Privacy Policy

1. Introduction

Eternity Law International respects the privacy and confidentiality of its clients, prospective clients, business partners, website visitors and other individuals whose personal data it processes.

This Privacy Policy explains how personal data is collected, used, disclosed, stored and protected when an individual:

• visits or interacts with www.eternitylaw.com (the “Website”);
• submits an enquiry or contact form;
• communicates with Eternity Law International by email, telephone, messaging applications, social media or other communication channels;
• requests or receives professional, consulting, legal support, corporate, compliance, licensing, IT or related services;
• interacts with our advertising or marketing campaigns; or
• otherwise provides personal data to us.

This Privacy Policy constitutes an integral and inseparable part of the Public Offer Agreement published on the Website and shall be read and interpreted together with the Public Offer Agreement.  By accepting the Public Offer Agreement and/or using the Website or the services provided through it, the you confirm that you have read, understood, and agreed to the terms of this Privacy Policy.  In the event of any inconsistency between this Privacy Policy and the Public Offer Agreement with respect to the processing and protection of personal data, the provisions of this Privacy Policy shall prevail.

2. Data Controllers

Eternity Law International operates through the following entities:

EL INTERNATIONAL LLC
Registration No. 404647735
Registered address: Georgia, Tbilisi, Mtatsminda district, Revaz Tabukashvili Str., N 45, area N 7

and

ELI GLOBAL LTD
Company No. 12586107
Registered office: 85 Great Portland Street, First Floor, London, United Kingdom, W1W 7LT.

Depending on the circumstances, the relevant Eternity Law International entity may act as a data controller independently or, where the purposes and means of processing are jointly determined, together with another Eternity Law International entity.

The entity responsible for processing in connection with a particular professional engagement will generally correspond to the entity identified in the relevant invoice, engagement letter, quotation, service agreement or other contractual documentation.

For Website administration, marketing, advertising, analytics and lead-management activities, personal data may be processed by one or more Eternity Law International entities as necessary for those purposes.

3. Personal Data We Collect

Depending on the nature of the interaction, we may collect and process the following categories of personal data:

3.1 Identification and contact information

This may include:

• name and surname;
• company name and position;
• email address;
• telephone number;
• postal or business address;
• country of residence or business activity;
• internal client or CRM identifier.

3.2 Client and professional information

Where necessary for providing services, we may process:

• corporate and ownership information;
• identification and KYC documentation;
• information concerning directors, shareholders, beneficial owners and authorised representatives;
• information concerning a client’s business activities;
• regulatory, licensing and compliance information;
• financial and transactional information;
• correspondence and documents provided in connection with an engagement.

3.3 Website and technical information

When an individual visits or interacts with the Website, we may collect information such as:

• IP address;
• browser and device information;
• approximate location derived from technical information;
• referring website;
• Website pages viewed;
• date and time of visits;
• cookie and similar technology identifiers;
• advertising and attribution identifiers;
• Google Click ID (GCLID) and similar campaign identifiers;
• information concerning interaction with advertisements and Website forms.

3.4 Marketing and conversion information

Where permitted by applicable law, we may process information concerning:

• the source through which a client or prospective client contacted us;
• advertising campaign, advertisement or keyword attribution;
• enquiries and leads;
• whether a lead became a qualified lead or client;
• purchase or conversion status;
• conversion date;
• transaction or conversion value;
• CRM status;
• marketing preferences and consent status.

4. Sources of Personal Data

We may obtain personal data:

• directly from the individual;
• through Website forms;
• through our CRM and internal systems;
• through email, telephone, messaging applications or social media;
• from a company or representative acting on behalf of the individual;
• from publicly available sources where permitted by law;
• from professional advisers and service providers;
• through advertising platforms and analytics technologies;
• from cookies and similar technologies, subject to applicable consent requirements.

Where personal data has not been obtained directly from the individual, we will provide the information required by applicable data protection legislation where required.

5. Purposes and Legal Bases for Processing

We process personal data only where there is an appropriate legal basis.

Depending on the circumstances, the legal basis may include:

5.1 Performance of a contract

We may process personal data where necessary to:

• respond to a request for services;
• prepare a proposal or engagement;
• provide professional services;
• manage a client relationship;
• process payments;
• communicate concerning an engagement; or
• fulfil our contractual obligations.

5.2 Compliance with legal obligations

Personal data may be processed where required for:

• accounting and tax obligations;
• anti-money laundering and compliance requirements;
• fraud prevention;
• regulatory requirements;
• sanctions screening;
• responding to lawful requests of courts, regulators or public authorities;
• establishing or maintaining legally required records.

