Privacy Policy

This Privacy Policy explains how ROZSUD CONSULTING LTD (“ROZSUD”, “we”, “us”, “our”) collects, uses, shares and protects personal data, and the rights you have in relation to it.

1. Who we are

ROZSUD CONSULTING LTD is the controller of the personal data described in this policy. Our details are:

For any question about this policy or about your personal data, contact us at contact@rozsud.com.

2. Scope of this policy

This policy applies to personal data we process in connection with:

• the website at rozsud.com;
• enquiries sent through the website or by email;
• correspondence before any engagement is agreed;
• ordinary business correspondence;
• the administration and security of the website; and
• managing our relationships with prospective and existing clients, contacts and business partners.

Where we are engaged on a matter, the processing of personal data in the course of that engagement may also be governed by the engagement terms and by any separate notice we provide. Where those terms or notices differ from this policy, they apply to that processing.

3. Personal data we collect

Information you provide through the consultation form

• your full name and work email address;
• if you choose to give them, your company, your sector and the jurisdictions or markets you are interested in;
• the content of your enquiry and anything you choose to include in it;
• your acknowledgement that you have read this Privacy Policy; and
• the page of the website from which the enquiry was sent.

Correspondence and business relationships

When you email us, or correspond with us before or during a business relationship, we process your name, contact details, job title and organisation where given, the content of our correspondence and any other information you choose to share with us.

Where relevant to assessing whether we can act, we may also obtain information about you or your organisation from publicly available sources, such as company registers, or from the person who introduced you to us.

Technical information

When you visit the website, technical information is processed so that pages can be delivered and the website kept secure. This includes your IP address, browser and device information, the pages requested, the referring page, and the date and time of each request. It is recorded in server and security logs.

The website does not use cookies or similar technologies for analytics, advertising or tracking. Our Cookie Policy explains the position in more detail.

Information we ask you not to send

Please do not include confidential or legally privileged information, or special categories of personal data (for example, information about health, political opinions or religious beliefs) or information about criminal convictions, in an initial enquiry. If such information is needed for a matter, we will ask for it and explain how it will be handled.

4. Whether you have to provide information

You do not have to contact us or provide any personal data. To respond to an enquiry sent through the form, we need your name, a work email address and a description of your enquiry; the other fields are optional. If you do not provide the information we need, we may not be able to respond to your enquiry or assess whether we can assist.

5. How we use personal data and our legal bases

We process personal data only where we have a legal basis to do so under the UK General Data Protection Regulation (UK GDPR) and, where it applies, the EU General Data Protection Regulation.

We do not rely on your consent for the processing described above. The checkbox on the consultation form confirms that you have read this policy; it is an acknowledgement, not a request for consent. If we ask for your consent for a specific purpose in future, such as the use of non-essential cookies, you will be able to withdraw it at any time, without affecting processing that took place before you withdrew it.

We do not sell personal data, and we do not use enquiry data for unrelated marketing.

6. Legitimate interests

Where we rely on legitimate interests, those interests are:

• responding to people and businesses who ask about our services;
• assessing new matters, including whether we are able to act, before agreeing an engagement;
• running our business and managing our professional relationships and correspondence;
• keeping the website, our systems and the information we hold secure; and
• protecting our legal position.

We have considered whether our processing is necessary for these interests and concluded that, given the limited information involved and the business context in which it is provided, your interests and rights do not override them. You can ask us for more information about this assessment, and you have the right to object to processing based on legitimate interests (see section 11).

7. Who we share personal data with

We share personal data only where necessary for the purposes described in this policy. Recipients fall into the following categories:

• website hosting and infrastructure providers;
• email and communications providers;
• IT and security service providers;
• professional advisers, including lawyers, accountants and auditors, and local counsel;
• corporate and administrative service providers;
• regulators, courts, law enforcement and other public authorities, where required by law; and
• other third parties where disclosure is necessary for a matter, is required by law, or is otherwise permitted by applicable data protection law, including a successor if our business is reorganised or transferred.

Service providers that process personal data on our behalf do so under contractual terms that require them to act on our instructions and protect the data. Where an enquiry would benefit from input from local counsel or another specialist, we will normally discuss this with you before sharing details of it.

8. International transfers

Some of our service providers, professional advisers and counterparties are located, or process personal data, outside the United Kingdom and, where relevant, the European Economic Area. This is particularly likely given the cross-border nature of our work.

