William Fry 

William Fry is responsible for your Personal Data.  William Fry comprises the partnership known as William Fry constituted under the laws of Ireland (with offices in Dublin, London, New York, Silicon Valley and San Francisco) and any entities owned or controlled by it (or by some or all of its partners) in connection with its business, including William Fry Tax Advisors Limited and Wilton Secretarial Limited (the "William Fry Companies"). References in this Statement to "William Fry", "we", "our" or "us" include the William Fry Companies and the international offices. Each of these entities is committed to protecting your privacy.

Privacy Statement 

This Privacy Statement ("Statement") explains how and why William Fry processes personal information (known as "Personal Data" under applicable data protection law) that we collect from or that is provided to us by clients and/or those with whom we deal on behalf of clients, as part of our business operations, including via our website, www.williamfry.com (the "Website").

Please see our Cookie Policy if you would like to understand how we use cookies and other web tracking devices on our Website. 

If you are a client of William Fry and would like to know more about our client confidentiality obligations, please refer to our Terms of Engagement. 

 

We may process your Personal Data:

  • when you, or an organisation with which you are connected, are our client (see 1 below );
  • for marketing, business operation and relationship management purposes (see 2 below);
  • and/orwhen you visit our Website (see 3 below).

Processing your personal data when you, or an organisation with which you are connected, are our client 

1. How we Collect your Personal Data when you, or an Organisation with which you are Connected, are our Client

When you or an organisation with which you are connected (e.g. your employer) engages us to perform legal or other services, we may collect certain Personal Data directly from you, your organisation and/or from publicly available resources (e.g. company filings).

2. What Personal Data we Process when you, or an Organisation with which you are Connected, are our Client

William Fry will collect and process Personal Data including, where applicable:

  • your name;
  • your employer, your job title and/or position;
  • your contact details, including your address, email address and phone number;
  • documentation confirming your identity, such as your passport or driving licence;
  • your status as a director of a company;
  • your status as a beneficial owner of a company;
  • financial information, including information necessary to make or receive payments to and from you and for the purposes of fraud prevention;
  • details of your visits to William Fry and your correspondence, communications and connections with our staff;
  • special category Personal Data, specifically information regarding any disability or mobility or dietary requirements you might have, which we will only process on the basis of your consent;
  • publicly available information
  • and any information which is provided to us by you or on your behalf.

3. Legal Basis

We process this Personal Data according to the following legal bases:

Entering into and performing a contract: We process your Personal Data where it is necessary to enter into and perform our contract with you, and in particular:

  • to incept you or your organisation as our client;
  • to provide the legal advice or other services or matters that have been requested (including online or legal technology services or solutions for which we are engaged);
  • managing and administering your or your organisation's business relationship with William Fry, including processing payments, accounting, auditing, billing and collection and support services; and
  • for purposes related and/or ancillary to any of the above or any other purpose for which your Personal Data was provided to us.

It is necessary to provide us with your Personal Data on this basis as it is necessary to provide our services to you. The consequence for not doing so is that we will not be able to perform the legal services for which you or your organisation engage us.

Legitimate interests: We process your Personal Data where it is in our legitimate interests to do so, and in particular:

  • to incept the organisation with which you are connected as our client;
  • to enter into a contractual relationship with the organisation with which you are connected;
  • to provide legal advice or other services or matters that the organisation has requested (including online internet or legal technology services or solutions for which our client engages us);
  • managing and administering the organisation's business relationship with William Fry, including processing payments, accounting, auditing, billing and collection and support services;
  • to conduct client due diligence checks; and
  • for purposes related and/or ancillary to any of the above or any other purpose for which your Personal Data was provided to us.

When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). 

You have certain rights when we process your Personal Data on this basis. For more on exercising your data subject rights please see 'Your Rights'.

Compliance with legal obligations: We also process your Personal Data in order to comply with legal obligations to which we are subject. We process your Personal Data:

  • to comply with our legal and regulatory obligations (e.g. record keeping obligations);
  • to conduct client due diligence checks;to comply with our obligations under anti-money laundering and terrorist financing legislation;
  • to comply as appropriate with the Law Society of Ireland, Chartered Accountants Ireland and other relevant governmental and/or regulatory authorities or bodies;
  • to conduct conflict checks;
  • to establish, exercise and defend our legal rights and any legal proceedings which may arise; and
  • to prevent, detect and respond to actual or potential fraud or other illegal activities.