5.3 Legitimate interests

Where permitted by applicable law, we may process personal data where necessary for our legitimate interests, including:

• managing and developing our business;
• maintaining relationships with clients and business contacts;
• improving our services;
• administering our Website and IT systems;
• ensuring network and information security;
• detecting fraud or misuse;
• measuring the effectiveness of advertising campaigns;
• analysing business performance;
• maintaining CRM records;
• carrying out certain business-to-business marketing activities;
• establishing, exercising or defending legal claims.

Before relying on legitimate interests, we consider the nature of the processing, its necessity and the impact on the rights and interests of the individuals concerned.

5.4 Consent

Where consent is required, we may rely on consent for purposes including:

• non-essential cookies and similar technologies;
• personalised advertising;
• certain forms of direct electronic marketing;
• Customer Match or similar advertising audience functionality;
• the use of personal data for advertising personalisation where required by applicable law.

Consent may be withdrawn at any time without affecting the lawfulness of processing conducted before withdrawal.

6. Advertising, Google Ads and Conversion Measurement

We may use advertising and measurement services, including services provided by Google, to understand how users interact with our advertising and Website and to evaluate and improve the effectiveness of our marketing campaigns.

Depending on the technologies used and the individual’s consent preferences, this may involve processing information including:

• email addresses;
• telephone numbers;
• GCLID and similar advertising identifiers;
• conversion dates;
• conversion values;
• lead or client status;
• campaign and advertisement information;
• Website interaction data;
• consent signals.

6.1 Customer Match

Where permitted by applicable law and where required consent has been obtained, we may use first-party customer information for Google Ads Customer Match or comparable advertising functionality.

This may involve securely transmitting identifiers such as an email address or telephone number to an advertising provider for matching against its own user records.

Where technically supported, identifiers may be hashed before transmission.

We do not sell client contact information to advertisers.

Customer data is used for Customer Match only where we have an appropriate lawful basis and, for jurisdictions where consent is required, only where the appropriate consent has been obtained.

Individuals may withdraw their consent or object to the use of their personal data for direct marketing at any time.

6.2 Enhanced Conversions and offline conversion measurement

We may use enhanced conversion or offline conversion technologies to determine whether an advertising interaction resulted in an enquiry, qualified lead, purchase or other conversion.

For these purposes, information such as an email address, telephone number, GCLID, conversion date and conversion value may be transmitted to Google or another advertising provider.

Where applicable, customer identifiers are transmitted in hashed form.

The purpose of such processing is to:

• attribute enquiries and purchases to advertising campaigns;
• measure advertising performance;
• improve conversion reporting;
• optimise advertising expenditure; and
• improve the relevance and effectiveness of our advertising.

6.3 Advertising consent

For users located in the European Economic Area, United Kingdom or other jurisdictions requiring consent, advertising technologies that require consent will be used only in accordance with the consent choices made by the user.

Where applicable, consent status may be communicated to advertising providers using technical consent signals.

Refusing or withdrawing advertising consent will not prevent an individual from using the essential functionality of the Website or requesting our services.

7. Cookies and Similar Technologies

The Website may use cookies, pixels, tags, local storage and similar technologies.

These may include:

Strictly necessary technologies

Required for security, Website operation and essential functionality.

Analytics technologies

Used to understand Website usage and improve Website performance.

Advertising and conversion technologies

Used to measure advertising campaigns, attribute conversions, create or measure advertising audiences and, where consent has been provided, personalise advertising.

Non-essential cookies and similar technologies will be activated in accordance with applicable consent requirements.

Users may change or withdraw their cookie choices through the Website’s cookie consent mechanism where available.

8. Disclosure of Personal Data

We do not sell personal data.

We may disclose personal data where necessary to:

• other Eternity Law International entities;
• employees and authorised personnel;
• lawyers, consultants, accountants and other professional advisers;
• CRM, hosting, cloud-storage, cybersecurity and IT service providers;
• communication and email service providers;
• payment and banking service providers where necessary;
• analytics and advertising providers, including Google, where permitted;
• contractors and professional partners involved in providing requested services;
• public authorities, regulators, law enforcement bodies or courts where disclosure is legally required.

Recipients may act either as processors acting on our instructions or as independent controllers, depending on the circumstances.

We require processors handling personal data on our behalf to implement appropriate confidentiality, security and data protection safeguards.

9. Google and Other Advertising Providers

When we use Google advertising or measurement services, Google may process information in accordance with its own privacy and data protection terms.

Depending on the services enabled, Google may receive hashed customer identifiers, advertising identifiers, consent signals, Website interaction information and conversion data.

We configure such services with the intention of limiting processing to the purposes authorised by us and permitted by applicable law.

The use of Google or another advertising provider does not mean that we sell or provide unrestricted access to our client database.

