Privacy Notice

ALN is an alliance of independent law firms across Africa that collaborate to provide seamless, continent-wide client services through member firms and their affiliates. ALN itself does not provide legal or other client services.

References in this Privacy Notice (Privacy Notice or Notice) to we, us or our is understood to mean ALN, a body corporate registered in Mauritius or one of the ALN member firms and affiliates listed here. Personal data is collected and processed individually by each of the listed entities, in accordance with their respective data protection obligations. Only the specific ALN entity that you interact with and share your personal data with will assume any obligations to you as the controller or processor (as the case may be) of your personal data. None of the ALN entities is liable for other ALN entities’ acts or omissions in the course of processing data in the manner set out in this Notice.

This Notice provides information on how we collect and process your personal data. Please read it alongside any other notices we may provide when collecting or processing your personal data, to ensure you fully understand how and why we use it. This Notice supplements but does not override other notices.

As ALN has continental reach, we are subject to the varying requirements of data protection laws in the jurisdictions where each of us operates. Although our approach to data protection across ALN member firms aims to be as consistent as possible and to accord with all applicable law, the specific requirements, rights and obligations relating to personal data and/or our data processing activities can be different across the various jurisdictions. The data processing obligations and restrictions are the data and privacy  laws in force from time to time in the jurisdictions in which each of ALN and the ALN members operate (referred to in this Notice as applicable law).

5.1. We collect personal data through various methods, including:

1. Direct interactions: You provide personal data (e.g., identity, contact, financial, profile, usage, and professional data) when interacting with us, such as filling out forms virtually or physically, using our electronic portals, corresponding via email or phone, or during in-person meetings and facility visits. This includes when you inquire about services, apply for jobs, provide necessary client, vendor or employee data, or participate in events.
2. Website, electronic portals, and marketing: We collect profile, usage, technical, and marketing data when you use our website or portals or engage with our marketing materials. We also use cookies and similar technologies.
3. Third-party sources: We may receive your data (e.g., identity, contact, financial, and professional data) from third parties, such as other ALN entities or their affiliates, recruitment agencies, international law firms, other law firms outside of the ALN alliance, client services providers, or regulatory bodies, for purposes like background checks, client service provision, or recruitment.
4. Publicly available sources: We may gather data (e.g., identity, contact, financial, and professional data) from public registers, such as company directories, electoral rolls, social media or professional networks like LinkedIn.
5. Automated technologies: We collect technical and usage data through cookies, server logs, and similar technologies.

5.2. If we are required by law or under the terms of a contract with you to collect personal data, and you fail to provide it, we may not be able to fulfill the contract or provide the requested services.

7.1. We will only use your personal data for the purposes for which it was collected, unless we reasonably determine that we need to use it for another purpose that is compatible with the original one or as permitted by law.

7.2. Please note that, where required or permitted by applicable law, we may process your personal data for an unrelated purpose without your knowledge or consent.

If we receive your personal data for recruitment purposes, we will use it to contact you regarding potential roles and opportunities. Should you apply for a specific position, internship, or programme with us, your personal data will be processed in accordance with the applicable law.

11.1. We may collect, use, and share aggregated data, such as statistical or demographic information, for any purpose. Aggregated data is derived from your personal data but is not considered personal data in law as it does not directly or indirectly reveal your identity. If we combine aggregated data with personal data so that you can be identified, we will treat the combined data as personal data and protect it in accordance with this notice.

11.2. We do not collect any special categories of personal data (such as information relating to race, ethnicity, religious beliefs, health, or biometric data) through our website. We also do not collect data relating to criminal convictions and offences through our website.

11.3. Our website may include links to third-party websites, plug-ins, and applications. We are not responsible for the privacy practices of those third parties. We encourage you to read their privacy notices when you leave our website.

11.4. We use cookies to differentiate you from other users, gauge your interaction with our website, and enhance our services.

13.1. When we share your personal data within ALN it may be transferred outside the jurisdiction within which it is collected. This is done in compliance with the applicable law and applicable privacy policies.

13.2. We may also share personal data with third-party processors or clients outside the jurisdiction within which it is collected, ensuring that only the minimum necessary data is shared, and where possible, anonymized.

13.3. For transfers outside the jurisdiction in which it is collected, we ensure your personal data is protected through safeguards such as:

1. transfers to countries with adequate data protection levels as determined by relevant authorities under the applicable law; or
2. use of specific contracts or such other instrument or lawful basis provided under the applicable law, where applicable, which provide equivalent protection for your data.

