Privacy Notice

1. Who we are and scope of this notice

This Privacy Notice is issued by DB & Partners ("the firm", "we", "us" or "our"). The firm is the controller of the personal information described in this notice.

The firm has an international practice. This notice therefore addresses several data protection regimes, and Section 12 sets out additional information for individuals in particular jurisdictions.

This notice applies to personal information relating to visitors to this website and to individuals who contact the firm, including prospective clients and individuals named in enquiries. Clients may receive further information in connection with their engagement, which applies in addition to this notice.

Questions about this notice and requests concerning your personal information may be sent to info@dbpartners.com.tr.

2. Personal information we process

Depending on how you interact with the firm, the following categories of personal information may be processed.

(a) Identity and contact information: such as your name, any professional, artist or company name you provide, your email address and any other contact details you choose to give.

(b) Enquiry information: such as the subject and content of your message, documents you provide and correspondence with the firm. An enquiry may contain information about other people, such as counterparties, business partners or co-writers.

(c) Engagement and billing information: for clients, information relating to a matter, instructions, identification records where applicable, invoices, payment details and records of fees and expenses.

(d) Professional information: such as your role, organisation and professional activities, to the extent relevant to your enquiry or matter.

(e) Application information: such as your CV, education, professional experience and any other information you include in a job or internship application.

(f) Technical information: data generated when you access the website, such as your IP address, browser and device information and the date and time of access.

Please do not send special categories of personal information (such as information concerning health, racial or ethnic origin, political opinions, religious beliefs or criminal convictions), or confidential documents, before an engagement has been agreed.

3. How personal information is obtained

Personal information is obtained directly from you, for example when you use the contact form, write to the firm, communicate through messaging or video services you choose to use, or instruct the firm. Technical information is obtained automatically when your device connects to the website.

Personal information may also be obtained from third parties in the course of an enquiry or matter, such as clients, counterparties and their advisers, other law firms, collecting societies, courts and public authorities, and from publicly available sources.

4. Purposes and legal bases

Personal information may be processed for the following purposes:

(a) responding to enquiries and communicating with you;

(b) checking for conflicts of interest;

(c) assessing and, where agreed, taking on engagements;

(d) providing legal services and managing the client relationship;

(e) invoicing and keeping financial records;

(f) complying with legal, regulatory and professional obligations;

(g) establishing, exercising or defending legal claims;

(h) assessing job and internship applications; and

(i) operating the website and protecting it against misuse.

Where the EU General Data Protection Regulation ("GDPR") or the UK GDPR applies, the legal bases are:

(a) Contract (Article 6(1)(b)): processing necessary to take steps at your request before entering into an engagement, or to perform an engagement.

(b) Legal obligation (Article 6(1)(c)): processing necessary to comply with obligations to which the firm is subject.

(c) Legitimate interests (Article 6(1)(f)): processing necessary for the legitimate interests of the firm, such as responding to enquiries, identifying conflicts of interest, managing the practice, the security of the website and legal claims, where those interests are not overridden by your interests or fundamental rights and freedoms.

(d) Consent (Article 6(1)(a)): where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing before its withdrawal.

Where special categories of personal information are processed, the applicable condition is Article 9(2)(f) GDPR (establishment, exercise or defence of legal claims) or another condition available under applicable law.

Providing personal information is voluntary. Without the information needed to respond to an enquiry or to enter into an engagement, it may not be possible to do so.

5. Recipients

We do not sell personal information. Personal information may be disclosed to the following categories of recipients, as necessary for the purposes described in this notice:

(a) service providers that support our website, communications and IT systems;

(b) providers of messaging and communication services you choose to use, under their own terms;

(c) where relevant to a matter, counterparties and their advisers, other law firms, experts, translators, collecting societies, courts, arbitral tribunals and other dispute resolution bodies;

(d) professional advisers and insurers; and

(e) public authorities, regulators and professional bodies, where required by law or necessary in connection with legal claims.

6. International transfers

Personal information may be processed in countries other than your own. Such transfers take place in accordance with the requirements of applicable data protection law.

7. Retention

Personal information is kept for as long as necessary for the purposes for which it is processed and as required by applicable law and professional rules.

8. Communications over the internet

No transmission over the internet is entirely secure, and unencrypted email and messaging services carry particular risks. Please take this into account before sending sensitive material.

9. Confidentiality and legal professional privilege

Information relating to clients and their matters may be subject to professional duties of confidentiality and to legal professional privilege or equivalent protections.

Data protection laws provide that certain rights may not apply, or may apply in a limited way, where their exercise would conflict with professional confidentiality or privilege, or would prejudice legal claims.

Sending information before an engagement has been agreed does not of itself create a duty of confidentiality or a lawyer-client relationship. Please see our Legal Notice.

10. Cookies and similar technologies

The website may use technologies such as cookies that are necessary for its operation and security. Where the law requires consent for any other technologies, it will be requested.

11. Your rights

Subject to the conditions and exceptions of the law that applies to you, you may have the right to:

(a) access your personal information;

(b) have it rectified;

(c) have it erased;

(d) restrict its processing;

(e) object to its processing;

(f) data portability;

(g) withdraw consent where processing is based on consent; and

(h) lodge a complaint with a data protection supervisory authority.