10. International Transfers

Due to the international nature of Eternity Law International and its service providers, personal data may be processed in countries outside the individual’s country of residence, including outside the European Economic Area or United Kingdom.

Where applicable data protection law requires safeguards for an international transfer, we use appropriate mechanisms, which may include:

• an adequacy decision;
• Standard Contractual Clauses;
• the UK International Data Transfer Agreement or UK Addendum;
• other legally recognised transfer mechanisms; or
• another applicable exemption permitted by law.

Where appropriate, additional technical or organisational safeguards may also be applied.

11. Data Retention

Personal data is retained only for as long as reasonably necessary for the purposes for which it was collected, including for legal, accounting, regulatory, contractual and dispute-resolution purposes.

Retention periods may vary depending on the nature of the information.

In determining an appropriate retention period, we consider:

• the nature and sensitivity of the data;
• the purpose of processing;
• applicable limitation periods;
• legal and regulatory requirements;
• whether the information remains necessary for an ongoing client relationship.

Marketing information will be retained only for as long as reasonably required for marketing purposes or until the individual withdraws consent or exercises an applicable right to object.

Where necessary, limited information may be retained on a suppression list to ensure that a marketing objection or withdrawal of consent continues to be respected.

12. Security

We implement technical and organisational measures designed to protect personal data against:

• unauthorised access;
• accidental or unlawful destruction;
• loss;
• alteration;
• unauthorised disclosure; and
• other unlawful processing.

Measures may include access controls, confidentiality obligations, security monitoring, appropriate authentication measures, restricted access to client files, backup procedures and other security controls appropriate to the nature of the data.

Access to personal data is limited to personnel and service providers who require such access for legitimate business purposes.

13. Confidential and Professional Information

Information supplied in connection with professional services may also be subject to contractual confidentiality obligations, professional secrecy or legal professional privilege where applicable.

Nothing in this Privacy Policy is intended to waive any privilege, confidentiality obligation or other legal protection applicable to such information.

14. Individual Rights

Subject to applicable law and relevant exemptions, individuals may have the right to:

• obtain confirmation as to whether we process their personal data;
• request access to their personal data;
• request correction of inaccurate or incomplete data;
• request deletion of personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• object at any time to processing for direct marketing purposes;
• withdraw consent at any time where processing is based on consent;
• request data portability;
• lodge a complaint with a competent data protection supervisory authority.

An objection to processing for direct marketing purposes will be respected in accordance with applicable law.

We may request reasonable information to verify the identity of a person making a rights request.

15. Automated Processing and Profiling

Advertising and analytics systems may automatically analyse information concerning Website interactions, enquiries, advertising interactions or conversion events.

This may be used to:

• measure advertising effectiveness;
• group users into advertising audiences;
• optimise advertising campaigns; or
• determine which advertisements may be more relevant.

We do not use solely automated decision-making producing legal or similarly significant effects on individuals unless permitted by applicable law and appropriate safeguards are implemented.

16. Direct Marketing

Where permitted by law, we may contact existing or prospective business clients regarding services that may reasonably be relevant to them.

Where consent is legally required, direct marketing communications will be sent only after obtaining the necessary consent.

Every individual has the right to object to direct marketing at any time.

Marketing preferences may be changed using an unsubscribe mechanism contained in a communication or by contacting us.

Withdrawal from marketing does not affect communications necessary to provide services or administer an existing contractual relationship.

17. Children

Our services are intended for businesses and adults acting in a professional or commercial capacity.

We do not knowingly seek to collect personal data from children for advertising or marketing purposes.

18. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time to reflect changes in:

• applicable law;
• our business operations;
• our services;
• technologies we use; or
• our data-processing practices.

The updated version will be published on the Website together with the date of the latest revision.

Where a change materially affects processing based on consent, we will obtain new consent where required by applicable law.

19. Contact and Data Protection Requests

Questions concerning this Privacy Policy or requests concerning personal data may be submitted through the contact details published on the Website.

For data protection requests, individuals should identify the nature of their request and provide sufficient information for us to locate the relevant personal data.

Individuals located in the European Economic Area or United Kingdom also have the right to lodge a complaint with the competent data protection supervisory authority.

20. Relationship with the Public Offer Agreement

This Privacy Policy forms part of the legal framework governing use of the Website and our services.

To the extent that the Public Offer Agreement or another general Website document states that personal data is never disclosed to third parties or is used exclusively for the performance of services, such wording shall be interpreted subject to this Privacy Policy and shall not prevent lawful disclosure to processors, professional advisers, advertising or analytics providers, regulatory authorities or other recipients identified above.

Personal data will in all cases be processed only for specified and lawful purposes and in accordance with applicable data protection legislation.