4. Sharing and Disclosure of your Personal Data

We may disclose some or all of the Personal Data we collect from you to certain trusted third parties in accordance with contractual arrangements we have in place with these third parties or as required by law, including:

  • the William Fry Companies;
  • third parties such as barristers, foreign counsel, consultants, expert witnesses, advisors and technology service providers such as data room providers;
  • other people in your organisation;our auditors and professional advisors;
  • suppliers and service providers to whom we outsource support services;
  • IT service providers;
  • parties involved in hosting or organising events or seminars; and
  • regulators and official authorities.

5. Data Retention

In accordance with our Data Retention Policy, we shall keep the Personal Data we process on the instructions of our clients for a minimum period of 13.5 years from closure of the relevant matter, or for a period of 7.5 years after the client in question ceases to be our client.  We retain the Personal Data so that we may fulfil our obligation and duty as a law firm to protect our client's interests, to protect our own interests as a law firm and as is required by legal and regulatory obligations to which we are subject.

Processing your personal data for marketing, business operation and relationship management purposes

1. How we Collect your Personal Data which we Process for Marketing, Business Operation and Relationship Management Purposes

We may collect your Personal Data for marketing, business operation and relationship management purposes when you or your organisation:

  • engage us, or enquire about engaging us, to provide legal advice or services;
  • communicate with any of our staff;
  • visit our premises;
  • work with us or supply us with services, or offer to;
  • when you supply your Personal Data to us via our Website, email, in person, by telephone or otherwise;
  • when you subscribe to, or express interest in, any of our newsletters or mailing lists, or access to any of our restricted content; and
  • when you attend, or express an interest in, any of our events or seminars.

2. What Personal Data we Process for Marketing, Business Operation and Relationship Management Purposes

For marketing, business operation and relationship management purposes, William Fry will collect and process Personal Data including:

  • your name;
  • your employer, your job title and/or position;
  • your contact details, including your address, email address and phone number;
  • CCTV footage, when you visit our premises;
  • our business activities and your areas of interest; and
  • information relating to your subscription to, receipt of or interest in any of our mailing lists or newsletters, or registration to access any of our restricted content (e.g. InFocus, PrivacySource).

3. Legal Basis

We process this Personal Data according to the following legal basis:

Legitimate interests: We may obtain, collect and process your Personal Data where we have a legitimate interest in doing so.  We have legitimate interests in:

  • promoting our firm;
  • inviting you to events, seminars, webinars and meetings;
  • developing and maintaining relationships with business contacts;
  • conducting administrative and operational processes within our business;
  • protecting the security and integrity of our premises, IT systems, online platforms and other systems;
  • managing and administering our relationship with our business contacts and with our clients;
  • sending you marketing material, newsletters, legal updates and other information; and
  • monitoring and analysing your reception of, and interest in, material we send you.

When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).

You have certain rights when we process your Personal Data on this basis. For more on exercising your data subject rights please see 'Your Rights'.

4. Sharing and Disclosure of your Personal Data

We may disclose some or all of the Personal Data we collect from you to certain trusted third parties in accordance with contractual arrangements we have in place with these third parties, including:

  • third parties who assist us in marketing and promoting the firm;
  • suppliers and service providers to whom we outsource support services;
  • IT service providers; and
  • third parties involved in hosting or organising events or seminars.

5. Data Retention

We will keep and process your Personal Data for these purposes for a period of six years after collection.  If however you wish to opt out of receiving marketing emails, newsletters or other such communications, you may do so at any time by emailing us at marketing@williamfry.com

Similarly if you wish to exercise your rights as a data subject over any of this Personal Data you may do so by emailing dpqueries@williamfry.com.

For more on exercising your data subject rights please see 'Your Rights'.

Processing your personal data when you visit our website 

How we Collect your Personal Data when you Visit our Website

1. For information about how we collect your Personal Data when you visit our Website, please see our Cookie Policy.

 

2. What Personal Data we Process when visit our Website

When you visit our Website, William Fry will collect and process Personal Data including:

  • the name of the domain and host from which you access the internet;
  • the internet protocol (IP) address of the computer which you are using;
  • the browser software you are using;the operating system you are using; and
  • the date and time at which you are accessing the Website.

William Fry will also collect and process information about your interaction with our Website using cookies.  For more information on how we use cookies, please see our Cookie Policy.

