Date last revised: 18 February 2025

Thornhill Legal (we/us/our), are committed to respecting your privacy and protecting your personal data. We recognise that your personal data is your property and that you have loaned it to us for specific purposes.

Unless otherwise required by law, the Information Commissioner’s Office (ICO) guidance or best practice, or in order to perform our contract with you, we will only process your personal data in the way we tell you or in the way you ask us to, and we will give it back to you at any time.

This Policy

This policy explains how we collect, use, share and otherwise process your Personal Data in connection with your relationship with us as a client, acting for a client, applying for a position with us, or being generally interested in our services and our publications in accordance with the Data Protection Act 2018, the UK General Data Protection Regulations (2021) (UK GDPR) and other applicable data privacy laws (Data Protection Laws).

By providing your personal data to us, and/or by visiting www.thornhill-legal.com (our Website), you understand, accept and consent to the practices described in this policy.

Any changes we make to this policy will be posted on this page. You are advised to check back frequently as, unless your consent is required, any changes will be binding on you when you continue to use the Website or work with us after the date of the relevant change.

For more information relating to your rights under this policy, please see Your Rights section.

If you have any queries relating to this policy, please contact us at Yuhua.yang@thornhill-legal.com in the first instance.

Who We Are

For the purposes of the Data Protection Laws, the data controller is Thornhill Legal Ltd. We are a limited liability company registered in England (15592779) and our registered office is at 1/F, 3 More London Riverside, London, United Kingdom. We are registered with the ICO to process your personal data and our registration number is ZB821118.

Your personal data will be held and stored by us in our internal management information systems. All personal data is stored on Cloud-based servers located in the UK.

What Personal Information Do We Collect About You?

We may collect personal information from you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage our legal or other services, where you provide services to us or as a result of your relationship with one or more of our staff and clients.

The personal information that we process includes:

• basic information, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person;
• contact information, such as your postal address, email address and phone number(s);
• financial information, such as payment-related information;
• technical information, such as information from your visits to our website or applications or in relation to materials and communications we send to you electronically;
• information you provide to us for the purposes of attending meetings and events, including access and dietary requirements;
• identification and background information provided by you or collected as part of our business acceptance processes;
• personal information provided to us by or on behalf of our clients or generated by us in the course or providing services to them, which may include special categories of data; and
• any other information relating to you which you may provide to us.

Where you are a potential employee, worker or other member of our staff, we may collect additional categories of your personal data from you for the purposes of our recruitment process.

How Do We Collect Your Personal Data?

The categories of data listed in section 3 are collected in the following ways:

• we collect information from you as part of our business acceptance processes and about you and others as necessary in the course of providing legal services;
• we gather information about you when you provide it to us, or interact with us directly, for instance engaging with our staff or registering on one of our digital platforms or applications;
• we may collect or receive information about you from other sources, such as keeping the contact details we already hold for you accurate and up to date using publicly available sources; and
• any personal data you give to us in meetings may also be retained by us.

When you use our Website, we will automatically collect technical information about the device you use to visit, including your IP address, browser type/version and related settings.

We also monitor email communications sent to and from us, your use of our Website. This includes the full URLs, your clickstreams through our Website, the pages you view and how you interact with them and how you leave the Website.

Where we provide services to you, we will take administrative personal data (personal contact details of your personnel or representatives) to enable us to administer our relationship with you.

What We Use It For

Your personal data is primarily to enable us to administer our relationship with you, and/or to supply you with the appropriate legal services and advice that you have instructed us to provide. We also may use your personal information:

• To provide and improve this website, including auditing and monitoring its use;
• To provide and improve our services to you and to our clients, including handling the personal information of others on behalf of our clients;
• To provide information requested by you;
• To promote our services, including sending legal updates, publications and details of events. We only do this where you have given us permission to do so, and you can opt-out at any time. Where you opt out, we will no longer contact you until you ask us to, and we will not prompt you to do so;
• To manage and administer our relationship with you and our clients;
• To fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims; and
• For the purposes of recruitment.

Technical information we collect about your visit to our Website is used to enable us to:

• personalise and improve its functionality and security (to keep it safe and secure);
• administer and monitor traffic and behaviours on our Website for analysis, testing, research, statistical and survey purposes; and
• ensure that we can offer you the most effective and efficient browsing experience, and make improvements where necessary.

Where we change our services, or any applicable terms and conditions, we will contact you.

