Rollette & Co
- Purpose of this policy
- Who are we and what do we do
Rollette & Co is a law firm registered in Tanzania (Business name No. __________). Its principal place of business at Diamond Plaza, 6th Floor, 8Mirambo Street/Samora Avenue, POP.O Box 75480, Dar es Salaam, Tanzania.
Rollette & Co is a member of ALFA International, a legal network of independent law firms having their presence in USA, Canada, Mexico, Europe, Middle East, Asia and Africa. Further information on ALFA International can be foundat https://www.alfainternational.com
- How to contact us
Clement E.A. Kihoko
T: +255 713 419120
T: +255 786 986 105
- What personal information do we collect
We may collect personal information in the course of our business, when you contact us or request information from us, when you engage our Services or as a result of your relationship with one or more of our staff and clients. When we require personal information from you in order to fulfil a statutory or contractual requirement, or where such information is necessary to enter into a contract or is otherwise an obligation, we will inform you and indicate the consequences of failing to do so.
From individuals who are clients and prospective clients, or are representatives of clients and prospective clients, we may collect the following personal information:
- Your name, the name of the entity (company, partnership, association, organisation, trust) you work for (if different) and your job title.
- Contact information for you, and the entity (company, partnership, association, organisation, trust) you work for (if different), including address, fax, phone number and email address.
- Payment information (including bank account and wire details), billing instructions and preferences (including to whom to direct invoices).
- Relevant information so that we can perform conflicts of interest checks.
- Relevant information as required by the Anti Money Laundering regulations and as part of our client intake procedures. This may include official records at the Companies Registry (memorandum and articles of association of the company and its certificate of incorporation), latest periodical reports and audited accounts, persons exercising control or significant influence over the organisation’s asset, evidence of source of funds.
- Please note, the requested information may be at the outset and possibly from time to time throughout our relationship with clients, which we may request and/or obtain from third party sources. The sources for such verification may include documentation, which we request from the client or prospective client or through the use of online or public sources or both.
- Information you provide to us for the purposes of attending meetings and events, including dietary requirements, which may reveal information about your health or religious beliefs.
- Other information relevant to the provision of Services.
Related parties and client representatives
Rollette & Co is also engaged by corporate entities and clients, who contain natural persons, subsidiary companies or parent companies that are not data subjects However, as part of our engagement with these clients, we may receive personal information about individuals, such as names, contact details and other information relating to:
- Officers, representatives and/or personnel of our corporate clients or prospective clients, as well as their affiliated and related entities.
- Adverse parties in a matter or potential matter, such as claimants, plaintiffs, defendants and other adverse parties.
- Related parties in a matter or potential matter.
- Vendors and suppliers of our corporate clients or prospective clients.
- Current and former legal advisors, consultants and other professional advisors of our corporate clients or prospective clients.
- Government and/or law enforcement entities and their representatives.
If you are an individual whose personal information is processed by us as a result of providing the Services to others (including individual clients and corporate clients), we will process a variety of different personal information depending on the Services provided.
For example, if we are representing a client in a cross-border acquisition, we may receive and then process (among other information) details of the key managers of the target company.
We might also need to process personal information in relation to other third parties instructed either by our own clients or other persons or companies involved in providing the Services to our client (e.g., other law firms, experts etc.).
These examples are non-exhaustive, which is reflective of the varied nature of the personal information we process as part of a law firm providing legal services.
For clients and prospect, we also collect information to enable us to market our Services, which may be of interest to you. For this purpose, we collect:
- Name and contact details.
- Other business information, such as job title and the company you work for.
- Areas or topics that interest you. i.e. previous engagement or work done.
- Additional information may be collected, such as events you attend and if you provide it to us, dietary preferences which may indicate data about your health or religious beliefs.
- Purpose and legal bases for our use of your personal information
Our processing of personal information is based on a “legal basis”, that is, a specific condition. We may use personal information for the following purposes, in each case as justified by a legal basis:
Fulfilment of services
We use personal information to enable us to perform the Services, respond to your requests and deliver our Services, to provide legal advice and related Services for which you have engaged us, verify your identity, and carry out requests made by you in relation to our Services.
What is our legal basis?