15.1. You have the following rights regarding your personal data:

1. Right to be informed: You have the right to know how your personal data is being used, and we shall uphold this right through the use of this Notice and any supplemental or additional notices provided to you subsequently.
2. Right of access: You can request confirmation of whether we are processing your data and obtain details about its use and a copy of the personal data we hold about you. Typically, we will honor your exercise of this right at no cost to you. However, we may charge a reasonable fee or, where you fail to make payment, refuse your request where processing your request will impose an unreasonable cost on us.
3. Right to rectification: You can request correction of inaccurate or incomplete personal data.
4. Right to erasure: In certain cases, you can request that we delete your personal data.
5. Right to restrict processing: You can request us to limit the processing of your personal data in specific situations.
6. Right to data portability: In certain situations, you can request that your data is transferred to you or a third party in a structured, commonly used electronic format.
7. Right to object: You can object to the processing of your personal data, including for marketing purposes subject to any overriding legitimate or public interests.
8. Right not to be subject to automated decisions: You have the right not to be subjected to decisions based solely on automated processing if these have significant legal effects.
9. Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time.

15.2. To exercise these rights, please contact us at ALNPrivacy@aln.africa. Requests will be processed without charge, except in cases of excessive or repetitive requests. We aim to respond to all requests without delay or, at the latest, within one calendar month. If additional time is needed due to complexity, we will notify you.

15.3. We take your privacy seriously and so, should you have any privacy related issues in respect of our data processing activities, we appreciate the chance to deal with your concerns before you take other legal steps available to you. For any complaints or queries about how we process your personal data please contact us at ALNPrivacy@aln.africa.

15.4. Notwithstanding, you have the right to make a complaint to the relevant authority under the applicable law including where we are unable to resolve any complaints or queries.

2.1. This Privacy Notice applies to our processing of personal data in connection with:

1. Client services: Delivering services to current and prospective clients, including through specialized software, and sharing marketing content.
2. Client on-boarding and legal compliance: Client on-boarding and conducting client due diligence and know-your-customer checks (including under anti-money laundering and other laws and sanctions screening).
3. Supplier services: Receiving products and services from our suppliers and service providers.
4. Visitor services: Receiving and hosting visitors and providing facilities such as conference rooms, WiFi, and other amenities to visitors at our offices.
5. Recruitment activities: Processing candidate data for employment opportunities, including data received directly or through recruitment agencies, outside of standard recruitment processes.
6. Employment information: Entering into a contract of services with consultants, employees and short-term placements such as interns and work-study programme, performance of the contracts, providing access to staff benefits and complying with legal and contractual requirements.
7. Website use: Collecting and processing personal data through www.aln.africa, including when visitors subscribe to newsletters, register for events, or use contact forms.
8. Electronic portals and platforms: Managing personal data through platforms and other agreed electronic services.
9. Marketing communications: Sending marketing communications including newsletters and event invitations and other messages to keep you informed of legal developments, market insights and of our services.
10. Alumni: Keeping in touch with alumni, sharing news and success stories, invitation to alumni events, and sharing news and insights with you.
11. Regulatory: Compliance with our legal and regulatory obligations, including auditing and reporting requirements.
12. Legitimate interest: Pursuing our legitimate business interests.

2.2. This Privacy Notice applies to all individuals whose personal data we process in connection with the activities mentioned above. In this regard:

1. When we refer to you or your in this Notice, we mean any individual whose personal data we process including current and prospective clients, visitors to our website and physical offices, current and prospective partners/employees, and suppliers/service providers.
2. References to clients or suppliers also include their employees and staff whose personal data we process.
3. This Notice extends to individuals (and their respective employees or staff, where applicable) who are involved with our clients. This may include, but is not limited to, transaction counterparties, rival bidders, and litigants in legal proceedings.

2.3. We may process children’s personal data when required for specific client services, such as inheritance matters or in the course of pro bono activities. In other instances, we may also process the personal data of other categories of persons who are legally incapable of providing consent. Where we process the personal data of children or other persons lacking the legal capacity to consent, we only process such data as permitted by law.

4.1. Personal data includes any information related to an identified or identifiable individual. This excludes data that has been anonymized.

4.2. Special categories of personal data include sensitive information such as race, religion, political opinions, health data, criminal convictions and offenses and more as may be defined under the applicable law.

4.3. The categories of personal data we may collect include:

6.1. We will only collect and use your personal data when the applicable law permits us. This includes where:

1. it is necessary to perform a contract with you or to take steps at your request before entering into a contract;
2. it is necessary to comply with a legal or regulatory obligation;
3. it is necessary in the public interest to do so;
4. it is necessary to protect your vital interest where you are incapable of providing consent;
5. you have given your consent (where required);
6. it is necessary for our legitimate interests (or those of a third party), provided that your rights and freedoms do not override those interests; and/or
7. it is necessary for historical, statistical, journalistic, literature and art or scientific research.

