Website Privacy Notice

1About this Notice

Paraphoenix Solicitors respects your privacy and is committed to handling personal data responsibly, lawfully and transparently.

This Privacy Notice explains how Paraphoenix Solicitors (“Paraphoenix”, “we”, “us” or “our”) collects, uses, shares, stores and protects personal data when you visit our website, contact us, make an enquiry, interact with our Insights or other website content, apply for an opportunity with us, or otherwise engage with us through the website.

This Notice should be read together with any more specific privacy information we provide where we collect personal data for a particular purpose.

2Who We Are

Paraphoenix Solicitors is a commercial law firm headquartered in Lagos, Nigeria. For the personal data processing described in this Notice, Paraphoenix will generally act as the data controller, meaning that we determine why and how the relevant personal data is processed.

Where we process personal data on a client’s documented instructions in a particular engagement, our role may differ and the relevant engagement terms or other privacy information may apply.

3Scope

This Notice applies principally to personal data processed through or in connection with the Paraphoenix website and related digital enquiry and recruitment channels.

It does not replace the confidentiality obligations applicable to established lawyer-client relationships, our engagement terms, or any matter-specific privacy information. Our professional duties concerning client information may provide protections in addition to applicable data-protection law.

4Personal Data We May Collect

The personal data we collect depends on how you interact with us. It may include:

• Identity and contact information, such as your name, organisation, job title, business email address, telephone number, postal address and country or jurisdiction.
• New-matter and conflict information, such as the nature of an enquiry, the names of relevant parties or counterparties, the relevant Practice or Industry and a brief description of the matter.
• Correspondence and communication information contained in messages, enquiries, calls or other communications with us.
• Recruitment information, where recruitment is enabled, such as your curriculum vitae, qualifications, employment history, professional experience and information contained in a covering note or application.
• Technical and usage information generated when you use the website, which may include IP address, device or browser information, security logs, pages visited, referring pages, interaction information and cookie or similar-technology identifiers, depending on the website configuration.
• Marketing or preference information where you choose to receive publications, event information or other communications from us.
• Other information you choose to provide, subject to the warnings in our Contact page concerning confidential, privileged or highly sensitive information.

We do not ask prospective clients to provide detailed confidential, privileged or highly sensitive information through an initial website enquiry. Please provide only the information reasonably necessary for us to understand and assess your enquiry until we confirm that we are able to act.

5Sensitive Personal Data

Legal matters and recruitment processes can sometimes involve sensitive personal data. We will process such information only where it is necessary and where an appropriate legal basis and safeguards apply.

Please do not provide sensitive personal data through a general website form unless we have specifically requested it or it is genuinely necessary for the relevant purpose.

6How We Collect Personal Data

We may collect personal data:

• directly from you when you complete a form, contact us, communicate with the firm or submit an application;
• from your organisation or another person involved in a matter or business relationship;
• from publicly available sources where reasonably necessary for conflicts, due diligence, professional or business purposes;
• from clients, counterparties, advisers, regulators, courts, service providers or other third parties where relevant and lawful; and
• automatically through the website and its security, hosting, analytics or cookie technologies, depending on the final website configuration.

7Why We Use Personal Data and Our Lawful Bases

We process personal data only where we have an appropriate lawful basis. The basis will depend on the purpose and circumstances. Our principal website-related purposes may include:

Responding to enquiries and considering potential instructions. To take steps at your request before entering into an engagement, to pursue legitimate interests in managing prospective client relationships and conflicts, and where applicable to comply with legal or professional obligations.

Client and matter onboarding. To take steps before or perform an engagement and to comply with legal, regulatory and professional obligations, including conflicts, client-identification, KYC/AML and related risk controls.

Providing legal services and managing client relationships. Performance of our engagement, compliance with legal and professional obligations, and legitimate interests in delivering and administering professional services.

Operating, securing and improving the website. Legitimate interests in providing a secure, reliable and effective website, subject to applicable rights and any consent required for non-essential cookies or technologies.

Recruitment. Taking steps at a candidate’s request in connection with potential employment or engagement, legitimate interests in recruitment and workforce planning, compliance with legal obligations, and consent where specifically appropriate.

Insights, events and communications. Legitimate interests in professional and business communications where appropriate, or consent where required. You may object to or unsubscribe from direct marketing communications.

Legal, regulatory and risk management. Compliance with legal and professional obligations and legitimate interests in establishing, exercising or defending legal claims, protecting the firm and others, preventing fraud or misuse and maintaining appropriate records.

Consent-based processing. Where we specifically rely on consent, we will seek an affirmative choice and you may withdraw consent at any time, without affecting processing already carried out lawfully.

Where we rely on legitimate interests, we consider whether those interests are compatible with your reasonable expectations and whether your rights, freedoms or interests require a different approach.

8If You Do Not Provide Information

Some information may be necessary for us to respond to an enquiry, conduct conflicts or onboarding checks, consider an application, comply with legal or professional obligations or provide requested services. If required information is not provided, we may be unable to progress the relevant request or engagement.

9Sharing Personal Data

We may share personal data where reasonably necessary with:

• lawyers, personnel and authorised contractors working with or for Paraphoenix on a need-to-know basis;
• technology, hosting, website, communications, document-management, cybersecurity, professional-services and other suppliers that support our operations;
• carefully selected independent local counsel, professional advisers or specialist providers where relevant to an international or other matter and appropriately authorised;
• banks, insurers, auditors and other professional or administrative service providers where relevant;
• courts, regulators, law-enforcement bodies, governmental authorities or other persons where disclosure is required or permitted by law or professional obligations; and
• other parties where you direct or authorise us to disclose information, or where disclosure is otherwise lawful and appropriate.