This processing is necessary for our compliance with legal obligations (including our professional and ethical duties as lawyers). It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others and comply with our professional and ethical duties as lawyers, consistent with applicable law. In some cases, this processing is necessary to perform a contract to which you are a party.
We use personal information to provide the Services, to communicate with you about your use of the Services, to respond to your inquiries, to provide troubleshooting, to fulfil your requests, to bill you for our Services, to collect payments, to respond to complaints and inquiries, to provide technical support, and to provide other client service and support.
What is our legal basis?
This processing is necessary to establish, exercise or defend our legal claims and rights. It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others and comply with our professional and ethical duties as lawyers, consistent with applicable law. In some cases, this processing is necessary to perform a contract to which you are a party.
Business administration and legal compliance
We use personal information for the following business administration and legal compliance purposes:
- To perform and maintain information for the purposes of performing conflicts of interest searches.
- To comply with our legal obligations (including Know Your Client, Anti-Money Laundering, Anti-Bribery, conflicts or similar obligations including, but without limitation, maintaining regulatory insurance).
- To enforce our legal rights. To investigate and/or settle inquiries or disputes.
- To comply with any applicable law, court order, other judicial process, law enforcement requests or the requirements of a regulator.
- To enforce our agreements with you.
- To protect the rights, property or safety of us or third parties, including our other clients and users of our Services.
- To maintain our records.
- To process business transaction data, such as in connection with a merger, or a restructuring, or sale.
- To use as otherwise required or permitted by law, consistent with these purposes.
What is our legal basis?
It is necessary to enforce, establish or defend our legal rights, or to protect the rights of third parties. This processing is necessary to comply with EU legal obligations imposed upon us. It is in our legitimate interest or a third party’s legitimate interest to use your personal information to comply with other legal obligations. In some cases, this processing will be necessary to perform a contract to which you are a party.
Marketing and promotions
We may use personal information for marketing and promotional purposes, such as to send you news, newsletters and legal alerts, to otherwise contact you about products, information and other value-added services which we think may interest you, by email and direct (postal) mail. We may also use it develop new Services and determine how to market our Services.
What is our legal basis?
It is in our legitimate interest to use your personal information for marketing purposes in order to develop and grow our business and Services and promote the reputation of our firm. We will, where required by applicable law, obtain your consent to send such communications.
We may use personal information in order to respond to Requests for Proposals (“RFPs”), prepare for and present pitches and other proposals, and identify potential business opportunities. Largely, this involves our collection and use of non-personal business information about current, former and prospective corporate clients. However, we may also process limited personal information about individuals (name, current and former company, current and former title, contact information and similar information).
What is our legal basis?
This processing is also in our legitimate interest to use your personal information in order to develop and grow our business and Services and promote the reputation of our firm. We also may process this information to respond to an RFP or a specific request in anticipation of a contract with you (i.e., engagement for Services).
Client insight and analytics
We may use personal information to better understand how you and others use our Services, so that we can improve our Services, develop new features, tools, offerings, services and the like, and for other research and analytical purposes. We may use this information and the insights we have derived for marketing purposes (see the marketing section above for further details), or to make decisions about events, news and information that may be of interest to clients and prospective clients.
What is our legal basis?
It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best Services to our clients and others in order to develop and grow our business and Services and promote the reputation of our firm.
Industry benchmarking and rankings
We participate in industry surveys and reports (such as Chambers and Partners and Legal 500), which clients use to assess law firms and the legal industry. Largely, this involves our collection and use of non-personal business information about clients and matters. However, we may also review and share limited personal information about individuals (such as referee name, title and contact).
What is our legal basis?
It is in our legitimate interest to use your personal information in order to develop and grow our business and Services and promote the reputation of our firm. Where required, we will obtain your consent.
Prevent misconduct, abuse and misuse
Subject to our professional and ethical duties, we may use personal information where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our terms of engagement.
What is our legal basis?
This processing is necessary to comply with EU legal obligations imposed upon us. It is necessary to enforce, establish or defend our legal rights, or to protect the rights of third parties. It is in our legitimate interest or a third party’s legitimate interest to use your personal information to comply with other legal obligations. In some cases, this processing will be necessary to perform a contract to which you are a party.
