Privacy Policy

1. General Provisions

1.11.1 This Data Processing Policy (hereinafter referred to as the "Policy") applies to personal data that UPPERCASE LEGAL ADVISORY FZ-LLC (hereinafter referred to as "UPPERCASE"), the owner of the website with the domain name upperlegal.com/en (hereinafter referred to as the "Website"), may obtain about individuals who have access to the Website through the Internet and use the Website, as well as clients receiving services from UPPERCASE (hereinafter referred to as the "User").

1.2 This Policy, adopted by UPPERCASE, defines the purposes, procedures, and conditions for processing personal data, measures to ensure the security and protection of personal data, and establishes UPPERCASE's obligations regarding the non-disclosure of personal data processed by UPPERCASE in accordance with applicable legislation.

1.3 Personal data means any information related to a living individual who can be directly or indirectly identified by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to his biological, physical, biometric, physiological, mental, genetic, economic, cultural, or social identity.

2. Principles and Conditions of Personal Data Processing

2.1 The processing of personal data is based on the principles of protecting the rights and confidentiality of information provided by Users.

3. Purposes of Personal Data Processing

3.1 The processing of Users' personal data is carried out for the purpose of providing legal services.

4. Composition of Personal Data

4.1 UPPERCASE processes and protects the personal data of Users, including those obtained during automatic registration of Internet access device data and personal data received at UPPERCASE corporate email addresses, individuals who have consented to the processing of their personal data.

UPPERCASE processes the following data (including but not limited to):

(a) General data: last name, first name, patronymic, workplace, position, phone numbers, email addresses, mailing addresses, information from social media profiles, and other contact details;
(b) Registration data: requests for UPPERCASE newsletters, registration for events organized by UPPERCASE, subscriptions, downloads, user login, and password;
(c) Data related to the provision of services, including correspondence, transaction documents, evidence, and other materials that may be used by UPPERCASE in the provision of services and consulting, payment information, and other data related to the provision of services;
(d) Data provided by job applicants and other individuals in connection with employment, including name and position, contact information, resumes, and other information related to employment at UPPERCASE.
(e) Technical information, including the type of mobile device used by the user, unique device identifier (e.g., information about the mobile network, mobile operating system, type of mobile browser used, device token, device type, time zone setting);
(f) Information about consent to the processing of personal data.

5. Consent to this Policy and Consent to the Use of Cookies and Other Technologies

5.1 The UPPERCASE website, email messages, and advertisements may use "cookies" and other technologies such as pixel tags and web beacons, including for remembering personal information during website visits. The information obtained is used for web analytics and processing errors related to the website's operation.

5.2 The use of the Website by the User without changing the default browser settings, as well as sending an email to the corporate email containing the subject's personal data to the corporate email address, signifies consent to this Policy and consent to the use of the aforementioned technologies. If the User does not agree with this Policy and/or the use of "cookies" and similar technologies when visiting the website, they should stop using the website and/or change the "cookies" settings in the browser.

5.3 UPPERCASE also uses the Google Analytics service.

6. Measures for the Protection and Confidentiality of Personal Data

6.1 UPPERCASE takes necessary organizational and technical measures to protect Users' personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as well as other unlawful actions by third parties.

6.2 UPPERCASE employees and data processors authorized by UPPERCASE who have access to personal data or are involved in their processing are required to maintain the confidentiality of such data and adhere to this Policy.

6.3 In the event of loss or disclosure of personal data, UPPERCASE informs the User about the loss or disclosure of personal data and takes all necessary measures to prevent any negative consequences.

6.4 UPPERCASE may engage subcontractors for the processing of personal data for document processing, translation, document destruction, telecommunications operators, software suppliers, technical support services, document and data storage services, who will process information on behalf of and under the instructions of UPPERCASE. In this case, UPPERCASE ensures that such subcontractors undertake appropriate obligations regarding the confidentiality of personal data.

6.5 If necessary, UPPERCASE may also appoint external personal data operators to provide UPPERCASE services, including but not limited to auditors, investment banks, law firms, and lawyers. In such cases, UPPERCASE ensures compliance with obligations regarding personal data within the framework and in accordance with this Policy.

6.6 The website may contain links to other sites, the processing of personal data on which may differ from this Policy. Before using such sites, users should familiarize themselves with their privacy policy or similar documents. UPPERCASE cannot guarantee compliance with this Policy by such sites as UPPERCASE does not control the data transmitted or collected by such third parties.

7. Cross-Border Transfer of Personal Data

7.1 UPPERCASE has the right to carry out the cross-border transfer of data for the purposes of data processing mentioned above. The use of the Website implies the User's consent to the cross-border transfer of data for the specific purposes stated in this Policy.

8. Rights and Obligations of Users

8.1 The User has the right to access personal data processed by UPPERCASE in accordance with this Policy. The User, in particular, has the right to:
(a) know what personal data about them is subject to processing;
(b) withdraw consent for the processing of personal data at any time and for any reason;
(c) take actions to correct, restrict, delete, or destroy inaccurate data;
(d) object to the processing of personal data;
(e) demand clarification of their personal data, its blocking, or destruction if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purposes;
(f) exercise other rights in accordance with applicable legislation.

8.2 The User has the right to contact UPPERCASE at the email address [email protected] to exercise the above rights, file a complaint if the User is dissatisfied with how UPPERCASE processes their personal data, or obtain additional information regarding the Policy.

8.3 UPPERCASE fulfills requests in accordance with applicable legislation.

9. Storage of Personal Data

The personal data of Users is stored for a period necessary for the purposes of collecting personal data.