Sanctions Center Privacy Policy
This Privacy Policy describes how Sanctions Center LLC collects, uses, shares, and otherwise processes Personal Data (defined below). The controller of your Personal Data is the Sanctions Center LLC entity with which you engage (the "Firm"). The Firm processes personal data about:
Visitors to our websites
Any other individuals about whom the Firm obtains Personal Data
In this Privacy Statement, "Personal Data" means information that (either in isolation or in combination with other information held by the Firm) enables you to be identified as an individual or recognized directly or indirectly.
If you provide us with Personal Data relating to other persons (such as family members, work colleagues, employees, etc.), you are responsible for ensuring the relevant individuals are made aware of the terms of this Privacy Statement and that you are legally entitled to provide us with their Personal Data. You are also responsible for ensuring that their Personal Data is accurate and up-to-date.
Overview
Unless we specifically state otherwise, the Firm is the controller of the Personal Data we process, and is therefore responsible for ensuring that the systems and processes we use are compliant with data protection laws, to the extent applicable to us.
Firm personnel are required to comply with this Privacy Statement and associated Firm policies when dealing with Personal Data and must also complete data protection training where appropriate to their role.
Summary of Key Points
| Collection | We collect Personal Data from a number of sources in connection with the day-to-day management of our business and our commercial relationships. |
|---|---|
| Use | We use Personal Data to provide our services and respond to inquiries, to manage accounts and maintain business operations, to provide relevant marketing, and to fulfill other business and compliance purposes. |
| Sharing | We share Personal Data as necessary to provide our services and respond to requests, and to fulfil other business and compliance purposes. |
| Marketing Choices | You have control on how we use Personal Data for marketing. |
| Cookies | We use cookies on our Sites, and provide choices on use of cookies. |
| Data Subject Rights | You have certain rights to request access, rectification, deletion, objection, or other actions regarding your Personal Data where required by applicable law. |
| Data Security | We maintain technical and organizational measures to protect Personal Data from loss, misuse, alteration, or unintentional destruction of Personal Data. |
| Cross-Border Data Transfers | We provide appropriate protections for cross-border transfers where specified by law. |
| Other Issues | We provide other information in this Privacy Statement about: (i) the possible consequences for not providing Personal Data, (ii) how we do not engage in automated decision-making that has substantial effects on individuals, (iii) how we handle do-not-track (DNT) signals, (iv) data retention, (v) links to third party websites, (vi) employee and contractor issues; and (vii) changes to this Privacy Statement. |
| Contact Us | Please contact us as detailed below with any questions. |
Collection of Personal Data
We collect the following categories of Personal Data about Site visitors, clients, prospective clients, suppliers and other third parties:
Basic data: Name and email address.
Registration data: Subscriptions, downloads, and username/passwords.
Client service data: Personal Data received from clients in respect of employees, customers or other individuals known to clients, invoicing details and payment history, and client feedback.
Transaction data: Personal data contained in documents, correspondence or other materials provided by or relating to transactions, proceedings or other legal matters on which we are advising our clients.
Interaction data: Personal data such as contact data, e-mail metadata and other technical data relating to your interactions with us.
Job applicant data: Data provided by job applicants or others on our Sites or offline means in connection with employment opportunities, which also may be subject to an additional relevant local recruitment privacy policy.
Device data: Computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, and data about usage of our Sites (Usage Data).
We collect Personal Data from a number of sources, either directly from the data subjects, or from clients, colleagues and publicly available sources. Where the Firm receives data from its clients about employees, customers or other individuals, the client is responsible for ensuring that any such data is transferred to us in compliance with applicable data protection laws.
Use of Personal Data
The purposes for which we use Personal Data, and the legal bases for such processing, are as follows:
To provide legal advice and respond to inquiries we use basic data, registration data, client service data, and device data. We need to process your information in this way in order to perform our obligations under our contracts with our clients.
To manage our business operations and administer our client relationships we use basic data, special categories of data, registration data, marketing data and client service data. This processing is necessary in order to perform our obligations under our contracts with our clients (e.g. issuing and processing invoices) and suppliers (e.g. managing the supply of goods and services to the Firm).
To make our Sites more intuitive and easy to use we use device data. It is necessary for our legitimate interests to monitor how our Sites are used to help us improve the layout and information available on our Sites and provide a better service to our Site users.
To protect the security and effective functioning of our Sites and information technology systems we use basic data, registration data, transaction data, and device data. It is necessary for our legitimate interests to monitor how our Sites are used to detect and prevent fraud, other crimes and the misuse of our Sites. This helps us to ensure that you can safely use our Sites.