6.2. We do not rely on consent as a legal basis for processing your personal data, except for where the law specifically requires that we seek your consent. Where processing is based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal.

6.3. How we use your personal data will depend on who you are, why you are interacting with us and the basis on which the personal data was obtained, and dependent on the aforesaid, we may use the relevant personal data for the respective purposes including:

1. advising clients of the firm(s);
2. supplier management;
3. employment and related purposes;
4. legal/regulatory compliance;
5. managing events and marketing;
6. running websites and platforms;
7. legal technology management;
8. handling enquiries and complaints;
9. office access management and security;
10. record keeping and documentation;
11. audits and quality control;
12. business planning, operations and related purposes; and
13. sharing within ALN, the member firms and their affiliates.

6.4. Our legitimate interests may include managing and operating our business efficiently, delivering services to you or your organisation, enhancing our services, carrying out marketing activities, ensuring the safety, security and integrity of our premises, operation of our systems, and complying with contractual and regulatory requirements. These are balanced against your rights and freedoms.

6.5. We will only process special categories of personal data (such as health data or data relating to criminal convictions) where you provide your consent or where it is necessary and permitted by law, for example to provide legal advice, meet employment obligations, or establish, exercise or defend legal claims.

6.6. Data retention periods apply depending on the nature of the data and our regulatory obligations. The retention period is determined based on the data’s nature and sensitivity, the purpose for processing, potential risks, and legal obligations.

6.7. In certain cases, we may anonymize your personal data for research or statistical purposes, allowing us to use it indefinitely.

6.8. You may contact us for further details on our retention practices at ALNPrivacy@aln.africa.

6.9. You may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.

In the course of providing services, you may share with us personal data relating to individuals who are unaware of our involvement or of our processing activities. Where we do not have direct contact with these individuals or where providing them with a privacy notice is not appropriate (for example, to maintain confidentiality), you must ensure that the relevant individuals have been appropriately informed and/or that there is a valid legal basis for sharing their personal data with us.

10.1. You can opt-out of receiving marketing communication at any time by using the unsubscribe links provided in our marketing communications or by contacting our Privacy Team at ALNPrivacy@aln.africa.

10.2. If you request that we stop using your personal data for marketing purposes, we will promptly honour your request at no cost.

10.3. We may still send non-promotional or administrative updates even if you opt out of marketing communications. Further, your previously collected personal data will continue to be processed for purposes unrelated to marketing where a valid alternative legal basis exists independent of your consent.

10.4. We do not share your personal data with any organisations outside of ALN for marketing purposes.

12.1. Where required and subject to applicable laws, professional obligations, and any relevant contractual terms, we may disclose your personal data to:

1. courts, governmental, tax, regulatory or law enforcement bodies (such as the anti-money laundering authorities);
2. professional advisers and consultants, such as lawyers, auditors, accountants, insurers, and bankers;
3. financial institutions providing finance to us;
4. service providers offering IT, courier, marketing, screening, data analysis and system administration services;
5. external auditors conducting independent reviews of our files for accreditation purposes;
6. fellow event attendees where your name appears on the attendee list for events where you have confirmed your intention to attend; and
7. other law firms outside of the ALN alliance.

for the purposes described in Section 6 above (How We Use Your Personal Data and the Bases for Doing So).

12.2. Your personal data may be shared within ALN. As an alliance of law firms, we share personal data between firms within our alliance to operate efficiently and to deliver high-quality client services. Such sharing is conducted in accordance with all applicable laws and applicable privacy policies.

12.3. Where necessary for client or visitor services, or supplier engagement, we may also disclose your personal data to third parties based on your instruction.

12.4. In the event of a merger, acquisition, alliance expansion, or sale of part of our business, we may share your personal data with the relevant parties.

12.5. Where we host events with partner organisations, we may share your personal data with these partners and where applicable act as joint controllers. We may provide additional information regarding joint processing in our event communications.

12.6. We may also share your corporate contact details with legal directories and ranking organisations to seek feedback on services we have provided to you.

We implement robust organisational, physical, and electronic security measures to protect your personal data from unauthorized access, use, or loss. This includes secure data storage, access controls, and regular security updates. All partners, staff, and third-party service providers who have access to your personal information are required to maintain strict confidentiality.

This Notice is kept under regular review. From time to time, we may change, amend or review this Notice to reflect changes in the law, or our data protection practices. It is important that you review the amended Privacy Notice to stay abreast of changes that may impact how we process your personal data.

ALN Privacy Policy