Privacy Policy

Personal Data Protection Policy

Of PGK-LEXWELL S.L.P, JMNA LAWYERS, S.L.P and JMN SAS, all members of the AARPI LEXWELL (hereinafter the “Lexwell firms”)

This Personal Data Protection Policy governs the processing carried out by the Lexwell firms, acting as Data Controllers, on the personal data of their clients, prospects, and visitors to the website www.lexwell-legal.com (the “Website”).

Who is the Data Controller of your personal data?

The Data Controller of your personal data is the Lexwell firm with which you are in contact for the purposes described below. When you submit a contact request via the Website, the Data Controller is the entity competent to respond to your request (it should be noted that this may not necessarily be the entity located in your country). Your data will not be shared with other Lexwell firms unless their involvement is necessary to achieve the relevant purposes.

PGK-LEXWELL S.L.P. Address: Diagonal 580 2-2, 08021 Barcelona NIF: B-67114819 Email: contact@lexwell-legal.com Phone: +33 1 76 40 02 91 / +34 931 311 415

JMNA LAWYERS (Spain) Address: Diagonal 580 2-2, 08021 Barcelona NIF: B-67114819 Email: jm.nogueroles@lexwell-legal.com Phone: +34 931 311 415

JMN SAS (France) Registered office: 12 Marechal Foch · 06000 · Nice Principal establishment: 7 rue Masséna · 06110 · Le Cannet Phone: +34 931 311 415 / +33 4 92 00 50 60

What personal data do we process?

Depending on the purposes pursued, we may process the following categories of personal data:

• Data relating to your identity and professional life that you provide directly to us: for example, when you fill in a form on our Website, including but not limited to your name, email address, telephone number, country and company (and/or the sector in which you operate); CV and information relating to your education and professional experience (when applying for a position).
• Our correspondence: if you contact us via the Website or by email, we generally retain a copy of such correspondence.
• Use of the Website and communications: details of your visits to the Website and data collected through cookies and other tracking technologies, including but not limited to your IP address and domain name, browser version and operating system, browser language, access time, traffic data, web logs, and navigation flows on the Website. We may also collect data relating to the pages you view and other actions you perform during your visit. In addition, we may use these tools to determine whether you have opened an email or clicked on a link contained in an email.
• Economic and financial information (financial situation; banking details) if you are a client of a Lexwell firm.
• Sensitive data (for example, where necessary for the handling of your case: religious, political or sexual preferences, trade union membership, data relating to criminal convictions or offences, etc.).

In certain cases, the provision of your personal data is mandatory in order to enable us to provide our services, establish a relationship with you, or comply with our legal obligations.

Personal data relating to third parties

Where, in the context of a matter, you provide us with personal data relating to third parties, you warrant that you have a legal basis for sharing such data, thereby releasing the Lexwell firm from any liability in the event of a claim by the third party relating to the processing of their personal data.

What are the purposes of processing your personal data?

The Lexwell firms process the personal data you provide, manually and/or automatically, as well as all information collected via the Website, for the following main purposes:

• Collection and management of requests made via the Website (contact section, telephone or email) (legal basis: pre-contractual measures; our legitimate interest in managing relationships with prospects and developing our business).
• Production, management and monitoring of client matters, i.e. provision of legal services and related administration (legal basis: performance of pre-contractual measures or the engagement letter binding you to the relevant Lexwell firm).
• Debt recovery (legal basis: performance of the engagement letter binding you to the Lexwell firm).
• Recruitment management (legal bases: pre-contractual measures; our legitimate interest in assessing applications and building a candidate pool).
• Invitations to Lexwell firm events and sending communications regarding the firm’s activities and services (legal basis: our legitimate interest in managing relationships with prospects and developing our business; your consent if you are not a professional).
• Compliance with any legal and contractual obligation, including accounting management and the prevention of money laundering and terrorist financing (legal basis: legal obligations).

Cookies and other tracking technologies

A cookie is a small text file, often encrypted, stored in your browser. When visiting a website, the site sends information to the browser, which then creates a text file on the receiving device (computer, phone, tablet, or any other device), containing information about the visit. Cookies are necessary to facilitate navigation.

The Website uses certain technical cookies to carry out activities strictly necessary for the operation or provision of the Website’s features and our services. These cookies do not store information that can personally identify you and therefore do not require consent.

The Website may also use cookies to provide certain features or personalised marketing content and improve your experience, or to enable the Lexwell firm to carry out analyses and statistics on user behaviour. These audience measurement or advertising cookies require consent.

You may accept or refuse cookies that are not necessary for the operation of the Website:

• via the cookie banner: upon your first visit, a banner asks you to accept or refuse cookies;
• via the cookie management tool available on the Website: where the use of cookies is based on consent, you may give or withdraw your consent by setting your preferences purpose by purpose.

Your choices will be stored for a reasonable period and may be modified at any time via the cookie management tool. These settings apply only to pages created and owned by the Lexwell firm. When you access external websites via links, you leave the Website and the settings made no longer apply.

You may also delete previously stored cookies via your browser or device settings. Other tracking technologies stored locally may be deleted by clearing your browsing history.

With regard to third-party cookies, preferences may be managed and consent withdrawn via the relevant opt-out link (where available), the third party’s privacy policy, or by contacting the third party directly.

Any configuration you apply may affect your browsing experience and access to certain Website features.

How long are your personal data retained?

The Lexwell firms retain personal data for the period required by law or, where no legal period is specified, for the time reasonably necessary to achieve the purposes of processing and any related authorised purpose.

Where data are processed for multiple purposes, they will be retained until the longest applicable retention period expires, but will no longer be used for purposes whose retention period has expired.

For example:

• client relationship management data are retained for the duration of the relationship plus 2 years;
• data relating to anti-money laundering and counter-terrorist financing are retained for 5 years after the end of the relationship;
• accounting data are retained for 10 years from the end of the financial year.

When personal data are no longer necessary and their retention is no longer required by law, they are securely deleted.

Who are the recipients of your data?

We may share your data with third parties:

• Our processors: service providers such as accounting, IT, platform providers, hosting services, maintenance and technical support, as well as software and applications that may process personal data. We contractually require these processors to implement appropriate safeguards.
• Other independent Data Controllers: such as tax authorities, social security authorities, customs authorities, regulatory bodies and professional organisations, courts, law enforcement authorities, auditors, insurers and other professional advisers. The Lexwell firms will disclose only the data strictly necessary in each case.

What are your rights?

In certain circumstances, you may exercise the following rights:

• Access: obtain confirmation and access to your personal data;
• Rectification: request correction or completion of inaccurate or incomplete data;
• Erasure: request deletion of your personal data;
• Restriction: request limitation of processing;
• Portability: receive your data in a structured, commonly used electronic format;
• Objection: object to the processing of your data.

It is your responsibility to ensure that the conditions for exercising these rights are met. The Lexwell firms reserve the right to refuse a request where legal requirements are not satisfied.

Requests must be submitted with proof of identity, clearly indicating the right you wish to exercise, via:

• Email: contact@lexwell-legal.com
• Address: Diagonal 580, 2-2, 08021 Barcelona (Spain)

You may also lodge a complaint with the competent data protection authority.

If you have any questions or comments regarding this Policy or how the Lexwell firms use your data, please contact us at: contact@lexwell-legal.com.