As Bozkurt | Bozkurt Attorneys at Law and Bozkurt Bozkurt LLC (“Bozkurt | Bozkurt”, “BB”, “Firm”, “we”, “us”, and “our”), we take your privacy seriously and this privacy notice explains what Personal Data or Information (“Data”) we collect from/about you, why we need it, how we use it, and what protections are in place to keep it secure in accordance with the Law on the Protection of Personal Data numbered 6698 (“The Law”) and other applicable data protection and privacy laws.
“Bozkurt Personnel” means Bozkurt | Bozkurt’s prospective, present, and past partners, employees, consultants and agency staff, and people connected to such persons,
“Personal Data or Information” means any information that can identify, directly or indirectly, a natural person, including identifiers such as a name, an identification number, location data, an online identifier, or factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity,
“You” means individuals whose data we process including, but not limited to Bozkurt | Bozkurt clients, Bozkurt | Bozkurt client personnel, counterparties, counterparty personnel, other attorneys, counselors, advisors, witnesses, suppliers, supplier personnel, job applicants, and individuals to whom we market. “You” does not include Bozkurt | Bozkurt personnel,
Bozkurt | Bozkurt Attorneys at Law and Bozkurt Bozkurt LLC are the Data Controller in relation to your data and we committed to protecting the privacy rights of individuals, including your rights.
How do we collect your data?
In some circumstances, we may obtain your data from you directly including through this website but, more typically, we will obtain your data from a third-party source, for example, we may collect information from our clients/our clients’ personnel, agents and advisors, other law firms/advisors which represent you, the company for whom you work, other organizations/persons with whom you have dealings, government agencies, recruitment agencies, information or service providers and publicly available records.
If you provide information to us about someone else (such as one of your associates, directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that information to us and that, without our taking any further steps, we may process that information in accordance with this Notice.
What data do we collect?
We collect and use different types of data about you to operate the firm effectively and provide you with a high-quality service. Please consider the following illustrative and non-exhaustive examples:
Data about you: name, address, date of birth, national insurance number, marital status, nationality, race, gender, preferred language, financial details, job title, work-life, information relating to your legal matter, Information and documents relating to the service we are providing, including communications with you, and restrictions and/or required accommodations, possibly about your family life,
Data to contact you at work or home: name, address, telephone, and e-mail addresses,
Data which may identify you: photographs, and video, passport and/or driving license, ID card details, electronic signatures,
Data to process any payment we might need to make to you or to get from you: bank account details, billing and payment information, the Ministry of Treasury and Finance of Turkey or the IRS numbers and references (where applicable),
Data to monitor your use of our website: IP address, traffic and location information, weblogs, and other communication information.
Why do we need to collect and use your data?
We need to collect and use your data for several reasons, the primary purpose is to provide legal advice and services to our clients, and which may involve the use of your data in the following (non-exhaustive) ways:
To deliver legal services to you on your instruction,
To answer enquiries that you make prior to any formal instruction,
To contact you if you are involved in a matter we are undertaking for a client, whether in your professional or personal capacity,
To avoid any conflict of interest as we represent you,
To carry out investigations, risk assessments, and client due diligence,
To analyze the practices of your employer or other organizations and/or persons with whom you have dealings,
To review, draft and disclose correspondence and other documents, including court documents,
To instruct third parties on behalf of our clients and,
To invoice you, and to track payments you make, or payments made to you,
For comparison/analytical purposes and to formulate legal opinions and provide advice.
We may also process your data for effective business management purposes which may involve the use of your data in the following (non-exhaustive) ways:
To engage and contact suppliers,
To carry out internal reviews, investigations, audits,
To conduct business reporting and analytics,
To advertise and market our services,
To help measure performance and improve our services,
For recruitment purposes,
For regulatory and legislative compliance and related reporting, and
For the prevention and detection of crime.
What is the legal basis for processing your data?
We believe that all these purposes are justified on the basis of our legitimate interests in running and promoting the firm, our contractual requirements to deliver the agreed legal services to you. And, under the Law, Bozkurt | Bozkurt must identify a lawful basis for processing your data which may vary according to the type of data processed and the individual to whom it relates.
Performance of a contract with you (where applicable):
Bozkurt | Bozkurt is entitled to process the data it requires to fulfill its obligations under its contract with you. This will be the relevant legal basis if you are an individual client or supplier/other individuals with a direct contractual relationship with Bozkurt | Bozkurt.
Legitimate interests of Bozkurt | Bozkurt or a third-party:
Bozkurt | Bozkurt processes some of your data on the basis that it is in its legitimate interests and/or the legitimate interests of a third party to do so. This will primarily concern the processing of data that is necessary to provide legal advice and services to our clients. Bozkurt | Bozkurt’s legitimate business interest in such instances is the proper performance of its function as an authorized and regulated provider of legal services. Bozkurt | Bozkurt’s clients’ also have a legitimate interest (and more general right in law) in obtaining legal advice and services.
