DATA PROTECTION POLICY
Updated on 2 June 2023
In the course of its business activities, Cabinet Samman (the “firm”) collects and processes the personal data of its clients, partners, prospects, job applicants, users of its website and persons who did not communicated their information directly to the firm (https://www.cabinet-samman.com/) (the “Data Subjects” or “you”). Cabinet Samman attaches great importance to the protection of the privacy and personal data of Data Subjects and is committed to offering a high level of security to any personal data processed, in compliance with applicable data protection legislation and with the rules of professional conduct applicable to the legal profession.
This Policy is effective as of May 25th, 2018.
The firm reserves the right to make changes to this Policy at any time. In such case, the firmwill post the revised version on its website (https://www.cabinet-samman.com/) and indicate the date last revised. Data Subjects are accordingly invited to periodically check the website for any possible revisions to this Policy.
- DATA CONTROLLER
Cabinet Samman is the controller of the personal data collected and processed by it.
Cabinet Samman is a law firm organized as a société d’exercice libéral à responsabilité limitée, with share capital of €20,000, registered with the Registry of Trade and Companies of Paris under the sole identification number 521 433 128, and has its registered office at 5-7 rue d’Aumale, Paris. You can contact the firm by phone, fax or email, as follows:
Phone : 01 83 62 39 80
Fax : 01 83 62 39 81
- DATA PROCESSING ACTIVITIES OF SAMMAN LAW FIRM
- Processing of data provided by data subject or authorized third parties
- In what context can data be collected?
The firm may collect and process personal data in the context the provision of its services, whenever you contact or request information from it. Most personal data are provided voluntarily by Data Subjects or by authorized third parties (e.g. tax administration, social security administration, judicial organs…).
The firm also collects the personal data of the users of its website, www.cabinetsamman.com, whenever they send us a request using the Contact Us form or apply for a position with us using the online form.
When browsing on www.cabinetsamman.com cookies may collect personal data about you under the conditions set forth in the “Cookies” section below.
Whenever the firm requests you to provide personal data, the firm will indicate whether such information is mandatory or not as well as, if applicable, any possible consequences of failure to provide such information.
Any information requested when submitting an online job application on the firm’s website is mandatory.
The firm makes all reasonable efforts to ensure that personal data are accurate and complete. To ensure that the information the firm has about you is up to date, let us know if there is any change in your contact details or other information.
- What types of data are collected?
The firm collects the following types of personal data:
- your contact details (surname, name, email address, profession, postal code, phone number, etc.);
- information about your professional situation (name of employer, position, etc.) and, if you are a job applicant, your qualifications (résumé, etc.);
- financial information, in particular for payment purposes; and
- more generally, any personal data provided in connection with the provision of services by the firm.
- Purposes of the processing
The firm processes data necessary to achieve the following purposes:
- The day-to-day management of our relationship with our clients and the provision of our services:
- Management of client matters (contacts with clients, case assessments, assistance, defense of rights, advisory services, negotiations, etc.);
- Billing, client account management, management of delinquent accounts receivable and litigation;
- Management of job applications and the recruitment process (administrative management of the application, assessment of match between the applicant’s abilities and the requirements of the job (person-job fit), contacts with the applicant, etc.);
- Management of registrations for events and training organized by the firm.
- The promotion of our services, including, by way of example, invitations to events organized by the firm, mailing of a newsletter on trending legal issues and to offer similar services;
- Compliance with our legal and regulatory obligations;
- Recruitment purposes;
- Processing any requests submitted to us using the “Contact Us” form on the website;
- Managing requests by Data Subjects for the exercise of their rights.
- Legal grounds for processing
Personal data is processed on the following legal grounds:
- For the performance of the services and assignments entrusted to the firm or in which we are involved;
- To comply with legal requirements, for example to comply with anti-money laundering legislation, to carry out conflict of interest checks or identity checks with new clients;
- To pursue our legitimate interests, while strictly complying with your rights, for example, the firm uses your data to offer you services similar to those for which you have already registered;
- For the establishment, exercise or defense of legal claims.
