This Privacy Policy also applies to all our websites and online services, including the following:

• hsfkramer.com (including content under sub-domains of hsfkramer.com);
• our mobile apps; and
• any other website, mobile app or other online service created or hosted by us from time to time on which this privacy policy appears,

together, our "online services".

We may collect certain details from you through our online services, for example, if you want to subscribe to our publications, register to use an app, apply for a job or join our alumni programme. In addition, our online services make use of cookies and similar technologies, as described in more detail in our Cookie Policy at www.hsfkramer.com/cookie-policy.

Our client confidentiality obligations are not addressed by this Privacy Policy but are instead described in our terms of engagement.

General

We will collect personal information directly from you, from clients or from authorised representatives.  We may also collect personal information from third parties such as regulatory authorities, your employer, other organisations with whom you have dealings, government agencies, credit reporting agencies, recruitment agencies, information or service providers, publicly available records and the third parties described in the ‘Disclosure of your information’ section below.  We will handle any unsolicited information in accordance with law, including destroying or de-identifying such information where we are required to do so by a relevant law.

We may collect current and historical personal information including your name, contact details, identification, organisation, employment, positions held and enquiry/complaint details. We may also collect personal information about your other dealings with us and our clients, including any contact we have with you by telephone, email or online.

Online Services

When you use our online services, we may collect the following:

• Information you provide by completing forms (this includes information you give us when registering for any of our online services, subscribing to our services, submitting material or requesting further services);
• Information you provide to us if you contact us, for example to report a problem with our online services or raise a query or comment; and
• Details of visits made to our online services including, but not limited to, the volume of traffic received, logs (including, where available, the IP address and location of the device connecting to the online services and other technical information and identifiers about the device and the nature of the visit) and the resources accessed.

Careers and Recruitment
If you apply online for a job or work placement you may need to provide information about your education, employment, racial background and state of health.  Your application will constitute your express consent to our use of this information to assess your application and to allow us to carry out any monitoring activities which may be required of us under applicable law as an employer. We may also carry out screening checks (including reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks) and consider you for other positions. We may exchange your personal information with academic institutions, recruiters, screening check providers, health service providers, professional and trade associations, law enforcement agencies, referees and your current and previous employers. Without your personal information we may not be able to progress considering you for positions with us.

Alumni
If you are a former employee and wish to join our alumni programme we will collect personal information such as your contact details (including addresses and phone numbers), information about your current employment and professional qualifications, basic details of your time with us and information about your preferences and engagement with the programme.  Visit www.hsfkramer.com/alumni to access the Alumni Hub including your profile information if applicable. 

We use your information in order to provide you with, and improve, our services, for example:

• To ensure that content from our online services is presented in the most effective and secure manner for you and for your device and settings;
• To provide you on an ongoing basis with information and services, including legal advice, that you request from us or which we feel may interest you as permitted under applicable law, and to measure the popularity and effectiveness of services such as newsletters and seminar invitations, in order to improve what we offer to you and other recipients; 
• To maintain and develop our relationship with you;
• For research, planning, service development, security or risk management;
• To maintain and update our records;
• To carry out our obligations arising from any contracts entered into between you and us;
• To facilitate our internal business operations, including to fulfil our legal requirements and professional obligations; and
• To allow you to use or access interactive features or secure areas of our websites, when you choose to do so.

We may not be able to do these things without your personal information. For example, we may not be able to provide our services to you.

Under applicable data protection legislation we have a duty of care to ensure that your personal information is accurate and up to date.  Therefore, please advise us of any changes to your information at [email protected].

We own the database rights in the information collected via our online services. We do not trade in or rent out this information.

As an international legal practice, we may in providing our services and operating our business, allow our offices, branches, subsidiaries and associated firms and our service providers to access your information. 

