Privacy Notice

1.Scope of this notice

This notice applies to personal data relating to visitors to this website, prospective and existing clients and their personnel, recipients of our insights and publications, suppliers and other contacts. Where we act for a client, the processing of personal data in connection with that engagement is also governed by our terms of engagement.

This website may contain links to third-party websites. We are not responsible for the privacy practices of those websites.

2.Personal data we collect

We may collect the following categories of personal data:

• identity and contact details, such as your name, job title, organisation, email address and telephone number;
• the content of enquiries and correspondence you send to us;
• information needed to carry out conflict, anti-money laundering, sanctions and other client due diligence checks;
• information relating to the matters on which we advise, which may be provided by our clients or third parties;
• marketing preferences and publication subscriptions; and
• technical information about your use of the website, such as IP address, browser type and pages visited.

We do not intentionally collect special categories of personal data through this website. Please do not send us such information unless we have asked for it.

3.How we use personal data

We use personal data to:

• respond to enquiries and assess whether we are able to act;
• provide legal and regulatory advisory services and manage our client relationships;
• carry out conflict checks and comply with our legal, regulatory and professional obligations, including anti-money laundering requirements;
• send insights, publications and event information where you have asked to receive them or where otherwise permitted;
• operate, secure and improve this website; and
• establish, exercise or defend legal claims.

4.Legal basis for processing

We process personal data on the basis of your consent; where processing is necessary to perform a contract with you or take steps at your request before entering into one; where it is necessary to comply with a legal obligation; or where it is necessary for our legitimate interests in operating our practice, provided those interests are not overridden by your rights. We process personal data in accordance with the Data Protection Act, 2012 (Act 843) and other applicable law.

5.Sharing personal data

We do not sell personal data. We may share personal data with:

• professional advisers, counsel, experts and other parties involved in a client matter, where necessary;
• service providers who support our operations, such as IT, hosting and communications providers, under appropriate confidentiality and security obligations;
• regulators, courts, law enforcement and other public authorities where required by law; and
• a successor organisation in the event of a reorganisation or transfer of our practice.

6.International transfers

Some of our service providers may process personal data outside Ghana. Where this happens, we take appropriate steps to ensure that the personal data receives an adequate level of protection, consistent with applicable law.

7.Retention

We keep personal data only for as long as necessary for the purposes for which it was collected, including to meet legal, regulatory, accounting and professional requirements. Client file retention periods are set out in our terms of engagement.

8.Security

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or alteration. No transmission over the internet is completely secure, and we encourage you not to send confidential information to us by email until we have confirmed that we are able to act.

9.Your rights

Subject to applicable law, you may have the right to request access to the personal data we hold about you, to ask us to correct or delete it, to object to or restrict certain processing, to withdraw consent at any time, and to unsubscribe from our communications. You may also complain to the Data Protection Commission of Ghana. To exercise your rights, please contact us at info@avermontconsultants.com.

10.Cookies

This website uses only those cookies and similar technologies that are necessary for it to function. If we introduce analytics or other non-essential cookies, we will update this notice and, where required, ask for your consent.

11.Changes to this notice

We may update this notice from time to time. The current version will always be available on this page, with the date of the latest revision shown above.

12.Contact us

Questions about this notice or our use of personal data should be addressed to Avermont Consultants Ltd, Accra, Ghana, at info@avermontconsultants.com.