Data Protection Notice

The purpose of this Notice is to inform the user (hereinafter "You") of the Website https://www.99avocats.com/ (hereinafter the "Website") fairly and transparently about the cookies used by the Website, how data is collected and processed and about the rights of the user, with regard to the applicable provisions of Law no. 1.565 of 3 December 2024 on the protection of personal data.

The Website is built on the Craft content management system (CMS). The Website's identity is authenticated by a Let's Encrypt digital certificate, which ensures a secure connection to the Website.

This Information Notice may evolve depending on the legal and regulatory context.

You are invited to consult the Legal Notice, which can also be accessed at the bottom of the Website page.

The data controller for the use of the Website is the law firm 99 AVOCATS ASSOCIÉS (hereinafter "99 AVOCATS"):

« Les Flots bleus » (4th floor)
16 rue du Gabian
MC 98000 Monaco

Email: dataprotection@99avocats.com

2.1 Minimisation

99 AVOCATS ensures that the data collected in the context of browsing the Site and using it is adequate, relevant and limited to what is necessary with regard to the purposes for which it is processed (article 4 of Law no. 1.565) (see 3. Purposes and legal basis for processing).

2.2 Data collected

Information relating to your browsing is collected via cookies that may be placed on or read by your terminal (computer, tablet, smartphone, etc.). Depending on their function, these cookies are:

• exempt from your consent (mandatory technical cookies, necessary for the operation and security of the Site);
• subject to your prior consent (optional analytical cookies, to measure the Website's audience) by means of a positive act (opt-in) (see 9. Cookie management).

Where applicable, personal data (mandatory and optional) concerning you may be collected from you, at your initiative:

• when you contact us using the "Contact us" form: first name, surname, e-mail address, telephone number (this information marked with an asterisk (*) is mandatory in order to process your request), and other information about yourself that you provide spontaneously in the body of the message (see 10. Contact management);
• when you send us your unsolicited application to the address candidature@99avocats.com: e-mail (mandatory) and other information that you send us spontaneously in the body of the message or as an attachment, including CV and covering letter, so that we can process your application (see 10. Contact management);
• when you subscribe to our newsletter: e-mail (mandatory), in order to be included in the distribution list (see 11. Newsletter management).

99 AVOCATS ensures that your personal data is collected via the Website for specific, explicit and legitimate purposes, and is not subsequently processed in a manner incompatible with these purposes (article 4 of Law no. 1.565).

You may withdraw your consent at any time where this constitutes the legal basis for the processing. Withdrawal of consent does not affect the lawfulness of the processing that took place prior to the withdrawal.

The purposes for which data is processed via the Website and their legal basis (article 5 of Law no. 1.565) are as follows:

4.1 In-house

The strictly authorised staff of 99 AVOCATS (management of contacts, applications, newsletter) have access to the data communicated on your initiative via the Website (see 10. Contact management,11. Newsletter management).

4.2 Third party recipients

Where applicable, third parties may receive your data when you give your consent by means of a positive action (opt-in, click):

• Sinch Mailjet, emailing service, when you subscribe to the newsletter distribution list (see 11. Newsletter management).
• Google Analytics, Website audience analysis service, when you accept the placement and reading of statistical cookies (see 9. Cookie management).

Data may be transferred to third countries on the basis of your consent:

• The Mailjet emailing service data centre (used to distribute the newsletter) is located in the European Union (Belgium, Germany) whose legislation (GDPR) provides an adequate level of protection with regard to Law no. 1.565 of 3 December 2024 on the protection of personal data. To find out more about data processing by Mailjet, click on the following link: https://www.mailjet.com/securi... (see 11. Newsletter management).
• Google Analytics (Website audience) transfers the data collected from its service to the United States of America, a country which does not have an adequate level of protection, i.e. does not provide you with guarantees and rights equivalent to those provided for by Law no. 1.565 of 3 December 2024 on the protection of personal data (see 7. Rights of the data subject and conditions for exercising them and 8. Right of recourse). To find out more about the processing of data by Google Analytics, click on the following link: https://support.google.com/ana... (see 9. Cookie management).