To exercise these rights, write to info@dbpartners.com.tr. Information may be requested to verify your identity. Requests are handled in accordance with, and within the periods prescribed by, applicable law.

12. Additional information for specific jurisdictions

12.1 European Economic Area, United Kingdom and Switzerland

Where the GDPR, the UK GDPR and the Data Protection Act 2018, or the Swiss Federal Act on Data Protection applies, the firm is the controller and the legal bases in Section 4 apply. You have the rights described in Section 11, including the right to object, on grounds relating to your particular situation, to processing based on legitimate interests, and the right to lodge a complaint with a supervisory authority, in particular in the country of your habitual residence, place of work or place of the alleged infringement.

12.2 Türkiye

This section constitutes the information provided under Article 10 of Law No. 6698 on the Protection of Personal Data ("KVKK"). The data controller is DB & Partners, which may be contacted at info@dbpartners.com.tr. The personal data processed, the purposes of processing, the methods of collection and the categories of recipients are described in Sections 2 to 5. Personal data may be collected by automated, partly automated or non-automated means.

Personal data is processed on the grounds set out in Article 5(2) KVKK, in particular where processing is necessary for the establishment or performance of a contract, for compliance with a legal obligation, for the establishment, exercise or protection of a right, or for the legitimate interests of the controller provided that the fundamental rights and freedoms of the data subject are not harmed, and otherwise on the basis of explicit consent. Special categories of personal data are processed under the conditions set out in Article 6 KVKK. Transfers abroad take place in accordance with Article 9 KVKK.

Under Article 11 KVKK you have the right to: learn whether your personal data is processed; request information on such processing; learn the purpose of processing and whether data is used in accordance with that purpose; know the third parties in Türkiye or abroad to which personal data is transferred; request rectification of incomplete or inaccurate data; request erasure or destruction under the conditions in Article 7 KVKK; request that third parties be notified of rectification, erasure or destruction; object to a result to your detriment arising from analysis exclusively by automated systems; and claim compensation for damage arising from unlawful processing.

Applications may be submitted to info@dbpartners.com.tr in accordance with Article 13 KVKK and the Communiqué on the Principles and Procedures for the Request to Data Controller, and are handled within the periods prescribed by applicable law. You may lodge a complaint with the Personal Data Protection Board in accordance with Article 14 KVKK.

12.3 United States

California. This section applies to residents of California to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the "CCPA"), applies to the firm.

The categories of personal information that may be collected include identifiers, personal information described in California Civil Code Section 1798.80(e), commercial information, internet or other electronic network activity information, professional information and, where you choose to provide it, sensitive personal information. The sources, purposes, categories of recipients and retention of personal information are described in Sections 3, 4, 5 and 7.

We do not sell personal information and do not share it for cross-context behavioural advertising.

Subject to the exceptions in the CCPA, you may have the right to know, delete and correct personal information, to opt out of its sale or sharing, to limit the use of sensitive personal information, and not to receive discriminatory treatment for exercising these rights. You may submit a request, or have an authorised agent submit one on your behalf, by writing to info@dbpartners.com.tr. Requests are handled in accordance with the CCPA, which may include verification of identity.

Other U.S. states. Residents of other U.S. states with comprehensive privacy laws may have similar rights under the law of their state, including, where provided, a right to appeal. To exercise these rights, write to info@dbpartners.com.tr.

12.4 Mainland China

Where the Personal Information Protection Law of the People's Republic of China ("PIPL") applies, the personal information handler is DB & Partners, which may be contacted at info@dbpartners.com.tr. The categories, purposes and methods of processing and retention are described in Sections 2, 4 and 7. Personal information is processed on the bases provided in Article 13 PIPL.

The firm is located outside mainland China, and personal information may be processed outside mainland China in accordance with the requirements of the PIPL, including separate consent where required.

Subject to Articles 44 to 50 PIPL, you may have the right to know and decide on the processing of your personal information, to restrict or refuse it, to access, copy, correct, supplement or delete it, to request its transfer where the statutory conditions are met, to request an explanation of the processing rules, and to withdraw consent. Requests may be made to info@dbpartners.com.tr.

12.5 Brazil

Where the Brazilian General Data Protection Law (Law No. 13,709/2018, "LGPD") applies, personal data is processed on the bases provided in Article 7 LGPD and, for sensitive personal data, Article 11 LGPD. You may have the rights set out in Article 18 LGPD, which may be exercised by writing to info@dbpartners.com.tr, and you may lodge a complaint with the National Data Protection Authority (ANPD).

12.6 Canada and other jurisdictions

Where the Personal Information Protection and Electronic Documents Act ("PIPEDA") or comparable provincial legislation applies, personal information is collected, used and disclosed in accordance with that legislation. You may request access to and correction of your personal information and may withdraw consent subject to legal or contractual restrictions. Personal information may be processed outside Canada, where it may be accessible to courts and authorities of other jurisdictions.

Individuals in other jurisdictions may have rights under local law in addition to those described in this notice.

13. Children

This website is not directed to children. Where a matter concerns a minor, the minor's personal information may be processed as permitted by applicable law, generally through a parent, guardian or other authorised representative.

14. Changes to this notice

This notice may be updated from time to time. The current version is published on this page.

15. Contact

Questions, requests and complaints concerning this notice or the processing of your personal information may be sent to DB & Partners at info@dbpartners.com.tr.