1. Introduction
This Privacy Policy explains how [FIRM LEGAL NAME], operating as loramora (the "Firm," "we," "us," or "our"), handles personal data collected through the website located at [WEBSITE DOMAIN] (the "Website") and through related communications, such as inquiries sent to the email address published on the Website.
This Policy is drafted with reference to widely recognized data protection principles, including those reflected in the General Data Protection Regulation ("GDPR"), where relevant to the Firm's processing activities. Reference to these principles does not constitute a representation that the Firm has undergone, or completed, a formal assessment of compliance with the GDPR or any other specific data protection law, and the Firm's actual obligations depend on the jurisdictions in which it operates and processes personal data, to be confirmed by the Firm prior to publication.
Personal data relating to Clients that is received in the course of a legal engagement, and that is subject to attorney–client privilege, professional secrecy, or confidentiality obligations under applicable rules of professional conduct, is handled in accordance with those obligations and the relevant Engagement Agreement, in addition to this Policy.
2. Definitions
Capitalized terms not defined in this Policy have the meaning given in the Website Terms of Use. In addition, in this Policy:
- "Personal Data" means any information relating to an identified or identifiable natural person.
- "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, and deletion.
- "Controller" means the entity that determines the purposes and means of Processing.
- "Data Subject" means the individual to whom Personal Data relates.
- "Supervisory Authority" means a governmental body responsible for monitoring the application of data protection law in a relevant jurisdiction.
- "Special Category Data" means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data used for identification, health data, or data concerning a person's sex life or sexual orientation, or an equivalent category recognized under Applicable Law.
3. Scope
This Policy applies to Personal Data the Firm processes as a Controller in connection with the Website and general inquiries. It does not apply to Personal Data the Firm processes on behalf of a Client, or within the scope of an active representation, which is instead addressed by the relevant Engagement Agreement and applicable professional obligations. It also does not apply to the practices of third-party websites that may be linked from the Website.
4. Categories of Personal Data
Depending on how you interact with the Website, the Firm may process the following categories of Personal Data:
- Contact details you provide when sending an inquiry, such as your name, email address, and telephone number, where you choose to include it;
- Inquiry content, meaning the information you choose to include in the body of your message describing your matter;
- Conflict-check information, meaning names of parties or entities you identify as relevant to a potential conflict of interest review; and
- Technical information that may be recorded by the hosting environment as a byproduct of serving Website pages, such as basic server access logs, to the extent the Firm's hosting provider generates them. The Website is built without analytics services, tracking cookies, or third-party embedded trackers by default.
The Firm does not request that Users submit Special Category Data or other sensitive categories of personal data (such as data concerning health, criminal history, or similarly sensitive information) through the general inquiry channel, and Users are asked not to include such information, or other confidential details, before receiving instructions to do so. If Special Category Data is nonetheless included in an inquiry because it is unavoidably relevant to the general nature of a prospective matter, the Firm will handle it with heightened care and will limit its use to the purposes described in this Policy, pending confirmation of the specific lawful basis for processing such data under Applicable Law.
5. How We Collect Personal Data
The Firm collects Personal Data directly from you when you send an inquiry by email or otherwise initiate contact using the details published on the Website. The Firm does not use the Website to collect Personal Data passively through analytics, advertising pixels, or third-party tracking scripts. If the Firm's hosting provider generates basic technical logs as part of standard infrastructure operation, those logs are governed by the hosting provider's own practices and, to the extent within the Firm's control, are used only for security and website-operation purposes.
6. Purposes and Potential Lawful Bases
The Firm may process Personal Data described above for the following purposes, together with the lawful basis that may apply under GDPR-style frameworks, subject to confirmation of the Firm's specific legal position by qualified counsel:
- Responding to inquiries and conducting conflict checks — potentially based on the Firm's legitimate interest in evaluating prospective engagements, or on steps taken at your request prior to entering into an agreement.
- Establishing and performing an Engagement Agreement, where one is entered into — potentially based on the performance of that contract.
- Complying with legal, regulatory, and professional obligations, such as client identification, anti-money-laundering, and sanctions screening requirements — potentially based on compliance with a legal obligation.
- Maintaining the security and integrity of the Website — potentially based on the Firm's legitimate interest in protecting its systems and communications.
Where Applicable Law requires consent as the lawful basis for a specific processing activity, the Firm will seek that consent separately before undertaking the activity.