- Sharing your personal information
We may appoint sub-contractor data processors as required to deliver the Services, such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, and document and information storage providers, who will process personal information on our behalf and at our direction.
Further, we may appoint external data controllers where necessary to deliver the Services such as accountants, attorneys, consultants and other third-party experts including, but without limitation, ALFA International member firms as well as other law firms. When doing so, we will comply with our legal and regulatory obligations in relation to the personal information including, but without limitation, putting appropriate safeguards in place.
We may also share personal information with a variety of the following categories of third parties as necessary:
- Our professional advisers, such as lawyers and accountants.
- Government and/or regulatory authorities.
- Professional indemnity insurers.
- Regulators, tax authorities and/or corporate registries.
- Third parties to whom we outsource certain services, such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, and document and information storage providers.
- Third parties engaged in connection with our Services, such as counsel, arbitrators, mediators, clerks, witnesses, court reporters, court, opposing party and their lawyers, document review platforms and experts, such as tax advisors.
- Third party service providers to assist us with client insight analytics, such as Google Analytics.
- Third party postal or courier providers who assist us in delivering our postal marketing campaigns to you, or delivering documents related to a matter.
- Where we transfer your personal information to
Rollette & Co is located in the United Republic of Tanzania (“Tanzania”) and therefore governed by the laws enacted in Tanzania: when you submit personal information to us, or when others provide personal information to us, we will receive it and process it in Tanzania and in accordance to the laws in Tanzania (and EU law, where applicable). In order to provide the Services, we also may need to transfer your personal information to locations in other jurisdictions. We will inform you in advance should this be the case.
- Retention of personal information
Rollette & Co will maintain retention policies and procedures to ensure personal information is deleted after a reasonable time for the purposes for which it was being held, unless a law requires that information to be kept for a minimum time. We will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in accordance with all the Firm’s applicable records retention schedules and policies.
We will contact you no later than one month before the scheduled destruction of any information that was originally collected for a legitimate business purpose, including for the purpose of satisfying any legal, accounting or reporting requirements. We will not destroy such files in the event you request the files to be delivered to you at your cost.
- Confidentiality and security of your personal information
We are committed to keeping personal information secure and we have implemented appropriate technical measures to protect the personal information that we have under our control from unauthorized access. Please note that no transmission over the Internet is completely secure or error-free, and that the information security policies, rules and technical measures utilized and maintained by us may be subject to compromise.
All of our partners, employees, consultants, workers and data processors (i.e., those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information.
- How to access your information and your other rights
Subject to the laws in operation in the United Republic of Tanzania and relevant EU law, where applicable, you shall have the following rights in relation to the personal information we hold about you:
Your right of access
Upon your request, we will confirm whether we are processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
Your right to correction (rectification)
If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it corrected. If you are entitled to have information corrected and if we have shared your personal information with others, we will let them know about the rectification where possible. Upon your request and where practicable as per the laws in the united Republic in Tanzania, we will also tell you, where possible and lawful to do so, with whom we have shared your personal information so that you can contact them directly.
Your right to erasure
You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we have shared your personal information with others, we will let them know about the erasure where possible and practicable in accordance with the laws of Tanzania. Upon your request, we will also tell you, where it is possible and lawful for us to do so, with whom we have shared your personal information with so that you can contact them directly.
Your right to restrict (block) processing
You may ask us to restrict the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we have shared your personal information with others, we will let them know about the restriction where it is possible and practicable in accordance with the laws of Tanzania. Upon your request, we will also tell you, where it is possible and lawful for us to do so, with whom we have shared your personal information so that you can contact them directly.
Your right to data portability
You have the right, in certain circumstances, to receive a copy of personal information we’ve obtained from you in a structured, commonly used and machine-readable format, and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your rights in relation to automated decision-making and profiling
Where applicable and practicable you have the right not to be subjected to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of a contract between you and us or in compliance of the law by us.
Your right to withdraw consent
Should we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the relevant regulatory authority, in accordance with the laws of Tanzania.
Please note that some of these rights may be limited where we have an overriding legitimate interest or legal obligation to continue to process the personal information, or where the personal information may be exempt from disclosure due to applicable law, the applicable rules of professional conduct, attorney-client privilege, legal professional privilege, other applicable privileges or protections, or professional secrecy obligations.