This Policy describes:
1. what personal information we collect about you 2. how we obtain your personal information 3. how we use cookies 4. how and on what basis we use your personal information 5. how long we keep your personal information 6. who we share your personal information with 7. how we protect your personal information 8. which countries we transfer your personal information to 9. your rights regarding your personal information 10. who are the data controllers 11. changes to our privacy policy 12. who to contact with questions or concerns
A&O Shearman refers to Allen Overy Shearman Sterling LLP, its subsidiaries and the other partnerships, corporations, undertakings and entities which are authorized to practice using a name which includes ‘Allen Overy Shearman Sterling’ or ‘A&O Shearman’. See the section entitled ‘Who are the datacontrollers’ below for more information on the entities that control and process personal information in A&O Shearman.
In this Privacy Policy, we use the term ‘personal information’ to describe information that is about you and which identifies you. In relation to your use of this RegGateway platform ("RegGateway platform") we will collect and process the following personal information:
You are responsible for ensuring that the personal information you provide to us complies with applicable data protection laws and you will not do or omit to do anything that would cause A&O Shearman to be in breach of those laws. If we do not collect, or you do not provide, your personal information to us, we may not be able to provide our products and services to you.
We collect your personal information in various ways:
when you edit your profile, set your preferences or subscribe for alerts on the RegGateway platform
Cookies are small text files that are downloaded to your device by websites you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website. We use different types of cookies for different things, such as analyzing how you use the RegGateway platform and to show you content on the RegGateway platform in your chosen language. We have listed the cookies that we use on the RegGateway platform, what each cookie is used for and how long it is retained below. You can find more information about cookies at allaboutcookies.org. Your choices You can choose whether or not to accept cookies by clicking on the ‘Cookie Preferences’ button, which can be found both at the top and at the bottom of this page. Some cookies are essential cookies and cannot be turned off using the Cookie Preferences tool. We have listed these ‘strictly necessary’ cookies, what they are used for and how long they are retained below. You can disable strictly necessary cookies by changing your browser settings, however, this may affect how the RegGateway platform functions. Some of the cookies listed below, such as the Vimeo cookie in relation to video content, are third-party cookies that cannot be turned off using the Cookie Preferences tool. In order to remove these cookies you will need to visit the third party sites and follow the instructions in their cookie notices. Alternatively, follow the instructions under the Changing cookie settings in your browser heading below. Necessary cookies These cookies are necessary to enable core functionality, such as accessibility, and to enable us to keep track of your cookie choices.
| Cookie name | Purpose | Expiry |
| wordpress_logged_in_ wordpress_sec_ wordpress_test_cookie | These cookies are set by WordPress and are used to store a user’s authentication details when logged in to the RegGateway platform, check whether a user is logged-in to the RegGateway platform and test that a user’s browser accepts cookies. | Session |
| PHPSESSID | This cookie is set by PHP.net and identifies a user’s session on the server. | Session |
| borlabs-cookie | This cookie is set by A&O Shearman to record a user’s cookie preferences. | 1 year |
| rg_sec_[randomly generated numbers] | These cookies (5 in total) are set by WP Cerber. They are used by A&O Shearman for security purposes in relation to the RegGateway platform to detect malicious activity, distinguish between users who are logged into the RegGateway platform and those who are not, and identify search engine robots attempting to access the RegGateway platform. | 6 Weeks |
Website functionality cookies These cookies enable functionality that gives you a better, more personalized experience, such as remembering your language preferences. If you disable these cookies it may interfere with your experience on the RegGateway platform.
| Cookie name | Purpose | Expiry |
| pll_language | This cookie is set by A&O Shearman and is used to record the language in which the RegGateway platform content should be displayed to a user. If a user does not accept this cookie, their language preferences will be stored for the duration of their session only. | 1 year |
Analytics cookies These help us to improve the RegGateway platform by collecting and reporting information on how you use it.
| Cookie name | Purpose | Expiry |
Universal Analytics (Google)
|
These cookies are used to collect information about how visitors use our website. They distinguish users on the website by assigning a randomly generated number as an identifier. They collect information on the number of visitors to the site, whether they are unique or returning visitors, the pages visited, the length of time spent on the site and how the visitor reaches the website (e.g. a search engine result, social post or direct link). The user data provided to A&O Shearman is aggregated and therefore anonymous. The aggregated information is shared by A&O Shearman with Lexemo (who power the RegGateway platform) to help us to improve the RegGateway platform. | _ga*: 2 years _gid: 24 hours _gat: 1 minute |
| ai_user | This cookie is set by Microsoft and is used by A&O Shearman to count the number of users accessing the RegGateway platform over time. The cookie stores a unique identifier to recognize users on subsequent visits to the RegGateway platform. | 1 year |
Third-party cookies In order to remove these cookies you will need to visit the third-party sites and follow the instructions in their cookie notices. Alternatively, follow the instructions under the Changing cookie settings in your browser heading below.
| Cookie name | Purpose | Expiry |
| vuid | Our video content is hosted on a third-party site (Vimeo). When you play a video on the RegGateway platform, Vimeo places third-party cookies to enable the video to play and to collect analytics data such as how long a user has watched the video. For more information, please see Vimeo’s cookie policy. | 2 years |
Changing cookie settings in your browser For information on how to disable and/or clear cookies, including third-party cookies, on your device please follow the instructions in the links below:
More information on managing your cookie settings can be found at allaboutcookies.org.
