1. General

Nanwani Solicitors LLP is committed to protecting personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”).

Nanwani Solicitors LLP is regulated by the Law Society of Hong Kong and is a data user for the purposes of the PDPO.

This document explains how we collect, use, disclose, transfer, store and protect personal data. Information provided to us constitutes personal data if it relates directly or indirectly to you and from which your identity can be ascertained.

2. Personal data we collect

The categories of personal data that we collect are described in our Personal Information Collection Statement in Section 12.

3. Purposes of collection and use

We collect and use personal data only for lawful purposes and in accordance with the PDPO.

The purposes for which personal data may be collected and used are set out in our Personal Information Collection Statement in Section 12.

4. AML / KYC and regulatory compliance

We are required to comply with applicable anti-money laundering and counter-terrorist financing laws, regulations and professional obligations, including customer due diligence requirements. We may collect, verify and retain identity documents, beneficial ownership information, source of funds, source of wealth, sanctions and politically exposed person screening results and other information required for compliance purposes. If requested information is not provided, we may be unable to accept instructions or continue to act.

5. Accuracy of information

You are responsible for ensuring that personal data provided to us is accurate, complete and current and for notifying us of any changes. We may rely on information supplied by you or your authorised representatives unless informed otherwise.

6. Disclosure of personal data

We may disclose personal data where necessary for the purposes described in this Privacy Policy and Personal Information Collection Statement, including to professional advisers, service providers, regulators and others as permitted or required by law. Further details are set out in our Personal Information Collection Statement in Section 12.

7. Overseas data transfers

Personal data may be transferred to, processed in, or accessed from jurisdictions outside Hong Kong where required for legal services, business operations, cloud hosting, document storage or engagement of overseas advisers. Such jurisdictions may not provide the same level of protection as Hong Kong. By providing personal data, you acknowledge that such transfers may occur.

8. Direct marketing

Subject to the PDPO and your consent where required, we may use your name, organisation, position and contact details to send legal updates, publications, newsletters, invitations to seminars and events, and information about our services. You may opt out at any time by contacting us.

9. Cookies and website use

Our website (www.nanwanis.com) may use cookies and similar technologies to support functionality, ensure security, analyse traffic and improve user experience. You may disable cookies through your browser settings, although some website functions may be affected.

10. Retention and security

We retain personal data only for as long as it is reasonably necessary for the purposes for which it was collected and in accordance with law.

Appropriate technical and organisational safeguards are implemented to protect personal data from unauthorised access, use, loss, alteration or disclosure.

11. Your rights

Subject to the PDPO, you may request access to personal data we hold about you, request correction of inaccurate personal data, and request that we cease using your personal data for direct marketing. A reasonable fee may be charged for processing access requests where permitted by law.

12. Personal Information Collection Statement

12.1  Scope

This Personal Information Collection Statement (“PICS”) applies to personal data collected by Nanwani Solicitors LLP through its website (www.nanwanis.com), legal practice and business operations, including where you:

• visit our website;
• subscribe to publications or legal updates;
• attend events organised or sponsored by us;
• contact us or make enquiries about our services;
• seek legal advice or legal services;
• are a client, prospective client, counterparty or representative of a client;
• apply for employment or internship opportunities; or
• otherwise interact with us in a professional or business capacity.

12.2  Personal Data Collected

We may collect and process personal data including:

• names, former names and aliases;
• contact details, including email addresses, telephone numbers and postal addresses;
• nationality, citizenship and identification details;
• passport, Hong Kong Identity Card and other identification documents;
• occupation, employer, job title and business information;
• company, directorship, shareholder and beneficial ownership information;
• billing, banking and payment information;
• source of funds and source of wealth information;
• information required for anti-money laundering and counter-terrorist financing compliance;
• educational, employment and recruitment-related information;
• photographs, audio recordings and visual images;
• IP addresses, device information, cookies and other website usage information; and
• any other information relevant to the provision of legal services or compliance with legal or regulatory obligations.

12.3  Sources of Personal Data

Personal data may be obtained directly from you, from our clients and their authorised representatives, counterparties, professional advisers, recruitment agencies, public registries, government authorities, regulators, courts, law enforcement agencies and publicly available sources, including professional networking and social media platforms.

12.4  Purposes of Collection

Personal data may be collected, held, used, processed and transferred for the purposes described in this Privacy Policy, including:

• providing legal services and advice;
• conducting conflict checks and client onboarding procedures;
• complying with anti-money laundering, sanctions screening and other regulatory obligations;
• managing and administering client relationships;
• billing, payment processing and debt collection;
• recruitment and human resources purposes;
• organising events and business development activities;
• operating, maintaining and improving our website and services;
• establishing, exercising or defending legal rights;
• fraud prevention, risk management and security purposes; and
• complying with applicable laws, regulations and professional obligations.

12.5  Transfers of Personal Data

For the purposes set out above, we may transfer personal data to:

• our partners, employees and consultants;
• barristers, foreign counsel, experts and other professional advisers;
• banks, insurers, auditors and accountants;
• information technology, cloud hosting, cybersecurity and document management service providers;
• translation, transcription and litigation support providers;
• recruitment, background screening and compliance service providers;
• courts, tribunals, regulators, government authorities and law enforcement agencies;
• counterparties and their professional advisers where required in connection with a matter; and
• any other person where disclosure is required or permitted by law.

12.6  Failure to Provide Information

Provision of personal data is generally voluntary. However, if requested information is not provided, we may be unable to:

• establish or continue a solicitor-client relationship;
• provide legal services;
• comply with our legal and regulatory obligations; or
• process applications, enquiries or requests.

13. Changes to this Privacy Policy

We may amend this Privacy Policy and PICS from time to time. Any changes will be published on our website (nanwanis.com).

14. Additional information

For more information about personal data privacy in Hong Kong, please visit the website of the Office of the Privacy Commissioner for Personal Data at www.pcpd.org.hk.

15. Contact details

If you need further information or have any questions or requests regarding this Privacy Policy or PICS, please write to:

Nanwani Solicitors LLP
Units 08B-09, Tower 1, Lippo Centre
89 Queensway, Admiralty
Hong Kong
Email: mail@nanwanis.com