some circumstances, we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. If you require further information regarding our data retention policy please e-mail privacy@seiler.com.

11.
children’s information
11.1

If you become aware that your child or any child under your care has provided us with information without your consent please contact us at privacy@seiler.com.

12.
KEEPING YOUR INFORMATION SECURE
12.1

All information that you provide to us is stored on secure servers. We have put in place and ensure that anyone we share your personal information with has put in place appropriate measures to protect the security of your information.

12.2

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our site and you acknowledge that any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access or inadvertent disclosure.

12.3

You are responsible for keeping confidential any passwords that you have to access our services. Please do not share your passwords with anyone else. If you lose control of your password you may lose control over your personal information. If your password has been compromised for any reason please let us know immediately by contacting us at: privacy@seiler.com.

12.4

We adhere to internationally recognized security standards and we have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

12.5

We may from time to time enable online payment transactions which will be encrypted using SSL technology and will be processed by third party providers. For these purposes from time to time we may store credit card details where required to enable payment transactions. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from privacy@seiler.com.

12.6

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

13.
Your Rights
13.1

You have the right under data protection laws to access information held about you, subject to certain conditions, and to request its rectification or deletion.

13.2

You can see, review and change most of your personal information by signing in to your portal account on our website. Alternatively if you would like to access, update or amend the information which we hold about you or would like us to stop using your personal information please contact privacy@seiler.com.

Your rights in connection with your personal information

13.3

By law you have the right to:

13.3.1

Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. We will need to prove your identity before we release any personal information to you. This right is subject to a number of exemptions which allow information to be withheld in certain circumstances. For example, subject access rights are excluded where compliance would involve disclosing information relating: to another individual; data which consists of information which is subject to legal professional privilege; negotiations or confidential references.

13.3.2

Request correction or erasure of your personal information unless we have the legal right to retain it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

13.3.3

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

13.3.4

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

13.3.5

Request the transfer of your personal information to another party.

13.3.6

Change your data processing preferences at any time. If you have changed your mind you can update your account settings by signing in to your portal account on the website or by contacting us by email atprivacy@seiler.com, in respect of marketing messages you can unsubscribe contacting us by email at info@seiler.com.

13.4

You should be aware that if you ask us to stop processing your personal information in a certain way or erase your personal information, and this type of processing or data is needed to facilitate your use of the website or portal you may not be able to use the website or portal as you did before. This does not include your right to object to direct marketing, which can be exercised at any time without restriction.

13.5

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us by emailing us at privacy@seiler.com address.

No fee usually required

13.6

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

13.7

We may need to request specific information from you, or request specific written consent in accordance with our regulatory or professional standards, in order to confirm your identity and to enable you to exercise your rights as data subject, including your rights to access or transfer your data. This may also include appropriate security measures to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

13.8

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact privacy@seiler.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

14.
MARKETING
14.1

We would like to send you information by email, updates, details of client seminars and similar events which may be of interest to you (including, for example promotional materials and newsletters). We will do this if we have a lawful basis for doing so in compliance with relevant privacy law or if you consented to us doing so.

14.2

You have the right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, you can unsubscribe or update your marketing preferences by contacting us at info@seiler.com.

14.3

We may analyze your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of extra information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and cut fraud and credit risk.

15.
OTHER WEBSITES

This privacy policy only applies to this website and the portal. Our website contains links to other website. If you use or follow a link to any of these third party websites you should be aware that these websites have their own privacy policies and we cannot accept responsibility for their use of your information.

16.
CHANGES TO THIS PRIVACY POLICY

We keep our privacy policy under regular review and will post any updates on this webpage. This privacy policy was last updated 2018.

17.
HOW TO CONTACT US AND COMPLAINTS
17.1

Seiler LLP (company number [650-]) is the data controller in respect of your personal information. Seiler LLP’s registered office is at 3 Lagoon Drive, Suite 400, Redwood City CA, 94065.

17.2

We have appointed Marla Sari as our data privacy manager to oversee compliance with this privacy policy. If you have any questions about this privacy policy or how we handle your personal information please contact our Data Privacy Manager at privacy@seiler.com.

17.3

If for any reason you are not happy with the way that we have handled your personal information, please contact us at privacy@seiler.com. You have the right to make a complaint to your relevant supervisory authority.