dara5 is responsible for ensuring that it uses your personal data in compliance with data protection law. The purpose of this notice (the “Privacy Policy”) is to explain what personal data dara5 collects and how dara5 uses it. For the purposes of data protection law, dara5 is a data controller in respect of your personal data. “Personal data” is any data that can be used to identify you or that dara5 can link to you and which dara5 has in its possession or control.

Personal data that dara5 collects dara5 will collect and process the following personal data:
Information that you or someone acting on your behalf provides to dara5. This includes information about you that you give dara5 by communicating with dara5 advisers, whether face-to-face, by phone, e-mail or otherwise. If you are a client or are connected with one of our client’s matters, this may include personal data about you or others that is provided to dara5 in connection with the provision of services to that client.
Information dara5 collects or generates about you. We will also collect information about you when you use our services or when we otherwise interact or correspond with you.

Disclosure of personal data to third parties

dara5 may disclose personal data to its Associates in the circumstances described below:

to provide the services or perform its obligations in connection with your contract or the contract of a client/supplier with whom you are connected;
for the management and administration of the dara5 business;
for the management and administration of internal policies and procedures within dara5

Retention of personal data

How long dara5 holds personal data for will vary. The retention period will be determined by various criteria including:

the purpose for which dara5 is using it - dara5 will need to keep the data for as long as is necessary for that purpose; and
legal obligations - laws or regulation may set a minimum period for which dara5 has to retain personal data.

Rights in relation to personal data

You have a number of legal rights in relation to the personal data that dara5 holds about you. These rights include:

the right to obtain information regarding the processing of your personal data and access to the personal data which dara5 holds about you;
the right to request that dara5 rectify your personal data if it is inaccurate or incomplete;
the right to request that dara5 erase your personal data in certain circumstances. Please note that there may be circumstances where you ask dara5 to erase your personal data but dara5 is legally entitled to retain it;
the right to object to, and the right to request that dara5 restrict, its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask dara5 to restrict, its processing of your personal data but dara5 is legally entitled to continue processing your personal data and / or to refuse that request;
in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that dara5 transmit such data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to dara5;
the right to withdraw your consent, although in certain circumstance it may be lawful for dara5 to continue processing your data where dara5 has another legitimate reason (other than consent) for doing so. dara5 is not relying on your consent in order to process your personal data for the purposes and in the manner set out in this Privacy Notice; and
the right to lodge a complaint with the relevant data protection authority if you think that any of your rights have been infringed by dara5

Use of your personal data

Personal data may be stored and processed by dara5 in the following ways and for the following purposes:

to contact you in connection with your work with dara5 and the products and services that dara5 provides to you or a client to whom you are connected;
to perform the contract with you or a client/supplier to whom you are connected (including performing dara5’s obligations and exercising dara5’s rights);
to engage in marketing and business development activity and to advise you or a client to whom you are connected of other products and services similar to those which you or a client to whom you are connected receive from dara5 and/or its Associates;
to notify you about changes to dara5’s service;
to comply with dara5’s legal and regulatory obligations. This includes reporting to the relevant authorities, complying with anti-money laundering obligations and tax reporting obligations;
to use it to look into any complaints or queries you or a client/supplier to whom you are connected may have.

dara5 is entitled to use personal data in these ways because:

Consent - we may (but usually do not) need your consent to use your personal data. You can withdraw your consent by contacting us (see below)
Performance of a contract - we may need to collect and use your personal data to enter into a contract with you or to perform our obligations under a contract with you or a client to whom you are connected.
Legitimate interest - we may use your personal data for our legitimate interests, some examples of which are given above.
Compliance with law or regulation - we may use your personal data as necessary to comply with applicable law/regulation

Transfers personal data outside of European Economic Area

Personal data may be transferred to or stored at a destination outside the European Economic Area (“EEA”). Where dara5 stores data outside the EEA, dara5 will ensure that it is protected in a manner that is consistent with how personal data will be protected by dara5 in the EEA. In other circumstances the law may permit dara5 to otherwise transfer personal data outside the EEA. In all cases, however, dara5 will ensure that any transfer of personal data is compliant with applicable data protection law.

Retention of personal data

How long dara5 holds personal data for will vary. The retention period will be determined by various criteria including:personal data is compliant with applicable data protection law.

the purpose for which dara5 is using it - dara5 will need to keep the data for as long as is necessary for that purpose; and
legal obligations - laws or regulation may set a minimum period for which dara5 has to retain personal data.

You can exercise your rights by contacting dara5 using the details set out in the “Contacting dara5” section below. You can find out more information about your rights by contacting the relevant data protection authority. We can, on request, tell you which data protection authority is relevant to the processing of your personal data.