Know Your Client (KYC) Privacy Notice

This Privacy Notice (the “Notice”) describes how Simmons & Simmons collected, uses and shared the information you provide to us in response to our client due diligence request. We require the requested information in order to comply with our legal obligations under anti-money laundering (AML) and anti-terrorist financing legislation and our legitimate interests (often referred to as KYC). Failure to provide it is likely to mean that we will be unable to provide you (or a company with which you are associated) with legal services. In this Notice when we refer to Simmons & Simmons or “we”/“us”/“our” we mean Simmons & Simmons LLP and our international offices and also other companies and entities that are associated with us.

Our use and treatment of your personal information is governed by the applicable data protection legislation.

Any personal data that you provide to us as part of our client due diligence checks will be used only for the purposes of identity verification, preventing money laundering and terrorist financing and our legitimate interests relating to those activities. We will process personal data that you give us in relation to the context above.

We shall retain a copy of each of the documents and information you provide to us in response to our client due diligence request, and which contain your personal data, together with sufficient supporting records of the transaction to enable it to be reconstructed, for the period necessary to meet our legal and regulatory requirements or fulfil our legitimate interests. At the cessation of our regulatory obligations or legitimate interests we will delete from our KYC/AML systems any personal data we have received from you for the purposes of identity verification and preventing money laundering and terrorist financing unless you consent to us retaining such data, or we need to retain any records containing your personal data i) in order to comply with, or as permitted by, applicable law or regulation; ii) for the purposes of court proceedings, or iii) because we have reasonable grounds for believing the records need to be retained for legal proceedings.

In connection with the purposes described above, we may share your information with our offices and with any other legal or professional advisors in other countries. We will take steps to ensure that your data is only accessed by those employees and legal or professional advisers who have a need to do so for the above purposes.

In the event that you become our client and we provide you with legal services, please note that any personal information we receive from you in that context may be used and retained by us as described in our firmwide Privacy Notice, which you can find at: http://www.simmonssimmons.com/en/legal-and-regulatory-information/data-privacy. Our Privacy Policy provides more information about how we process your personal information, including your rights relating to your personal data.

If you have any concerns or questions regarding the use of your personal data, you may contact us at: dataprotectionofficer@simmons-simmons.com