7. Recipients of Personal Data
The Firm may share Personal Data with categories of recipients that may include: personnel within the Firm who need the information to evaluate or handle an inquiry; professional advisers bound by confidentiality obligations; the Firm's information-technology and hosting providers, acting on the Firm's instructions; and courts, regulators, or law enforcement authorities where required by Applicable Law, as further described in the Compliance and Law Enforcement Requests Policy. The Firm has not identified specific named third-party vendors in this Policy; any such vendors will be identified by the Firm prior to publication if applicable.
8. International Transfers
Personal Data may be processed in a country other than the one in which you are located, including where the Firm's hosting infrastructure is situated. Where such transfers occur from a jurisdiction that restricts international transfers of Personal Data, the Firm intends to rely on appropriate safeguards recognized under Applicable Law, such as standard contractual clauses or an applicable adequacy decision. The specific safeguards applicable to the Firm's actual data flows are to be confirmed and documented by the Firm prior to publication, as they depend on the Firm's chosen jurisdiction, hosting arrangements, and service providers, which are not yet finalized in this draft.
9. Data Retention
The Firm retains Personal Data only for as long as reasonably necessary for the purposes described in this Policy, having regard to factors such as the nature of the inquiry, whether an Engagement Agreement results, applicable statutory retention periods (including those relating to professional conduct, conflicts records, and anti-money-laundering obligations), and applicable limitation periods for legal claims. Specific retention periods have not been finalized and will be determined by the Firm, with input from qualified counsel, prior to publication.
10. Security Measures
The Firm intends to apply administrative, technical, and organizational measures appropriate to the nature of the Personal Data it processes, aimed at protecting it against unauthorized access, loss, misuse, or alteration. No method of transmission or storage is completely secure, and the Firm cannot guarantee absolute security. Users are reminded not to send sensitive or confidential information through unencrypted email before receiving instructions to do so.
11. Cookies and Similar Technologies
The Website is built as a static site without analytics cookies, advertising cookies, tracking pixels, or third-party embedded content by default. If the Firm later decides to introduce cookies or similar technologies (for example, a strictly necessary session cookie required for a future feature), this Policy will be updated in advance to describe the categories of cookies used, their purpose, and, where required by Applicable Law, to provide a mechanism for obtaining consent before non-essential cookies are set.
12. Your Rights
Depending on the jurisdiction in which you are located and the law that applies to the Processing of your Personal Data, you may have some or all of the following rights, which the Firm intends to honor to the extent required by Applicable Law:
- the right to be informed about how your Personal Data is processed;
- the right to access a copy of your Personal Data;
- the right to request rectification of inaccurate or incomplete Personal Data;
- the right to request erasure of your Personal Data in certain circumstances;
- the right to request restriction of Processing in certain circumstances;
- the right to data portability, where applicable;
- the right to object to Processing based on legitimate interests, in certain circumstances; and
- the right to withdraw consent at any time, where Processing is based on consent, without affecting the lawfulness of Processing before withdrawal.
These rights may be subject to limitations, including where Personal Data is protected by attorney–client privilege, professional secrecy, or a legal obligation that requires or permits continued retention or restricts disclosure. To exercise a right described in this Section, please contact the Firm using the details in Section 16.
When you exercise a right under this Section, the Firm may need to verify your identity before acting on the request, to guard against a request being made by someone other than the Data Subject or their authorized representative. The Firm intends to respond to verified requests within the timeframe required by Applicable Law and, where a request is complex or the Firm requires additional time, to inform you of the reason for any extension.
13. Automated Decision-Making
The Firm does not use the Website to make decisions about individuals based solely on automated processing, including profiling, that produce legal or similarly significant effects.
14. Children's Privacy
The Website is intended for use by adults seeking or providing information about legal services and is not directed to children. The Firm does not knowingly collect Personal Data from children through the Website. If you believe a child has provided Personal Data to the Firm through the Website, please contact the Firm using the details in Section 16.
15. Changes to This Policy
The Firm may revise this Policy from time to time to reflect changes in its practices or Applicable Law. The effective date at the top of this page indicates when it was last revised.
16. Contact and Data Protection Inquiries
Questions about this Policy, or requests to exercise a privacy right, may be directed to:
[FIRM LEGAL NAME]
Email: privacy@loramora.example
Address: [FIRM OFFICE ADDRESS]
Data Protection Officer / Privacy Contact: [NAME AND CONTACT DETAILS, IF APPLICABLE]
17. Complaints to a Supervisory Authority
If you believe the Firm's Processing of your Personal Data does not comply with Applicable Law, you may have the right to lodge a complaint with a Supervisory Authority in your country of residence, place of work, or the place of the alleged infringement. The relevant Supervisory Authority for the Firm's principal place of business is [NAME AND CONTACT DETAILS OF RELEVANT SUPERVISORY AUTHORITY].