Your personal data collected via the Website is kept for the period necessary for the operations for which you have consented to it being processed, in compliance with the legislation in force:

• Data of the person subscribed to the newsletter mailing list: for as long as the person wishes to be subscribed.
• Data of the person sending an unsolicited application: 2 years maximum from the last contact.
• Data of the person using the contact form: the time necessary to respond to a simple request or a maximum of 1 year after the last contact (prospect) or for the duration of the contractual relationship and 5 years after the end of the relationship (client).

For information on how long cookies are kept, see 9. Cookie management.

You have the right to access the data concerning you and to obtain a copy (article 12 of Law no. 1.565), to obtain the rectification of inaccurate or incomplete data (article 13 of Law no. 1.565), their deletion (article 14 of Law no. 1.565), and the limitation of processing (article 15 of Law no. 1. 565), and where applicable, to object to the processing (article 17 of Law no. 1.565), which you may exercise by electronic means, by post or in person with the data controller (see 1. Identity and contact details of the data controller).

If you consider that the rights conferred to you by Law no. 1.565 of 3 December 2024 on the protection of personal data (see 7. Rights of the data subject and conditions for exercising them) or the texts adopted for its application have been disregarded, you may lodge a complaint with the Personal Data Protection Authority (Autorité de Protection des Données Personnelles "APDP") https://apdp.mc/ Le Concorde, 11 rue du Gabian, 98000 Monaco (article 39 of Law no. 1.565).

You also have the right to appeal to the courts (article 102 of Law no. 1.565).

Cookies are small text files (strings of information) placed on your terminal (computer, tablet, smartphone, etc.) and read by a web server when you visit a website. The cookies deposited are associated with the domain of the website visited, or even with other domains managed by third parties.

The content of a cookie generally consists of the name of the web server that placed it, an expiry date and a unique encrypted code. This unique code enables your Internet browser (Mozilla Firefox, Google Chrome, Microsoft Edge, Safari, Opera, etc.) to recognise you while you are browsing a website (session cookie remaining on your terminal for the duration of the session), or during a subsequent visit or use (persistent cookie remaining on your terminal until its retention period expires, unless you object).

The Website uses the following cookies, distinguished according to whether they are legally exempt from your prior consent (1), or subject to your prior consent (2):

1. Technical cookies exempt from your prior consent

The cookies placed by the Website that are strictly necessary for its operation and navigation (essential security functions and access to Website functions, navigation between Website pages, management of the display of the cookie banner) are legally exempt from the need to obtain your prior consent:

2. Third-party cookies requiring your prior consent

Cookies used to analyse traffic on the Website and measure the audience (traffic volumes), which are placed by Google Analytics, require your consent:

Google Analytics collects data on visits to the Website and information on visitor behaviour using cookies and their IP (Internet Protocol) address, which provides information on the country of origin of visits. To find out more about the processing of data by Google Analytics, click on the following link: https://support.google.com/ana...

The visit statistics (number of sessions, number of users, most common keywords entered by users on Google, pages viewed, average length of sessions, countries in which these activities were recorded, etc.) to which 99 AVOCATS has access during consultation are anonymous.

The use of statistical cookies to measure the Website's audience is subject to your prior and explicit consent.

On your first visit to the Website, a banner is displayed informing you of the use of cookies. You have the choice of clicking on "refuse all", "accept all" and continuing your browsing on the Website, or "personalise" the use of cookies requiring your consent.

When you click on "personalise", a second banner is displayed. You have the choice of refusing (default cursor) or accepting (opt-in) the use of statistical cookies by clicking on the cursor. Once you have made your choice, you must confirm it by clicking on "Save". Even if you refuse, you can continue to browse the Website.