3. Legal Basis

We process this Personal Data according to the following legal basis:

Legitimate interests: We may obtain, collect and process your Personal Data where we have a legitimate interest in doing so.  We have legitimate interests in:

  • providing you with access to our Website and enabling you to use it;
  • conducting administrative and operational processes within our business;protecting the security and integrity of our online platforms, IT systems and other systems;
  • providing, improving, monitoring and testing the effectiveness of our Website;
  • ensuring the content on the Website is presented in an effective, accessible and user-friendly format; and
  • monitoring metrics such as numbers of visitors, traffic data and demographic patterns.

When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).  

You have certain rights when we process your Personal Data on this basis. For more on exercising your data subject rights please see 'Your Rights'.

4. Sharing and Disclosure of your Personal Data

We may disclose some or all of the Personal Data we collect from you to certain trusted third parties in accordance with contractual arrangements we have in place with these third parties, including:

  • suppliers and service providers to whom we outsource support services; and
  • IT service providers.

5. Data Retention

For information about how long we retain Personal Data collected when you visit our Website for, please see our Cookie Policy.

It is your responsibility to ensure that all Personal Data you provide us with is complete, accurate and up-to-date in all respects and not misleading.  Our ability to provide our advice and services, and the quality thereof, may be negatively affected if you fail to do so.

You may provide Personal Data about yourself or about other people to us during the course of our dealings with you.  Whenever you provide us with Personal Data about another person, you must ensure that you are entitled to disclose the Personal Data relating to that other person to William Fry and that we may process that Personal Data in accordance with this Privacy Statement without having to take any further steps.  It is your responsibility to ensure that the person concerned is aware of the content of this Privacy Statement.  

In certain circumstances we may transfer your Personal Data outside of the EU. We only transfer your Personal Data where the EU Commission has decided that the third country in question ensures an adequate level of protection in line with EU data protection standards, or where there are appropriate safeguards in place to protect your Personal Data. If you would like to find out more about the appropriate safeguards that we have in place to govern the transfer of your Personal Data you can contact us at dpqueries@williamfry.com.

In particular when we transfer your Personal Data to those William Fry Companies which are situated outside of the EU, we shall do so in accordance with Standard Contractual Clauses to which William Fry and the William Fry Companies are subject, and which are accessible here

You have a number of rights regarding access to and control of your Personal Data, including:

  • Right of Access: You have the right to ascertain what type of Personal Data William Fry holds about you and to a copy of this Personal Data.
  • Right to Complain: You have the right to lodge a complaint regarding the processing of your Personal Data to the Data Protection Commission.
  • Right to Erasure: In certain circumstances you may request that we delete the Personal Data that we hold on you.
  • Right to Object: Where we rely on our legitimate interests to process your Personal Data, you have a right to object to this use.  We will desist from processing your personal information unless we can demonstrate an overriding legitimate interest in the continued processing.
  • Right to Portability: You may request us to provide you with certain Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another data controller where this is technically feasible.
  • Right to Rectification: You have the right to have any inaccurate Personal Data which we hold about you updated or corrected.
  • Right to Restriction: You have the right to request that William Fry stop using your Personal Data in certain circumstances including if you believe that the Personal Data we hold about you is inaccurate or that our use of your Personal Data is unlawful. If you validly exercise this right, we will store your Personal Data and will not carry out any other processing until the issue is resolved.

Please bear in mind that your rights in relation to your Personal Data are not absolute and that we must be cognisant of our legal and regulatory obligations and our duties as a law firm.  

You can exercise your rights in relation to your Personal Data by contacting dpqueries@williamfry.com. We may request that you provide proof of your identity for security reasons and in order to prevent the unauthorised disclosure or misuse of Personal Data.  We will only charge you for requests to access your Personal Data where they are unreasonable, unfounded or excessive.   If, after contacting us, you are still not satisfied with our response, you have the right to lodge a complaint with the Data Protection Commission.  Please see www.dataprotection.ie for further information.

We may amend this Statement on occasion, in whole or part, at our sole discretion. Any changes will be effective immediately.  You should check this page from time to time to take notice of any changes we make, as they will be binding on you.

If at any time we decide to use your Personal Data in a manner significantly different from that stated in this Statement, or as otherwise disclosed to you at the time it was collected, we will notify you by e-mail or by telephone, and you will have a choice as to whether or not we use your Personal Data in the new manner.

At William Fry ("William Fry", "we", "our" and "us") we respect the privacy of all visitors to our Website.

This is our policy on the use of cookies on www.williamfry.com (the "Website"). We may update this Cookie Policy from time to time to reflect any changes in technology or legislation affecting the way we use cookies and how you, as a user, can manage them.  We may change this policy from time to time by updating this page. You should check this page from time to time to ensure you are happy with any changes.