Where the law requires it, we make sure that such transfers are subject to appropriate safeguards. Depending on the transfer, these may include adequacy regulations or decisions, approved contractual safeguards such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses or the EU Standard Contractual Clauses, or another mechanism recognised by applicable law. You can contact us for more information about the safeguards that apply to a particular transfer.

9. How long we keep personal data

We keep personal data only for as long as is reasonably necessary for the purpose for which it was collected. That includes responding to enquiries, maintaining appropriate business records, meeting legal, accounting and regulatory requirements, managing disputes, and establishing, exercising or defending legal claims. Different categories of personal data may be kept for different periods.

• Enquiries that do not lead to an engagement are kept for as long as needed to deal with the enquiry and any follow-up, and for a limited time afterwards in case you contact us again about the same matter. They are not kept indefinitely: we review and delete them when they are no longer needed, unless we must keep them for longer to meet a legal obligation or to establish, exercise or defend legal claims.
• Where an engagement follows, the enquiry and related correspondence become part of the matter records and are kept in line with the engagement terms and our legal and record-keeping obligations.
• Technical and security logs are kept for a limited period for security and operational purposes, and then deleted or overwritten in the ordinary course.

When deciding how long to keep information, we consider:

• the purpose for which we hold it and whether that purpose can still be achieved;
• any legal, accounting, tax or regulatory requirement to keep it;
• limitation periods for possible claims; and
• the nature and sensitivity of the information.

10. Security and confidentiality

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or alteration. These include encrypted connections to the website, validation of information sent through the consultation form, and access controls that limit enquiries to the personnel who need to see them. We treat enquiries with discretion, and our service providers are bound by obligations to protect the data they process for us.

No method of transmission over the internet, or of electronic storage, is entirely without risk, and we cannot guarantee the security of information sent to us. This is one reason we ask you not to include confidential, privileged or sensitive information in an initial enquiry. Sending an enquiry does not by itself create a client relationship or legal privilege; see our Legal Notice.

11. Your rights

Under applicable data protection law, you have the right to:

• access — ask for a copy of the personal data we hold about you;
• rectification — ask us to correct personal data that is inaccurate or incomplete;
• erasure — ask us to delete your personal data;
• restriction — ask us to limit how we use your personal data;
• objection — object to processing based on legitimate interests, and to direct marketing at any time;
• portability — receive personal data you provided to us in a structured, commonly used and machine-readable format, or ask us to transmit it to another controller, where the processing is based on consent or a contract and carried out by automated means;
• withdrawal of consent — where we rely on consent, withdraw it at any time; and
• automated decision-making — not to be subject to a decision based solely on automated processing that has legal or similarly significant effects on you.

These rights are subject to conditions, limitations and exemptions under applicable law, and some apply only in particular circumstances. To exercise any of them, email contact@rozsud.com. We may need to confirm your identity before responding. We will respond within one month of receiving your request; the law allows us to extend this period in some cases, and we will tell you if we do.

12. Automated decision-making

We do not make decisions based solely on automated processing, including profiling, that have legal or similarly significant effects on you.

13. Complaints

You have the right to complain to the UK supervisory authority, the Information Commissioner’s Office (ICO), at ico.org.uk/make-a-complaint. You do not need to contact us before doing so, although we would welcome the chance to address your concern first if you wish. You may also have the right to complain to another competent supervisory authority, for example the data protection authority in the country where you live or work, or where you believe an infringement took place.

14. Children

The website and our services are intended for businesses and professionals. They are not directed at children, and we do not knowingly collect personal data from children.

15. Cookies and similar technologies

The website does not currently use non-essential cookies or similar technologies, and it does not display a cookie banner for that reason. Our Cookie Policy explains the technologies used and how you can manage cookies in your browser.

16. Changes to this policy

We may update this policy from time to time, for example to reflect changes to our services, our service providers or the law. The date at the top of this page shows when it was last updated. Where a change is significant, we will take reasonable steps to bring it to your attention.

17. Language versions

This policy is published in English, Ukrainian, Russian, Spanish, Arabic and Simplified Chinese. In the event of any inconsistency between a translated version of this policy and the English version, the English version shall prevail to the extent permitted by applicable law.

18. Contact

For any question about this policy or your personal data, email contact@rozsud.com or write to ROZSUD CONSULTING LTD, 66 Paul Street, London, England EC2A 4NA, United Kingdom. See also our Legal Notice and Website Terms of Use.