Privacy Policy and Personal Data Protection

This policy is designed to ensure dual compliance: with the General Data Protection Regulation (EU Regulation 2016/679 — GDPR), applicable in the EU and to any service targeting EU residents, and with the United Arab Emirates Personal Data Protection Law (Federal Decree-Law No. 45 of 2021 — PDPL), applicable to the office established at Meydan Free Zone (a non-financial free zone, falling within the scope of the federal PDPL rather than the DIFC or ADGM regimes).

3.1. Identity of the data controller

Maître Hervé Israel, Avocat au Barreau de Paris, acting from his principal office in Dubai (Meydan Free Zone) with an administrative service address in Paris, is the data controller within the meaning of Article 4(7) GDPR and Article 1 of the PDPL.

Any request relating to data protection may be addressed to: – Email: hi@parnassah-international.com

3.2. Categories of data collected

In the context of the use of the website and the provision of legal services, Maître Hervé ISRAEL may collect and process the following categories of data:

• Identification data: surname, first name, title, nationality, date and place of birth, copy of identity document (in the context of KYC);
• Contact data: postal address, email address, telephone number;
• Professional data: position, employer, sector of activity;
• Financial data: bank details, billing information, source of funds information;
• Matter-related data: any factual, legal or documentary element provided in the context of the engagement;
• Connection data: IP address, pages visited, duration of visit, cookie data (see § 3.7).

Sensitive data within the meaning of Article 9 GDPR or Article 1 PDPL (racial or ethnic origin, political opinions, religious or philosophical beliefs, health data, sexual orientation, judicial data, etc.) is only collected where strictly necessary to the engagement and with your express consent, or where the law so allows.

3.3. Purposes and legal bases for processing

3.4. Recipients of data

Your data is not sold or rented to any third party. It may be communicated, strictly within the limits of the engagement or legal obligations, to:

• the firm’s collaborators and personnel, who are bound by professional secrecy;
• avocatsand other legal officers (notaries, bailiffs, experts) involved in the matter;
• courts, administrative authorities or prosecuting authorities involved in the matter;
• the firm’s technical service providers (hosting, email, accounting, billing), under sub-processing contracts containing confidentiality and security undertakings consistent with the GDPR and the PDPL;
• TRACFIN (the French financial intelligence unit) or equivalent authorities (notably the UAE Financial Intelligence Unit) under AML/CFT obligations;
• the CARPA in the context of client fund handling.

3.5. International data transfers

Given the firm’s activity between France and the UAE, your data may be transferred between these two jurisdictions:

• EU → UAE transfers: the European Commission has not adopted an adequacy decision in respect of the UAE. Such transfers are therefore framed by the Standard Contractual Clausesadopted by the European Commission (Implementing Decision 2021/914), supplemented where necessary by additional measures consistent with EDPB recommendations;
• UAE → EU transfers: the GDPR being deemed to provide an equivalent level of protection, such transfers are made in accordance with Article 22 of the PDPL;
• Transfers to other jurisdictions: carried out only with your express consent, or where necessary for the performance of the engagement or the establishment, exercise or defence of legal claims.

3.6. Retention periods

Your data is retained for no longer than is necessary for the purposes for which it was collected:

• Client files: 5 years from the end of the engagement (Article 2225 of the French Civil Code on professional liability), extended to 10 years in commercial matters (Article L.123-22 of the French Commercial Code);
• KYC documents: 5 years from the end of the business relationship (Article L.561-12 of the French Monetary and Financial Code);
• Accounting records: 10 years (Article L.123-22 of the French Commercial Code);
• Prospect data: 3 years from the last contact;
• Connection data: 13 months maximum (CNIL recommendation);
• Newsletter: until the consent is withdrawn.

3.7. Cookies

This website uses cookies. Upon your first visit, a banner informs you of their presence and invites you to express your choices. No cookie other than those strictly necessary for the operation of the website is placed without your prior consent.

The cookies used are:

• Strictly necessary cookies: session, security, load balancing (exempt from consent);
• Audience measurement cookies: [specify — e.g. Matomo in anonymised mode (consent-exempt), or Google Analytics (subject to consent)];
• Social sharing cookies: [where applicable, subject to consent].

You may modify your preferences at any time via [the cookie management tool / the footer of the site].

3.8. Your rights

In accordance with Articles 15 to 22 GDPR and Articles 13 to 19 PDPL, you have the following rights in respect of your data:

• right of access;
• right to rectification;
• right to erasure(subject to legal retention obligations);
• right to restrictionof processing;
• right to portability;
• right to object;
• right to withdraw consentat any time, without prejudice to the lawfulness of prior processing;
• right to issue post-mortem directivesregarding the fate of your data.

These rights may be exercised by sending a written request, accompanied by a copy of an identity document, to: [privacy@cabinet.com] or by post to the firm’s address. A response will be provided within one month (GDPR) or as soon as possible (PDPL).

3.9. Right to lodge a complaint

If you consider that your rights have not been respected, you have the right to lodge a complaint with:

• the Commission Nationale de l’Informatique et des Libertés (CNIL)— 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France — cnil.fr;
• the UAE Data Office— competent authority in the United Arab Emirates under Federal Decree-Law No. 44 of 2021.

3.10. Security

Maître Hervé Israel implements appropriate technical and organisational measures to ensure the security, confidentiality, integrity and availability of the data processed: encryption of communications (HTTPS/TLS), strong authentication, access control, regular backups, and training of staff in professional secrecy and information security.