Privacy Policy

This Privacy Policy is applied to all personal data that you provide to us or that we collect and process when you use the website ellex.legal of the Ellex Circle Law Firms. Ellex Circle Law Firms mean law firm Ellex Raidla in Estonia (office address: Ahtri 4, 10117 Tallinn, Estonia), law firm Ellex Klavins in Latvia (office address: K.Valdemara 62, 1013 Riga, Latvia) and law firm Ellex Valiunas in Lithuania (office address: Jogailos 9, LT-01116 Vilnius, Lithuania).

Your data that we collect in our website are processed by Ellex Circle Law Firm acting as a Controller in their respective country. “We” or “us” in this Privacy Policy refers to the respective Ellex Circle Law firm with whom you have contacted through the use of the website or who has accessed your personal data as a result of your use of the website or other respective services.

We respect your privacy and protect your personal data that you provide to us via this website. This Privacy Policy explains why we collect your personal data and how we use them.

Newsletter

We use and process your personal data (email address) for the direct marketing purpose on the basis of your consent that you express by entering your personal data in the section “Subscribe to our newsletter” of our website. We may also process for the direct marketing purpose email addresses of our clients, their representatives and employees on the basis of our legitimate interest, unless the client objects to such marketing messages in the engagement letter or expresses its objection by contacting us. Should you decide not to provide your personal data, we will not be able to inform you about current news.

We store and process your personal data for direct marketing purposes in accordance with local laws and practices or until you have unsubscribed or withdrawn your consent.

Career

We process personal data (name, surname, email address, phone number, CV and motivational letter) of candidates who sent their CV directly to us by email or through jobs portals or by using the application form available in the section “Career” of our website for the personnel selection purpose. When candidates provide their data to us, the provision of data is based on candidate’ freely given consent. Further processing of personal data for personnel selection purpose is based on our legitimate interests in processing candidate’s application, evaluating the information provided therein, organizing negotiation procedure, conducting negotiations and retaining evidence that substantiates the lawfulness of recruitment process. Should you fail to provide your personal data, we will not be able to call you for an interview and evaluate your candidacy for a job position.

While performing selection to job positions, we process only such personal data of candidates that are related to qualification, professional competences and characteristics. We do not collect or process special categories of personal data of candidates, unless required by law.

We store personal data of the candidates as long as the selection to the specific position is taking place and up to 6 months after that. Upon expiration of the period of the selection to the specific position, we delete the CV and other data sent by the candidates, unless we have obtained the candidate’s consent for processing his or her personal data longer in order to enable us to offer a job position. In such case we store the candidate’s personal data for 1 year.

Contact form

We use and process your personal data (name, surname, email address and the content of your inquiry) you entered in the section “Contact form” of our website for the purpose of giving answers to your enquiries on the basis of our legitimate interests, in particular, related to carrying out professional activity and ensuring control over information security and confidentiality requirements. Should you fail to provide your personal data, we will not be able to answer your enquiry.

Your personal data for the purpose of preparation of answers to enquiries are stored not longer than for 1 year.

Legal directories

For the purpose of assessing the quality of legal services we may process your preference to be contacted and your personal data which was collected while providing legal services, i.e. title, first name, surname, position; the name and industry sector of the represented company; address, e-mail address, telephone number; the fact whether the represented company is a client of the Law Firm; the practice area in which legal services were provided; connection with previous and other projects.

This personal data will be processed for the term of 3 years and on the basis of your consent.

Prevention of Money Laundering and Terrorism Financing

We are obliged to abide by the applicable rules on anti-money laundering (AML) and terrorism financing and know your customer (KYC) compliance. We must inform respective authorities of certain transactions performed in cash or that could involve money laundering. We will collect information related to client’s or client’s representatives identity for the purposes of AML compliance and KYC checks (identification information, information about the company, bank account and payments details, political affiliation data, source of funds / income, information on beneficial owners and other information that must be collected for these purposes) based on legal obligation to collect and process this data.

This personal data will be processed for up to 10 years after provision of our services in accordance with applicable law.

Anti-Corruption Policy

1. PURPOSE AND SCOPE

1.1 The law firm Ellex (“Firm”) conducts its activities in compliance with highest standards and principles of ethics, being guided by the values of transparency, integrity and ethical conduct.

1.2 The Anti-Corruption Policy (“Policy”) of the Firm stands as the document that delineates the Firm’s policy regarding corruption (e.g., the principles and obligations related with fostering a transparent environment for the Firm, implementation, supervision and governance of the Policy).

1.3 The Policy applies to all lawyers, consultants, legal assistants, employees (irrespective of position), and students in internships at the Firm (“Employees”). The Firm endeavors to ensure that its clients adhere to the provisions of this Policy.

2. DEFINITIONS

2.1. Terms used in the Policy:

2.1.1. Conflict of Interest – a situation in which an Employee has to choose between the perfomance of their duties and/or assigned functions and their own or a third party’s private interests.