To expand and maintain our list of contacts, better understand how people use our services and improve the strength of our relationships with clients and other third parties we use basic data, interaction data and device data. It is necessary for our legitimate interests to keep your information accurate and up-to-date with the aim of improving the overall client experience and our relationship with you.
To provide relevant marketing such as providing you with information about events or services that may be of interest to you including legal services, legal updates, client conferences or networking events, and groups of specific interest (e.g. specific types of networking groups) we use marketing data, basic data, special categories of data, registration data, client service data, and device data. It is necessary for our legitimate interests to process this information in order to provide you with tailored and relevant marketing, updates and invitations.
To address compliance and legal obligations, such as complying with the Firm's tax reporting obligations, checking the identity of new clients and to prevent money laundering and/or fraud we use compliance data, basic data, registration data, transaction data, and device data. This processing is necessary for the purposes of complying with legal requirements to which we are subject.
To consider individuals for employment and contractor opportunities and manage on-boarding procedures we use job applicant data and compliance data. The processing is necessary for the purposes of recruitment and on-boarding and for complying with legal obligations to which we are subject and which may be subject to a relevant local recruitment privacy policy.
Sharing of Personal Data
We may share Personal Data with the following categories of recipients:
Suppliers and service providers: We share Personal Data with suppliers and service providers to enable such parties to perform functions on our behalf and under our instructions in order to carry out the purposes identified above. These include: infrastructure and IT services providers, for example, the providers of our client intake system, our finance systems and our customer relationship management databases; third party consultants who provide us with support in respect of business analytics and marketing campaigns; and the providers of external venues where we host conferences and events. We require such parties by contract to provide reasonable security for Personal Data and to use and process such Personal Data on our behalf only.
Financial institutions: We share Personal Data with financial institutions in connection with invoicing and payments.
Corporate purchasers: We may share Personal Data with any corporate purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of Firm assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Data would be transferred as an asset of the Firm.
Mandatory disclosures and legal claims: We share Personal Data in order to comply with the Firm's tax reporting obligations, comply with any subpoena, court order or other legal process, to comply with a request from our regulators, governmental request or any other legally enforceable demand. We also share Personal Data to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.
If you have questions about the parties with which we share Personal Data, please contact us at help@sanctionscenter.com
Marketing Choices
You have control regarding our use of Personal Data for direct marketing. In certain markets, you will need to expressly consent before receiving marketing. In all markets, you can choose to not receive such communications at any time. If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed, or receive any other marketing communication, please send us an email to subscriptions@sanctionscenter.com.
Cookies
We use and engage certain providers to use cookies, web beacons, and similar tracking technologies (collectively, "cookies") on our Sites.
What are cookies?
Cookies are small amounts of data that are stored on your browser,
device, or the page you are viewing. Some cookies are deleted once you
close your browser, while other cookies are retained even after you
close your browser so that you can be recognized when you return to a
websites. More information about cookies and how they work is available
at All About Cookies.
How do we use cookies?
We use cookies, and allow certain third parties to place cookies on our
Sites, in order to provide the Sites and services, gather information
about your usage patterns when you navigate the Sites in order to
enhance your personalized experience, and to understand usage patterns
to improve our Sites, products, and services.
Cookies on our Sites are generally divided into the following categories:
Necessary Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
Functional Cookies: These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
Targeting Cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
Social Media Cookies: These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.
What are your options if you do not want cookies on your
computer?
When you first visit our Sites, you will be asked for your consent to
the use of any cookies which are not classed as strictly necessary. You
can manage your choices using the consent management tool provided. If
you change your mind, you can adjust your preferences at any time using
the manage cookies link in the footer of our Sites.
Data Subject Rights
If you are in the European Economic Area (EEA) you have the following rights:
Access. Subject to certain exceptions , you have the right to request a copy of the Personal Data we are processing about you, which we will provide to you in electronic form. At our discretion we may require you to prove your identity before providing the requested information. If you require multiple copies of your Personal Data, we may charge a reasonable administration fee.
Rectification. You have the right to require that any incomplete or inaccurate Personal Data that we process about you is amended.
Deletion. You have the right to request that we delete Personal Data that we process about you, unless we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
Restriction. You have the right to request that we restrict our processing of your Personal Data where:
you believe such data to be inaccurate;
our processing is unlawful; or
we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
Portability. You have the right to request that we transmit the Personal Data we hold in respect of you to another controller, where this is:
personal information which you have provided to us; and
we are processing that data on the basis of your consent or in order to perform our obligations under contract to you (such as to provide legal services).