Meetings, events and seminars:

We will collect and process personal information about you in relation to your attendance at our offices or at an event or seminar organised by us or our business partners. We will only process and use special categories of personal information about your dietary or access requirements in order to cater for your needs and to meet any other legal or regulatory obligations we may have. We may share your information with IT and other service providers or business partners involved in organising or hosting the relevant event.

Legal Services

We collect, create, hold and use personal information in the course of and in connection with the services we provide to our clients.  We will process identification and background information as part of our business acceptance, finance, administration and marketing processes, including anti-money laundering, conflict, reputational and financial checks.  We will also process personal information provided to us by or on behalf of our clients for the purposes of the work we do for them.  The information may be disclosed to third parties to the extent reasonably necessary in connection with that work.  Please also see ‘Who we share your personal information with’.

We use your personal information on the following bases:

• To perform a contract, such as engaging with an individual to provide legal or other services;
• For the establishment, exercise or defence of legal claims or proceedings;
• To comply with legal and regulatory obligations;
• To keep you updated on legal developments; and
• For legitimate business purposes.

Retention of your personal information

Your personal information will be retained in accordance with our data retention policy which categorises all of the information held by us and specifies the appropriate retention period for each category of data.

To determine the appropriate retention period for your personal data, we will consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will also take into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and our business purposes.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.

Your Consent

We do not ordinarily rely on your consent to process your personal data. All personal data we take is either to enable us to perform our contract or proposed arrangements with you, to advise you on the matters on which we are instructed, and/or to comply with our legal and regulatory obligations whether under applicable Money Laundering Regulations or otherwise. We therefore consider that all personal data we obtain is reasonable and necessary for these purposes.

By using our Website and/or working with us, you expressly consent to the transfers of your personal data to those specifically listed third parties in this policy, for the reasons specified.

You may exercise your rights under section 10 at any time, which includes withdrawing your consent to our processing of your personal data. However, where this withdrawal prevents us from performing our contract or providing services to you, we may not be able to provide our services to you.

Security

We use a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable Data Protection Laws.

Each member of staff has unique log-in details and authentication software requires these to access the systems. Staff have access to personal data only for the purposes of performing their roles and providing the necessary advice.

Who Can We Share Your Personal Information With?

We may share your personal information with certain trusted third parties in accordance with contractual arrangements in place with them, including:

• our professional advisers and auditors;
• suppliers to whom we outsource certain support services such as word processing, translation, photocopying and document review;
• IT service providers to us;
• third parties engaged in the course of the services we provide to clients and with their prior consent, such as barristers, local counsel and technology service providers like data room and case management services;
• third parties involved in hosting or organising events or seminars;
• third party search facilities for anti-money laundering checks and know-your-client checks. You should review their privacy policies for more information on how they deal with your personal information.

Where necessary, or for the reasons set out in this policy, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies.  While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.

If in the future we re-organise or transfer all or part of our business, we may need to transfer your information to our new entities or to third parties through which the business will be carried out.

We may use social media sites such as Facebook, LinkedIn and Twitter.  If you use these services, you should review their privacy policy for more information on how they deal with your personal information.

We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.

In order to provide our services we may need to transfer your personal information to locations outside the jurisdiction in which you provide it or where you are viewing this website for the purposes set out in this privacy policy.  This may entail a transfer of your information from a location within the European Economic Area (the EEA) to outside the EEA, or from outside the EEA to a location within the EEA.

The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws.  Where our third party service providers process personal data outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures.

Your Rights

In relation to all of your personal data, you have the following rights (in addition to any rights you may have under Data Protection Laws) to ask us:

• not to process your personal data for marketing purposes;
• to clarify what data we hold about you, how it was obtained, to whom it has been disclosed and for how long it will be stored;
• to amend any inaccurate data we hold about you;
• to delete any of your data (where you no longer think we need to hold it, or you think we have obtained or processed it without your consent at any time); and
• to only process your personal data in limited circumstances, for limited purposes.

We must ensure your personal information is accurate and up to date. Therefore please advise us of any change to your information by emailing us.

We have the capacity to extract your personal data from our databases and provide it to you in a structured, commonly-used way (typically by .csv file).

If you wish to exercise any of your rights at any time, please contact us on the details contained at the beginning of this policy in the first instance. We will require you to verify your identity to us before we provide any personal data, and reserve the right to ask you to specify the types of personal data to which your request relates.

Where you wish to exercise any of your rights, they may be subject to payment of a nominal administration fee (to cover our costs incurred in processing your request) and any clarification we may reasonably require in relation to your request. Alternatively, we may refuse to comply with the request in such circumstances where we consider (acting reasonably) that your request is excessive, unfounded or repetitive.