We expect service providers that process personal data for us to protect it appropriately and to process it only for authorised purposes, subject to applicable contractual and legal requirements.

Nothing in this Notice is intended to require disclosure of information where disclosure would be prohibited by applicable professional confidentiality, legal privilege or other legal obligations.

10International Transfers

Our work and the technologies used to support the website may involve processing or access in more than one country. Where personal data is transferred from Nigeria to another country, we will seek to use a transfer basis and safeguards permitted by applicable Nigerian data-protection law.

Depending on the circumstances, these may include an adequacy basis, approved contractual or other transfer safeguards, or another legally permitted condition. The appropriate mechanism will depend on the recipient, destination, purpose and nature of the transfer.

11Security

We use organisational and technical measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, access or other misuse.

Measures are selected having regard to the nature and sensitivity of the information, the risks presented by the processing and the systems involved. No internet transmission or information system can, however, be guaranteed to be completely secure.

If you believe personal data you have provided to Paraphoenix may have been compromised, please contact us promptly using the approved privacy contact once published or the firm telephone number shown in this Notice.

12Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected or further processed, and as required or permitted by applicable legal, regulatory, professional, conflicts, risk-management and records-management requirements.

Different categories of information may therefore have different retention periods. Relevant considerations include the nature of the relationship or enquiry, whether an engagement was opened, legal and professional record-keeping obligations, limitation and claims considerations, conflicts requirements, regulatory expectations, security needs and whether continued retention is otherwise lawful.

We do not use this Website Privacy Notice to impose a single universal retention period on all categories of personal data.

13Your Data-Protection Rights

Subject to applicable law and any relevant limitations or exemptions, you may have rights in relation to your personal data, including rights to:

• be informed about the processing of your personal data;
• request access to personal data we hold about you;
• request correction of inaccurate or incomplete personal data;
• request deletion of personal data where the applicable conditions are satisfied;
• object to certain processing, including processing based on legitimate interests in appropriate circumstances;
• request restriction of processing in applicable circumstances;
• request portability of personal data where the applicable conditions are satisfied;
• withdraw consent at any time where processing is based on consent, without affecting the lawfulness of earlier processing;
• object to or challenge qualifying automated decision-making; and
• lodge a complaint with the Nigeria Data Protection Commission.

These rights are not absolute in every circumstance. For example, legal, regulatory, professional, privilege, confidentiality, record-keeping or claims requirements may affect whether and how a request can be fulfilled.

To exercise a right, please use the approved privacy contact once published. We may need to verify your identity and clarify the scope of your request before acting on it.

14Complaints

If you have a concern about how we handle your personal data, we encourage you to contact Paraphoenix first so that we can consider and address the issue.

You also have the right, where applicable, to lodge a complaint with the Nigeria Data Protection Commission. Current information about the Commission and its complaint processes is available through its official channels.

15Cookies and Similar Technologies

The website uses cookies and similar technologies for functions such as security, core website operation and remembering the choices you make about optional technologies.

Strictly necessary technologies are used where required to provide or secure the website and to record your cookie preferences. These cannot be switched off.

Optional analytics technologies, which help us understand how the website is used, are set only where you have accepted them. No advertising or cross-site tracking technologies are used.

When you first visit the website, a cookie banner allows you to accept optional technologies, reject them, or manage your choices individually. Refusal is as straightforward as acceptance, and you can change your choice at any time using the Cookie Settings control in the website footer.

16Direct Marketing and Insights

If we offer subscriptions to Insights, event invitations or other professional communications, we may use contact and preference information to send communications where permitted by law.

Where consent is required, it should be obtained separately and affirmatively. Marketing consent must not be bundled with a new-matter enquiry or other service request.

You may opt out of marketing communications at any time using the unsubscribe mechanism provided or by contacting us. Service, matter, legal or administrative communications may continue where they are necessary and lawful.

17Recruitment

If Paraphoenix opens recruitment opportunities, we may process candidate information to assess applications, communicate with candidates, conduct appropriate checks, manage the recruitment process, comply with legal obligations and establish or defend legal claims.

The Careers page does not collect applications until an approved recruitment channel and associated privacy, access, security and retention controls are operational.

Any future recruitment form or applicant portal will provide additional just-in-time privacy information where the processing materially differs from this Notice.

18Children

The Paraphoenix website and legal services are directed principally to businesses, professionals and adults. We do not intentionally use the website to solicit personal data from children.

If a matter requires the processing of a child’s personal data, that processing will be handled through the relevant professional engagement and in accordance with applicable legal requirements and safeguards, rather than through a general website form.

19Automated Decision-Making

Paraphoenix does not intend at launch to use the public website to make decisions producing legal or similarly significant effects about individuals solely through automated processing.

If this changes, the relevant processing, significance, envisaged consequences and applicable rights will be explained before deployment and this Notice updated accordingly.

20Third-Party Websites

Our website may contain links to websites or services operated by third parties. Their privacy practices are governed by their own notices and controls. Paraphoenix is not responsible for the privacy practices of third-party websites merely because we provide a link to them.

21Changes to this Notice

We may update this Privacy Notice to reflect changes in law, regulatory guidance, our services, website technologies or processing activities.

The current version always displays its effective or last-updated date. Material changes will be communicated in an appropriate manner where required.

22Contact Us About Privacy

Questions, requests or concerns concerning this Notice or the way Paraphoenix handles personal data should be directed to the firm’s approved privacy contact.