Objection. Where the legal justification for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
Withdrawing Consent. If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge This includes cases where you wish to opt out from marketing messages that you receive from us.
If you are in the EEA you also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. Access a list of local data protection authorities in EEA countries.
Data Security
We have implemented technical and organisational measures in an effort to safeguard the Personal Data in our custody and control. Such measures include:
restricting access to Personal Data to staff and service providers on a need-to-know basis;
a formal Information Security Management System (ISMS) aligned with ISO 27001 and 27002:2013. The ISMS is a comprehensive set of policies and procedures for deploying, managing and securing the Firm's Information Technology infrastructure; utilizing a defense-in-depth approach to protecting our internal Firm and client data.
While we endeavour to always protect our systems, sites, operations and information against unauthorized access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.
You also have an important role in protecting Personal Data. You should not share any username, password or other authentication data provided to you with anyone, and we recommend that you do not re-use passwords across more than one website or application. If you have any reason to believe that your username or password has been compromised, please contact us as detailed below.
Cross-Border Data Transfers
We transfer Personal Data to jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of data protection as your home country. In particular, our Sites are hosted on servers in the United States. If you are located in a non-US jurisdiction, the transfer of Personal Data is necessary to provide you with the requested information and/or to perform any requested transaction. When you submit personal information to us you are transferring your data across borders.
With respect to transfers originating from the European Economic Area and Switzerland (together "EEA") to the United States and other non-EEA jurisdictions, we implement standard contractual clauses approved by the European Commission, and other appropriate solutions to address cross-border transfers as required or permitted by Articles 46 and 49 of the General Data Protection Regulation or other relevant laws. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below.
Other Issues
What are the consequences of not providing Personal Data?
You are not required to provide all Personal Data identified in this Privacy Statement to use our Sites or to interact with us offline, but certain functionality will not be available if you do not provide Personal Data. If you do not provide Personal Data, we may not be able to respond to your request, provide legal services to you, or provide you with marketing that we believe you would find valuable.Do we engage in automated decision-making without human intervention?
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.Do the Sites honor do not track ("DNT") signals sent via browsers?
Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we generally do not respond to DNT signals at this time.How long do we retain Personal Data?
We typically retain Personal Data related to marketing activities for as long as you accept marketing communications from us, and we will securely delete such data in accordance with applicable law upon request. For Personal Data that we collect and process for other purposes, we will typically retain such Personal Data for as long as it is necessary to fulfill the purposes outlined in this Privacy Statement and as otherwise specified in applicable record retention policies and procedures.Are third party websites governed by this Privacy Statement?
The Sites may contain links and references to other websites administered by unaffiliated third parties. This Privacy Statement does not apply to such third party sites. When you click a link to visit a third party website, you will be subject to that website's privacy practices. We encourage you to familiarize yourself with the privacy and security practices of any linked third party websites before providing any Personal Data on that website.How will we handle any changes to this Privacy Statement?
We may update this Privacy Statement from time to time as our services and privacy practices change, or as required by law. The effective date of our Privacy Statement is posted below, and we encourage you to visit our Sites periodically to stay informed about our privacy practices. We will post the updated version of the Privacy & Cookies Statement on our Sites, and ask for your consent to the changes if legally required.
Contact Us
If you have questions or comments regarding this Privacy Statement or our privacy practices, please contact us here: help@sanctionscenter.com
Effective date: August 2024
Sanctions Center Terms of Service
Effective Date: August 1, 2024
Welcome to Sanctions Center LLC ("Company," "we," "us," or "our"). These Terms of Service ("Terms") govern your access to and use of our website, services, and any related content (collectively, the "Services"). By accessing or using our Services, you agree to be bound by these Terms. If you do not agree with these Terms, you may not use our Services.
1. Acceptance of Terms
By accessing or using the Services, you agree to these Terms and our Privacy Policy. These Terms apply to all visitors, users, and others who access or use the Services ("Users").
2. Changes to Terms
We reserve the right, at our sole discretion, to modify or replace these Terms at any time. We will notify you of any changes by posting the new Terms on our website. Your continued use of the Services following the posting of any changes constitutes acceptance of those changes.