What Cookies Are and How We Use Them

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a better experience when you visit our Website and assists us in making improvements. It enables the Website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them when you come back to the Website or browse from one page to another.

A cookie is a small text file, often encrypted, that is placed in your web browser on your PC, telephone, tablet or other device when you visit a website. During the course of your visit to that website, and on subsequent visits, it sends information from your browser about your visit(s). They do not damage your device.

The Types of Cookies We Use

  • Functional/strictly necessary cookies: These are cookies that are necessary for the operation of our Website. They include, for example, cookies that register the type and version of your browser and enable you to login to view registration-only content.  If you disable these cookies then the Website will not function properly.
  • Analytical/performance cookies: These allow us to recognise and count the visitors to our Website and to see how visitors use our Website. This information helps us to improve the way our Website works, for example, by ensuring that users find what they are looking for easily. If you do not consent to the use of these cookies, please disable them following the instructions in this Cookie Policy so that cookies from this Website cannot be placed on your device. This information is gathered anonymously - it is not to enable us to identify who you are. We use these cookies to determine the kind of content and services our visitors value most, which in turn helps us improve our Website and its content.
  • Social media cookies: These cookies are embedded in tools providing access to social networks from our Website.  They may collect personal information in relation to your use of these social networks. We have no control over how the social networks may collect and use your personal information and their use is determined by that social network.
  • Google Analytics cookies: This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses its own persistent cookie, which expires two years after it is placed on your computer. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google, which may include being stored on its servers in the United States. For more information about Google Analytics cookies see http://www.google.com/analytics/learn/privacy.html.

    You can find more information about the individual cookies that we use and the purposes for which we use them in the table below.
 Cookie Description Expiry 
 _atuvc
 These first party cookies are created and read by the AddThis social sharing site in order to make sure users see the updated count if users share a page and return to it before the share count cache is updated. No data from these cookies is sent back to AddThis.  13 months from last visit
 _atuvs  hese first party cookies are created and read by the AddThis social sharing site in order to make sure users see the updated count if users share a page and return to it before the share count cache is updated. No data from these cookies is sent back to AddThis.  13 months from last visit
 _ga  These first party cookies are used to distinguish visitors to the Website.  12 months from last visit
 _gat  These first party cookies are used to throttle the request rate.  10 minutes
 _gid  These first party cookies are used to throttle the request rate.  10 minutes
 lang  This cookie enables you to toggle the language in which the Website is presented to you.  1 year
 sf-trckingckie  These first party cookies log the page visit.  180 days

 

Third Party Cookies

Some cookies that have been set on our Website are not directly related to or overseen by William Fry. You will note that third parties (particularly advertising companies, social networks and service providers such as retargeting or even behavioural analysis services) can also place cookies on our Website. 

We have no control over these cookies. These cookies can have the purpose of analysing performance or allowing customised targeting of advertising displayed on your web browser.

Cookie Description Expiry 
 BizoData  This cookie is used for advertising analytics purposes by LinkedIn.  6 months
 BizoID  This cookie is used for advertising analytics purposes by LinkedIn.  6 months
 BizoNetworkPartnerIndex  This cookie is used for advertising analytics purposes by LinkedIn.  6 months
 BizoUserMatchHistory  This cookie is used for advertising analytics purposes by LinkedIn.  6 months
 bscookie  This cookie is used by LinkedIn in conjunction with the L1c cookie to secure the ID of your browser.  1 year
 L1c  This cookie identifies your browser for LinkedIn.  Current session
 lidc  This cookie is used for routing by LinkedIn.  1 day

 

 

How to Control and Delete Cookies

Web browsers accept cookies by default but you can usually change the web browser’s settings to refuse new cookies, disable existing ones or simply let you know when new ones are sent to your device.

In order to do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” facility) or you can click on the links below to access instructions from some of the most popular browsers:

For more information on how to manage cookies, please visit http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm.

Please be aware that if you refuse or disable cookies then some of the Website’s functionality may be adversely affected for you. 

In addition, disabling a cookie or category of cookie does not delete the cookie from your browser and would need to be done by you within your browser if you so wish.

Changes to Our Use of Cookies

Any changes to our use of cookies for this Website will be posted here and if appropriate, we will highlight and signpost changes.

Contact Information

If you have any queries in relation to this notice, please contact us at dpqueries@williamfry.com.

 

If you have any questions or concerns, please contact us on dpqueries@williamfry.com