2.1.2. Corruption – the abuse of powers for own or other persons’ benefit, to the detriment of the interests of the State or individual natural or legal persons. The most relevant corruption offences in Lithuania are: (i) bribery (passive corruption), (ii) trading in influence, and (iii) graft (active corruption).

2.1.3. Gift – any asset, right or service given or received without consideration. The concept of “gift” shall include tangible objects and other types of benefits that can be quantified in monetary terms (e.g., goods, services, entertainment, discounts, gift vouchers, loans, invitations to events, hospitality and entertainment, etc.).

2.2 Any other terms used in the Policy shall carry the definitions as prescribed by the Criminal Code of the Republic of Lithuania, the Law on Prevention of Corruption of the Republic of Lithuania, and other legal acts.

3. GENERAL PROVISIONS

3.1 In the event of any conflict between the Policy and other legal acts, the provisions of the legal acts shall prevail.

3.2 Where the Policy, laws or regulations do not provide the appropriate standards of conduct, the Firm commits to behave in the manner consistent with the highest standards of trustworthiness, integrity and transparency acceptable to the society.

4. PRINCIPLES AND COMMITMENTS

4.1. General principles for creating a transparent environment

4.1.1. The Firm operates on the principle of zero tolerance for corruption, i.e. the Firm does not tolerate any form of corruption or corrupt practices, including, but not limited to bribery, trading in influence, graft, or any other practices intended for soliciting or requesting a bribe, bribery, trading in influence, or concealing the commission of such corrupt practices. This principle shall apply in relations with both public and private sectors.

4.1.2. All Employees of the Firm must carry out their duties in good faith, without taking advantage of their position to seek personal gain or advantage for themselves or their relatives, and without otherwise engaging in activities that are detrimental to the interests of the Firm or to the public interest.

4.1.3. The Firm’s business partners and clients must also base their activities on the principles of ethical and responsible business conduct, and comply with the anti-corruption provisions that are set out in the applicable legal acts.

4.2. Management of interests

4.2.1. The Firm’s decisions and actions shall be guided by the principles of mutual trust, objectivity, and impartiality. Employees must avoid any Conflict of Interest that could adversely affect the impartial and objective performance of their duties and / or assigned functions. In the performance of their duties and / or assigned functions, Employees undertake not to seek personal gain for themselves or for their relatives.

4.2.2. The Employee who is exposed in to a situation which may give rise to a Conflict of Interest, or who becomes aware of any potential Conflict of Interest in the activities of other Employees, must report this to the anti-corruption officer.

4.3. Gifts, hospitality and other benefits

4.3.1. The Firm does not accept any Gifts that are intended to influence the activities or services of Firm (regardless of the donor) and are classified as illegal actions or corrupt practices.

4.3.2. The Firm does not offer or give any Gifts, which are intended to influence the prospects of winning contracts or the impact or outcome of Firm business activities (regardless of the recipient) and are classified as illegal actions or corrupt practices.

4.3.3. The Firm distributes corporate Gifts only to a reasonable extent and in conformity with the accepted practices of individual markets and organizations. In the context of corporate Gifts, priority is placed on the symbolic gesture of giving and the Gift’s role as reminder of the Firm. The material value of the Gifts must be of secondary (minor) importance to the recipient.

4.3.4. The Firm accepts and extends invitations to business dinners or other social occasions only to an extent that complies with the customary practices of hospitality in the country in question and at the clients in question.

4.4. Provision of support

4.4.1. The Firm refrains from any influence, whether it be direct or indirect, and does not fund or otherwise support politicians, political parties / movements, their representatives, or their candidates, election campaigns, foundations, or other organisations set up by politicians or related persons).

4.4.2. The Firm shall provide support only in accordance with legal acts regulating the provision of support and in adherence to the Firm’s rules on the provision of support.

5. IMPLEMENTATION, SUPERVISION AND GOVERNANCE OF THE POLICY

5.1. The anti-corruption officer of the Firm is responsible for ensuring that the Policy is properly communicated to the Employees or other accountable persons, and that the Policy content is clearly and understandably disclosed.

5.2. Employees shall be encouraged to report observed, suspected and / or possible cases of corruption and other violations of the Policy. In every instance, the anonymity of the whistleblower, the security of the person and the information shall be ensured and measures shall be taken to protect them from any adverse consequences of violations of the Policy.

5.3. The Firm shall ensure that all potential Policy breaches are appropriately managed by authorised and competent individuals. If any indicators of criminal activity are detected, the Firm shall promptly notify the relevant law enforcement bodies.

5.4. Violation of provisions of the Policy shall be considered a breach of obligations, which may result in consequences outlined in the association agreement. All cases of the Policy breaches shall be disclosed through the Firms’s internal communication channels, ensuring the protection of personal data.