3. Use of Services
a. Eligibility
You must be at least 18 years of age to use our Services. By using the Services, you represent and warrant that you have the legal capacity to enter into these Terms.
b. Account Registration
Some features of our Services may require you to create an account. You are responsible for maintaining the confidentiality of your account information and for all activities that occur under your account.
c. Prohibited Conduct
You agree not to use the Services for any unlawful or prohibited activities, including but not limited to:
- Violating any applicable laws or regulations.
- Infringing on the intellectual property rights of others.
- Attempting to gain unauthorized access to our systems or Services.
- Using the Services to transmit harmful or disruptive code.
4. Intellectual Property
All content, trademarks, logos, and other intellectual property provided by the Company as part of the Services are owned by or licensed to the Company. You may not use, reproduce, distribute, or create derivative works based on the content of our Services without our express written permission.
5. Fees and Payment
Certain features of the Services may require payment of fees. You agree to pay all applicable fees and charges in accordance with the terms set forth at the time of purchase. All payments are non-refundable unless otherwise stated.
6. Termination
We may terminate or suspend your access to the Services, without prior notice or liability, for any reason, including if you breach these Terms. Upon termination, your right to use the Services will immediately cease.
7. Disclaimers and Limitation of Liability
a. Disclaimer of Warranties
The Services are provided on an "as is" and "as available" basis. We make no warranties, express or implied, regarding the availability, reliability, or accuracy of the Services.
b. Limitation of Liability
To the maximum extent permitted by law, Sanctions Center LLC shall not be liable for any indirect, incidental, special, consequential, or punitive damages, or any loss of profits or revenues, whether incurred directly or indirectly, or any loss of data, use, goodwill, or other intangible losses, resulting from your use of the Services.
8. Indemnification
You agree to indemnify, defend, and hold harmless Sanctions Center LLC, its affiliates, and their respective officers, directors, employees, and agents from and against any and all claims, liabilities, damages, losses, costs, expenses, or fees (including reasonable attorneys' fees) that arise from your violation of these Terms or your use of the Services.
9. Governing Law
These Terms shall be governed by and construed in accordance with the laws of the State of [Your State], without regard to its conflict of law provisions. Any dispute arising under or related to these Terms shall be resolved exclusively by the state and federal courts located in [Your State].
10. Miscellaneous
a. Entire Agreement
These Terms, together with our Privacy Policy, constitute the entire agreement between you and Sanctions Center LLC regarding the use of the Services.
b. Severability
If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions will remain in full force and effect.
c. Waiver
No waiver of any term or condition shall be deemed a further or continuing waiver of such term or condition or any other term or condition.
d. Contact Information
For any questions about these Terms, please contact us at:
Email: help@sanctionscenter.com
Sanctions Center LLC
August 1, 2024
By using our Services, you acknowledge that you have read, understood, and agree to be bound by these Terms.
Sanctions Center Disclaimer
The information provided on this website, operated by Sanctions Center LLC ("Company," "we," "us," or "our"), is for general informational purposes only. All content, including but not limited to articles, reports, and summaries, is provided in good faith; however, we make no representations or warranties of any kind, express or implied, regarding the accuracy, completeness, reliability, suitability, or availability of any information on the site.
No Professional Advice
The content on this website is not intended to serve as legal, financial, or professional advice. You should not rely on any information provided on this site as a substitute for consultations with qualified professionals who are familiar with your specific situation. The use of any information on this site is at your own risk.
Third-Party Links
Our website may contain links to third-party websites or content. These links are provided for your convenience and do not signify our endorsement of the views expressed or the products or services offered. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party websites.
Limitation of Liability
Sanctions Center LLC, its affiliates, officers, directors, employees, agents, and partners shall not be liable for any loss or damage of any kind, including but not limited to direct, indirect, incidental, consequential, or punitive damages, arising out of or in connection with your use of this website or reliance on any information provided herein.
Changes to This Disclaimer
We reserve the right to modify this disclaimer at any time without prior notice. By continuing to use our website after any changes, you accept and agree to the revised disclaimer.
Contact Information
If you have any questions or concerns regarding this disclaimer,
please contact us at:
Email: help@sanctionscenter.com
Sanctions Center LLC
© 2024 Sanctions Center LLC. All Rights Reserved.
All content, including but not limited to text, graphics, logos, images, and software, on this website is the property of Sanctions Center LLC and is protected by United States and international copyright laws. Unauthorized use, reproduction, or distribution of any material from this website is strictly prohibited without the express written permission of Sanctions Center LLC.
For permissions or inquiries, please contact us at help@sanctionscenter.com