If you have any question or would like more information about the legal grounds the firm relies on for the processing of personal data, you can write to us at email@example.com .
- Data retention
The personal data processed by the firm are kept for as long as is strictly necessary to achieve the purpose for which such data were collected. Data in connection with the provision of legal services are kept for the duration of the contractual relationship between the firm and the client, after which time they will be securely archived for a period of five years, before being erased or anonymized, unless the applicable statute of limitation period is longer.
The personal data of job applicants will be kept by the firm for two years after the last contact between the firm and the job applicant, unless the applicant requests the erasure of his or her personal data records.
Cookie-related information is kept for a maximum of thirteen months.
- Processing of data relating to public figures in the framework of the provision of public affairs services
- In what context can data be collected?
As part of its public affairs and regulatory consulting activities, which include research of information and intelligence, collect and process personal data of public figures or people who have an influence on a given topic.
- What types of data are collected?
The data collected pertain to the public and professional spheres. Data can specifically concern the professional experience, belonging to political parties ideological currents or trade unions. In exceptional cases, data pertaining to the private sphere may be collected if they have a direct and certain impact on the professional or public life or the influence of the person concerned. These data are mainly acquired from public sources (online media, social networks, etc.). Data can also be provided by the person concerned, notably in the course of the preparation of an appointment.
- Purposes of the processing
Personal data can be processed in the context of the elaboration of biographies or the mapping of relevant stakeholders on a given subject. These data processing operations are necessary for the firm to advise its clients. It facilitates a better understanding of the positions taken, expectations, scope of action or influence of public interlocutors of the firm’s clients in order to adapt public affairs strategies accordingly and build a constructive public/private dialogue. These operations also allow public authorities to maintain a dialogue with private actors in the framework of the designof public policies benefitting to the whole society. The data collected is never used for direct marketing purposes.
- Legal grounds for processing
The firm relies on the legitimate interest to process personal data of public figures or influential persons on a given subject. The collection and processing of such data has a very limited impact on the rights and interests of the data subjects, as it does not result in any decision being taken that directly affects them. When evolving into the public sphere and the public sector, data subjects can reasonably expect either that information relating to their professional and social backgrounds is being processed in this regard or that they are being required to provide such information.
For any question or request for additional information concerning the legal basis for the processing of personal data, you may contact the firm using the contact details set out above.
- Data retention
The data are retained for the time necessary to achieve the purposes for which they are collected.
- DISCLOSURE OF PERSONAL DATA
The personal data of Data Subjects can be shared among the lawyers, employees and administrative staff at the firm as well as with its clients for the provision of public affairs services (for instance, biographies shared ahead of a meeting). All these persons are under a strict confidentiality obligation.
Personal data can also be shared, to the extent necessary, with (i) any third-party providing services in connection with the matters entrusted to the firm (local counsels or consultants, experts, translators, process-servers, etc.); (ii) our service providers, including IT service providers, for the purposes of conducting audits or checks; (iii) our communication providers; and (iv) judicial bodies and authorities.
If required, such data can be disclosed to the competent authorities or courts, in particular to comply with our legal and regulatory obligations. In case of legally required disclosure, the firm will make every effort to give you advance notice, unless the firm is prohibited by law from doing so.
As regards job applicants, their personal data will only be shared with those involved in the recruitment process (administrative staff involved in the recruitment, HR department staff, lawyers in the relevant department or team and the partners of the firm).
- INTERNATIONAL DATA TRANSFERS
The firm may transfer your personal data to a service provider located outside the European Union. In such case, the service provider shall apply international binding corporate rules for processors and controllers authorizing the transfer of the personal data processed by the service provider on behalf of clients located in countries within the European Economic Area (EEA) to countries outside the EEA. These binding corporate rules have been validated by the competent European authorities.