You can change your settings at any time and revoke your consent by clicking on "Cookies" at the bottom of the Website page.

With regard to the buttons (external links) at the bottom of the Website page which allow you to be redirected to the LinkedIn, X, Facebook and Instagram pages of 99 AVOCATS when you click on them, these do not generate cookies on the Website:

• https://www.linkedin.com/compa...
• https://x.com/99avocats_mc
• https://www.facebook.com/giacc...
• https://www.instagram.com/giac...

99 AVOCATS declines all responsibility for the possible use of cookies by these third parties when you have clicked on these links and are redirected to their websites, as these third parties are responsible for the cookies they deposit on your terminal. Their terms and conditions relating to cookies apply. You are advised to check the cookie policy of these third-party sites:

• LinkedIn: https://www.linkedin.com/legal...
• X: https://x.com/en/privacy
• Facebook: https://www.facebook.com/priva...
• Instagram: https://www.facebook.com/priva...

You can also express your choices regarding cookies by using the appropriate settings in your web browser. You can choose to refuse cookies being stored on your terminal. The way to delete cookies and adjust settings varies from one browser to another. For the most common browsers Mozilla Firefox, Google Chrome, Microsoft Edge, Safari and Opera, simply press the [Ctrl] + [Shift] + [Delete] keys to quickly access the cookie settings and make individual adjustments. To find out more, click on the following links:

• Chrome: https://support.google.com/chr...
• Firefox: https://support.mozilla.org/en...
• Safari: https://support.apple.com/en-g...
• Microsoft Edge: https://support.microsoft.com/...
• Opera: https://help.opera.com/en/late...

10.1 Contact form

The mandatory information on the "Contact us" form, marked with an asterisk (*), enables us to process your request. Your consent to 99 AVOCATS contacting you to respond to your request is obtained via a positive action (opt-in), by ticking the box "I agree to be contacted following my message". Once your request has been submitted (click on ‘send’), you will be notified of the success or failure of your request by a confirmation or error message.

The length of time we keep the data you send via the form varies depending on whether or not you are a client of 99 AVOCATS (See 6. Data retention period).

10.2 Unsolicited application

When, on your own initiative, you send your application by e-mail to the address candidature@99avocats.com in the "Contact us (unsolicited application)" section of the Website, you spontaneously communicate documents and personal information about yourself (CV, covering letter) to support your application, and by doing so, you express your consent to these being consulted to assess your professional skills and kept for the time necessary for the assessment procedure and, where applicable, the recruitment procedure.

By sending your application, you also give your consent for 99 AVOCATS to keep your data in its CV library in order to be contacted in the event of new opportunities. This is without prejudice to your right to object at any time, by post or electronically (see 6. Data retention period).

99 AVOCATS uses the Mailjet emailing tool (AFAQ certification issued by AFNOR Certification) which enables it to manage your requests to subscribe to and unsubscribe from the 99 AVOCATS newsletter mailing list, to send subscribers legal publications (texts published in the Journal de Monaco, legislative works, Website publications, etc.) and information on the life of the law firm, and to monitor performance (sending statistics - undelivered emails, unsubscribes, spam, blocking -, openings, clicks). To find out more about Mailjet's confidentiality policy, click on the following link: https://www.mailjet.com/legal/...

You express your consent to subscribe to the 99 AVOCATS legal newsletter mailing list after entering your e-mail address in the "Subscribe to our Newsletter" field and clicking on the arrow to send your request. A window will appear informing you of the success or failure of your registration.

The newsletter email contains a clear and concise unsubscribe link allowing you to easily refuse to receive future communications at any time.

99 AVOCATS reserves the right to modify the content of this Information Notice relating to the protection of personal data at any time, without prior notice, according to the evolution of the legal and regulatory context.

You are therefore invited to consult it regularly.

In the event of any dispute, the French version shall prevail.

Last update: 26 February 2025