Bozkurt | Bozkurt’s broad interest in the provision of legal services as a basis for processing your data, and our clients’ corollary interest in the receipt of such services, can be broken down into more discreet categories which may include, but are not limited, to:
The interest in contacting individuals relevant to Bozkurt | Bozkurt’s work and our clients’ matters, which may involve the use of your data,
The interest in reviewing documents and correspondence that have been disclosed to Bozkurt | Bozkurt, Bozkurt | Bozkurt clients and third parties which may contain your data,
The interest in reviewing and analyzing all evidence available to Bozkurt | Bozkurt and its clients, which may contain your data,
The interest in adducing legal arguments, creating documents and correspondence, which may contain your data,
The interest in disclosing documents and correspondence, which may contain your data, to various parties in the furtherance of Bozkurt | Bozkurt’s clients’ objectives,
The interest in instructing third parties on behalf of Bozkurt | Bozkurt clients,
The interest in receiving payment from Bozkurt | Bozkurt clients and third parties and to facilitate payments to and from Bozkurt | Bozkurt clients and third parties, and,
To allow for all of the above, the secure management and storage of your data, within our IT environment and hard copy filing systems.
Bozkurt | Bozkurt may also process your data on the basis that it is necessary for its legitimate business interests in the effective management and running of Bozkurt | Bozkurt which may include, but is not limited to: engaging suppliers and supplier personnel; ensuring that its systems and premises are secure and running efficiently; for marketing purposes; for regulatory and legislative compliance, and related auditing and reporting; for insurance purposes; for recruitment purposes; and to facilitate, make and receive payments.
Bozkurt | Bozkurt does not consider that the processing of your data, on the basis that it is within Bozkurt | Bozkurt’s legitimate interests (whatever such interests might be), is unwarranted because of any prejudicial effect on your rights and freedoms or your legitimate interests.
Compliance with a legal obligation to which Bozkurt | Bozkurt is subject:
In certain circumstances, Bozkurt | Bozkurt must process your data to comply with its legal obligations. This might include, but is not limited to, data required: for tax and accounting purposes; for conflict checking purposes as required by the common law and Bozkurt | Bozkurt’s regulators; and for Bozkurt | Bozkurt to fulfill its compliance and other obligations under relevant legislation/regulation.
Special category and criminal records data
If Bozkurt | Bozkurt processes your criminal records data or special category data relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, health data, biometric data, or sexual orientation, we will obtain your explicit consent to those activities unless this is not required by law (because, for example, it is processed to exercise or defend legal claims) or the information is required to protect your health in an emergency. Where we are processing data based on your consent, you have the right to withdraw that consent at any time.
Marketing and Business Development
We should like to send information about our services that we believe may be of interest to you. We will keep the personal information you have provided for any marketing or business development purpose for as long as is necessary or until you have advised us that you have changed your mind, wish to opt out and want us to delete the information.
Who has access to your data?
We do not sell or rent your data or information to any third party or share your information with third parties for their marketing purposes. We may disclose your data to third parties (outside of Bozkurt | Bozkurt and Bozkurt | Bozkurt Personnel) if, but only when, we have a legal basis to do. Such recipients include but are not limited to: co-counsel, other attorneys/legal professionals/experts/foreign law firms whom we instruct on your behalf; Bozkurt | Bozkurt’s insurance brokers and underwriters; Bozkurt | Bozkurt’s bank, auditors, and accountants; Bozkurt | Bozkurt’s outsourced IT providers and other suppliers; the Ministry of Treasury and Finance of Turkey or the IRS; the other side/other parties on any given matter.
How do we protect your data?
When you give us your data, we take steps to ensure that it’s treated securely and strive to protect it on our internal systems. We have security arrangements in place to guard against unauthorized access, improper use, alteration, destruction, or accidental loss of your data. We take appropriate organizational and technical security measures and have rules and procedures in place to ensure that any data we hold is not accessed by anyone unauthorized to access it. We have in place and abide by a specific information security policy about the security standards used to protect your data.
How long do we keep your data?
It is our policy to retain your data for the length of time required for the specific purposes for which it is processed by Bozkurt | Bozkurt and which are set out in this Notice. However, we may be obliged to keep your data for a longer period, for example, where required by our legal and regulatory obligations or to ensure we have effective backup systems. In such cases, we will ensure that your data will continue to be treated in accordance with this Notice, restrict access to any archived data and ensure that all data is held securely and kept confidential.
What are your data protection rights?
The Law and other applicable data protection and privacy laws generally afford individuals a right to access their data, to object to the processing of their data, to rectify, to erase, to restrict, and to port their data.
There are exceptions to the rights of individuals about their data and, particularly when we are processing your data to provide legal advice to our clients, your rights may be limited. We will, always, respect your data and seek to be as transparent as possible but please be aware that, in some instances, we may be restricted from even acknowledging that we process your data.
If you are unhappy with the information provided in this Notice or have concerns about how Bozkurt | Bozkurt processes your data, you may in the first instance contact with us using the contact details provided below:
Bozkurt | Bozkurt Attorneys at Law
Windowist Tower, Eski Buyukdere Caddesi No: 26 34485, Maslak, Sariyer, Istanbul, Turkey
E-mail: [email protected]
Bozkurt Bozkurt LLC
Citigroup Center, 601 Lexington Avenue, 20th Floor New York, NY 10022 USA
E-mail: [email protected]