6. FINAL PROVISIONS

6.1. All Employees must be familiarised with the Policy and comply with its requirements.

6.2. The Policy is published on the Firm’s website.

7. Anti-corruption principles

7.1. The firm does not allow corruptive activities, the purpose of which is to receive unduly benefits by abuse of position (e.g. bribery, favouritism, influence peddling).

7.2. Bribery is a promise of property or other advantages to a person in exchange for using of his or her official position. Employees of the firm shall not offer, enable, accept, demand, take or receive bribes directly or indirectly, incl. through any third party.

7.3. Influence peddling is requesting, consenting to promising of property or other advantage by a person to himself or herself or third persons or accepting thereof in exchange for his or her actual or alleged influence peddling over an official with the intention of getting unequal or unjustified advantages from the point of view of public interest for the person giving the advantage or third persons, as well as promising of giving an advantage for the same purpose. Influence peddling is prohibited.

7.4. In addition to the provisions in the Code of Ethics of the Estonian Bar Association, conflict of interest occurs also when financial or other personal considerations affect or seem to affect the employee’s loyalty, professional judgment or performance of work tasks. Employees are expected to apply impartial judgment that is not affected by private interests. It is important to prevent interests or situations that are or seem to be in conflict with professional duties.

8. Business gifts and entertainment

The firm and its employees may agree to business gifts and participation in entertainment events only if these serve a clear business purpose and are appropriate in the business relationship. It is not permitted to give or accept gifts, payments or other benefits in order to contribute to the making of a decision or in exchange for a decision.

8.2. The firm can give business gifts and offer the possibility to participate in entertainment events in appropriate occasions (e.g. birthdays, Christmas, receiving an award etc.) but these gifts cannot be of significant value (exceeding EUR 100) and it is recommended that the gift is wine, local food or a culturally appropriate thing that is not beyond common courtesy. It is not permitted to give gifts to state or local government officials.

8.3. When making donations, it should be directed at organisations, not individuals, except for if donating to an individual is an objective in itself and it is not used to conceal corruption.

8.4. Sponsorship is when the firm makes a monetary or financial contribution to associate its name or trademark with a popular event or person. Sponsorship shall be transparent. Donations or sponsorship contributions shall not be used to conceal corruption.

What type of cookies do we collect?

• Necessary cookies. These cookies are necessary for the user to browse the website and use it and its functions.
• Statistic / performance cookies. These cookies are used by the Law Firm to collect information about how visitors use our website. These statistics give us information about how often our website is visited, which pages of our website visitors spend the most time on, and how often they use the page or part of it. This allows us to make the structure, navigation and content of our website as user-friendly as possible. The Law Firm can monitor you for any errors and determine which parts of the website need to be adjusted.

For analytics purposes we are using Google Analytic services and its provided cookies. Please note that, although we only have access to aggregated data (we do not use cookies to identify specific person), the service provider of respective cookies may have access to your personal data. For more information about how Google processes your personal data, please visit: https://policies.google.com/privacy?hl=en-US. Please note that this is hyperlink to third party website for which we have no control and we are not liable for its content. By accepting third party cookies you are also consenting to the privacy policies of respective service providers.

Cookies used on the website

Data transfer

We may transfer your personal data for processing to third persons who help us to administer our website and protect its data. Such persons include suppliers of data base software, providers of data base administration services, providers of direct marketing services, providers of cloud services, etc. We may also share your personal data for conflict of interest checks and other purposes with Ellex Circle Law Firms. Your personal data can be disclosed to third parties only when required under the applicable law, for example to the government or law enforcement institutions, e.g., police or supervisory institutions, or in order to ensure our rights or safety of our clients, employees and resources. In case you agree to provide your feedback on the quality of services, your personal data may be transferred to legal directories such as the Legal 500, Chambers Global, Chambers Europe, IFLR1000, and client feedback companies such as TNS Sifo Prospera and others.

Data protection

We process data in accordance with the safety and processing requirements established in the European Union Regulation 2016/679 (the General Data Protection Regulation) and the applicable data protection laws in Estonia, Latvia and Lithuania.

We take due technical and organisational measures in order to ensure the security of personal data processing against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Your rights

You have the following rights related to your personal data:

• right to request from us access to, and rectification or erasure of, personal data, or restriction of processing;
• right to object to processing of data;
• right to receive your personal data in a structured, commonly used, machine-readable format and the right to transmit those data to another controller without hindrance (right to data portability);
• right to withdraw consent;
• right to lodge a complaint with the data protection authority in Estonia Estonian Data Protection Inspectorate (Tatari 39, 10134 Tallinn; e-mail ); in Latvia Data State Inspectorate (Elijas iela 17, Riga, e-mail: ); in Lithuania Lithuanian Data Protection Inspectorate (L. Sapiegos g. 17, Vilnius, Lithuania; e-mail ).

If you want to exercise these rights or have any questions with regard to our processing of your personal data, please contact us at in Estonia, in Latvia or in Lithuania.