In addition, we may exchange your personal information with third parties where:

• You have consented to us sharing your personal information in this way;
• We are under a legal, regulatory or professional obligation to do so (for example, in order to comply with anti-money laundering requirements) or in order to enforce or apply our Terms of Business (or other client terms) or to protect the rights and interests, property, or safety of HSF Kramer, our clients or others;
• All, or substantially all the assets of an entity within HSF Kramer are merged with or acquired by a third party, or we expand or re-organise our business, in which case your personal information may form part of the transferred or merged assets or we may need to transfer your information to new entities or third parties through which our business will be carried out;
• It is relevant in the circumstances to disclose the information to our clients, your employer or place of business, your professional advisers and parties with whom we have co-promotional arrangements (such as jointly sponsored events);
• We provide anonymous statistical information about users of our websites and related usage information to reputable third parties, including analytics and search engine providers; or
• We use a third party service provider to provide services that involve data processing, for example archival, auditing, reference checking, professional advisory (including legal, accounting, financial and business consulting), mailing house, delivery, technology, website, research, banking, payment, client contact, data processing, insurance, forensic, litigation support, marketing and security services. 

Some of the third parties with whom we share personal information may be located outside your country or the country from which the data were provided (collectively the "jurisdiction of origin"), including in the countries where HSF Kramer has offices (see “HSF Kramer office locations”). While such third parties will often be subject to privacy and confidentiality obligations, you accept that where lawful such obligations may differ from and be less stringent than the requirements of the privacy laws of the jurisdiction of origin. In those cases we are not responsible for imposing the laws of the jurisdiction of origin, and you may not be able to seek redress under those laws.

The transmission of information via the internet is not completely secure. We cannot guarantee the security of your data transmitted to our online services; any transmission is at your own risk. Once we have received your information, we will take reasonable steps to use procedures and security features to try to prevent unauthorised access, modification or disclosure.

We take reasonable steps to hold information securely in electronic or physical form.  We store information in access controlled premises or in electronic databases requiring logins and passwords. We require our third party data storage providers to comply with appropriate information security industry standards. All partners and staff and third party providers with access to confidential information are subject to confidentiality obligations.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area. It may also be processed by staff operating outside the European Economic Area who work for us or for one of our suppliers.

You can help us to keep your information secure; please remember that any user name or password in relation to our websites is personal to you and should not be made available to any other person.  You should stop using your username and password and notify us immediately if you suspect that someone else may be using them.

Our online services use cookies and other similar technologies, for example, to distinguish you from other users when you browse our websites and also to allow us to improve our online services. For more information about the cookies we use, the purposes for which we use them and details on how to block or delete cookies, please see our Cookie Policy at www.hsfkramer.com/cookie-policy. 

Our websites link through to third party websites (including, for example for the delivery of podcasts) which may also use cookies over which we have no control. We recommend that you check the relevant third party's privacy policies for information about any cookies which may be used.

The privacy laws of some jurisdictions may give you the right to access, amend or erase your personal information or, in some circumstances, to restrict or object to the processing of your personal information.

If you would like to request a copy of your data, or would like to take steps to exercise any of your rights please contact us in writing as set out below. We may refuse to provide access and may charge a fee for access if the relevant legislation allows us to do so, in which case we will provide reasons for our decision as required by law.

In the limited circumstances where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the rights to withdraw your consent for that specific processing at any time.

Information we hold about you should be up-to-date and accurate. Please advise us in writing of any changes to your information using the contact details set out below.

Technologies and information governance practices are constantly developing. We may therefore need to revise this Privacy Policy in future. You should therefore review this page regularly to ensure that you are aware of any changes to its terms.

To find out more about HSF entities, please visit www.hsfkramer.com/where-we-work.

If you have any questions about this Privacy Policy, or want to submit a written complaint to us about how we handle your personal information, please contact us at:

Herbert Smith Freehills LLP
Exchange House
Primrose Street
London
EC2A 2EG

Attention: Clare Wilson

Telephone: +44 20 7374 8000

Email: [email protected]

Or call your local HSF office.

You may also have the right to submit a complaint to the relevant supervisory authority in your jurisdiction.

If you make a privacy complaint, we will respond to let you know how your complaint will be handled. We may ask you for further details, consult with other parties and keep records regarding your complaint.

HSF offices are located in Australia, UK, Germany, Belgium, Indonesia, Spain, US, France, Italy, United Arab Emirates, Thailand, China (including Hong Kong), Singapore and Japan, although our services extend beyond these locations. For the most current list of our offices and other key regions we service, see www.herbertsmithfreehills.com/locations.

Last updated: 27 May 2025