We have set out below the purposes for which we use your personal information and the legal basis under the EU General Data Protection Regulation ("GDPR") that we rely on to process your information.
| Purpose | Legal Basis |
| To provide the RegGateway platform to you and others in your organization | For our legitimate business purposes (i.e., the provision of the RegGateway platform) To perform a contract with individual subscribers |
| To create and administer your account | For our legitimate business purposes (i.e., the provision of the RegGateway platform) To perform a contract with individual subscribers |
| To audit and monitor the use of the RegGateway platform, including to understand what features, materials and sections of the platform you visit | For our legitimate business purposes in providing, and improving and ensuring the security of, the RegGateway platform and related services We may request your consent in circumstances where required (for example, in relation to our use of cookies) |
| To send you information you have asked for, including legal and regulatory updates, and to respond to your communications, queries and feedback | For our legitimate business purposes (i.e., the provision of the RegGateway platform and any other services requested by you) We may request your consent in circumstances where required |
| To promote the RegGateway platform | For our legitimate business purposes (i.e., the promotion of the RegGateway platform and related services) We may request your consent in circumstances where required |
| To manage and administer our relationship with you and our clients | For our legitimate business purposes (including the provision of the RegGateway platform |
| To share information with the subscribing organization about its use and performance of the RegGateway platform The organization receiving the information is responsible for ensuring its use of the data complies with data protection law | For our legitimate business purposes and those of the subscribing organization |
| To compile and share (aggregated and anonymous) statistics about the use and performance of the RegGateway platform | For our legitimate business purposes and those of the subscribing organization and any others with whom we share the information |
| To fulfil our legal, regulatory and risk management obligations, including establishing, exercising, or defending legal claims | For our legitimate business purposes (i.e., to manage risk and actual and potential claims) and for compliance with legal obligations to which we are subject |
Your personal information will be retained in accordance with our global data retention policy which categorizes all of the information held by A&O Shearman and specifies the appropriate retention period for each category of data. Those periods are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and A&O Shearman ’s business purposes.
A&O Shearman is an international law firm and any information that you provide to us may be shared with and processed by any entity in the worldwide network of A&O Shearman and our associated firms. You can see a list of our offices by clicking here. We may share your personal information with your employer that subscribes for the services for the purposes set out above. The organization receiving the information is responsible for ensuring its use of the data complies with data protection law. We may also share your personal information with certain trusted third parties in accordance with contractual arrangements in place with them, including:
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 personal information to comply with legal or regulatory requirements. We will use reasonable endeavors to notify you before we do this, unless we are legally restricted from doing so. If in the future we re-organize or transfer all or part of our business, we may need to transfer your information to new A&O Shearman entities or to third parties through which the business of A&O Shearman will be carried out. If you separately access aoshearman.com or use our legal services, we will process your personal information as set out in the privacy policy on the website, which is available by clicking here. We do not sell or rent personal information or otherwise sheare it with a third party in return for monetary compensation, except with your prior permission.
We use a variety of technical and organizational measures to help protect your personal information from unauthorized access, use, disclosure, alteration or destruction consistent with applicable data protection laws. When we engage a third-party service provider to collect or otherwise process personal information on our behalf, the third party is selected carefully and will be required to have appropriate security measures in place.
The RegGateway platform is hosted in the European Economic Area (“EEA”). Your personal data will also be processed in the country in which you are accessing the RegGateway platform. In order to provide our services, A&O Shearman may need to transfer your personal information to locations outside the EEA or the jurisdiction in which you provide the information for the purposes set out in this privacy policy. Please see the section entitled ‘Who we shareyour personal information with’ for more detail on how your personal information may be shared with A&O Shearman offices and third-party service providers. The level of data 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. EU standard contractual clauses are in place between all A&O Shearman entities that share and process personal information. Where our third party service providers process personal information outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures, usually standard contractual clauses. Please contact us using the details at the end of this Privacy Policy if you would like to see a copy of the safeguards applied to the export of your personal information.
The GDPR and other applicable data protection laws provide certain rights for data subjects. You are entitled to request a copy of the personal information A&O Shearman holds about you and information about how we process your personal information. You may also have a right in accordance with applicable data protection law to have it rectified or deleted, to restrict our processing of that information, to stop unauthorized transfers of your personal information to a third party and, in some circumstances to have personal information relating to you transferred to another organization. You may also have the right to lodge a complaint in relation to A&O Shearman’s processing of your personal information with a local supervisory authority. If you object to the processing of your personal information we will respect that choice in accordance with our legal obligations. Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above (see section entitled ‘How and on what basis we use your personal information’) or that you may not be able to make use of the services and products offered by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations. We must ensure that your personal information is accurate and up to date. Therefore, please advise us of any changes to your information by emailing: reggateway@aoshearman.com.
Allen Overy Shearman Sterling LLP is the principal data controller. As there are a number of entities through which A&O Shearman provides legal and other services, another A&O Shearman entity may also be a controller of your personal information. For example, where certain personal information is processed using, or accessible via, global systems or depending on the location where the legal or other services are provided. Please click here for details of which A&O Shearman entity will be the data controller in each country and, where necessary having regard to local applicable data protection or privacy laws, a country-specific privacy notice.
This Privacy Policy may change from time-to-time and the updated policy will be posted on this page. The date of the last change will be indicated at the end of this document. Please check our website regularly for any updates. This Privacy Policy was last updated in May 2024.
If you have questions, complaints or need further information about our privacy policy or practices, please contact: Chief Privacy Officer A&O Shearman 68 Donegall Quay Belfast Northern Ireland BT1 3NL Email: DataPrivacy@aoshearman.com