You can obtain a copy of these rules by writing to the firm at the following postal address: Cabinet Samman, 5-7 rue d’Aumale, 75009 Paris or at the following email address: firstname.lastname@example.org.
- SECURITY OF PERSONAL DATA
The firm implements appropriate technical, organizational and software measures ensuring physical and software security to protect personal data against loss, unauthorized access, disclosure or alteration.
Cookies may be used when you browse the www.cabinetsamman.com website. Cookies are text files saved on your connection terminal whenever you visit the firm’s website.
www.cabinetsamman.com uses the following cookies:
- Google Analytics audience measurement cookies: these cookies are used to collect information anonymously about website users.
These cookies monitor your browsing on the website for statistical analysis purposes and help the firm get to know its audience better so as to improve its service.
You can obtain more information about the Google Analytics service by going here.
You can disable cookies at any time, free of charge, by changing the appropriate settings on your browser. The steps to be followed differing for each browser, you can find instructions in the “Help” menu of your browser, on the CNIL website at https://www.cnil.fr/fr/maitriser-mes-donnees (in French) or at https://www.allaboutcookies.org/ (in English and French).
However, if you disable cookies, you may not be able to use some of the features of the website.
- DATA SUBJECTS RIGHTS
Data Subjects are informed that they have, in accordance with the law, a right of access, to rectification, to erasure and the right to the portability of their personal data, as well as a right to restrict processing and to object to the processing of their personal data.
Data Subjects also have the right to lodge a complaint with the CNIL (website: http://www.cnil.fr), 3 Place de Fontenoy, 75007 Paris.
When processing is carried out on the basis of consent, Data Subjects can withdraw their consent at any time.
Data Subjects can exercise these rights, free of charge, directly with the firm.
Find out more
In addition to reading the information provided below, the firm invites Data Subjects to consult the CNIL’s website at: https://www.cnil.fr/
- RIGHT OF ACCESS: Data Subjects have the right to obtain from the firm confirmation as to whether or not their personal data are processed and, if processed, to access such data and be informed of the purposes pursued by such processing (Article 15 of Regulation 2016/679 on the protection of personal data (“GDPR”)). No response may be forthcoming in case of requests that are manifestly unfounded, excessive, or repetitive.
- RIGHT TO RECTIFICATION: Data Subjects have the right to obtain from the controller, without undue delay, rectification of inaccurate personal data (Article 16 GDPR).
- RIGHT TO ERASURE: Data Subjects have the right to obtain from the firm the erasure of their personal data, under the conditions set forth in Article 17 GDPR.
- RIGHT TO DATA PORTABILITY: Data Subjects have the right to receive the personal data concerning them, which they have provided to the firm, in a structured, commonly used and machine-readable format (Article 20 GDPR). This right only applies to data that has been provided by a Data Subject, when processing is based on consent or on a contract and is carried out by automated means.
- RIGHT TO RESTRICTION OF PROCESSING: Data Subjects may obtain from the firm the restriction of the processing of their personal data under the conditions set forth in Article 18 GDPR.
- RIGHT TO WITHDRAW CONSENT: Data Subjects have the right to withdraw their consent to the processing of their data when such processing is based on consent. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
- RIGHT TO OBJECT TO PROCESSING: Data Subjects have the right to object, on grounds relating to their particular situation, to the processing of their personal data, when such processing is based on the legitimate interest of the firm (Article 21 GDPR).
- RIGHT TO GIVE INSTRUCTIONS ON WHAT SHOULD BE DONE WITH THEIR PERSONAL DATA AFTER THEIR DEATH: Data Subjects can give instructions regarding the storage, erasure and disclosure of their personal data after their death (Data Protection Act 78-17 dated January 6th, 1978, as amended, Art. 40, II).
- RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY: without prejudice to any other administrative or judicial remedy, Data Subjects have the right to lodge a complaint with a supervisory authority if they consider that the processing of personal data relating to them infringes data protection legislation (Article 77 GDPR).