We practice the laws of the British Virgin Islands and Uruguay and do not provide legal or tax advice with respect to any other jurisdiction. Specifically, we do not provide advice under United States law or the law of the State of Florida or any other State of the United States. From our office in the State of Florida, we provide only consulting services, including liaison with U.S. counsel on behalf of our clients. Our attorneys are admitted to practice law only in the jurisdiction(s) noted in their individual biographies. In addition to the above, we provide fiduciary and corporate management services through affiliated entities and/or strategic partners. In particular, we provide company management and authorized representatives services in the British Virgin Islands, certain fiduciary services in New Zealand and the United States of America (Wyoming and South Dakota) and we also have an association with a Cayman Islands law firm. This website contains much information in the form of articles of general applicability or intended as educational and introductory to various areas of the law or legal issues.

 

NONE IS LEGAL ADVICE APPLICABLE TO YOUR PARTICULAR SITUATION. NO LAWYER-CLIENT RELATIONSHIP IS CREATED BY VISITING THIS WEBSITE AND REVIEWING ANY MATERIAL ON IT. YOU ARE NOT JUSTIFIED IN RELYING ON ANY ARTICLE IN MAKING A DECISION ABOUT A SPECIFIC SITUATION; RATHER, YOU SHOULD CONSULT COMPETENT COUNSEL LICENSED IN THE RELEVANT JURISDICTION FOR LEGAL ADVICE OR REPRESENTATION. A PERSON MAY BECOME A CLIENT OF UNTITLED ONLY THROUGH A WRITTEN ENGAGEMENT LETTER BETWEEN THAT PERSON AND THE FIRM, AFTER THE FIRM HAS HAD AN OPPORTUNITY TO REVIEW ITS DATABASE TO ASSURE NO CONFLICT OF INTEREST EXISTS AND AFTER DECIDING WHETHER THE REPRESENTATION IS APPROPRIATE. Under some interpretations of the legal ethics rules, some material in this website should be considered advertising. The hiring of a lawyer is an important decision that should not be based solely upon the information included on this website. Before you decide to hire a lawyer, please ask us to send you written information about our qualifications and experience. The firm’s standard terms and conditions of engagement which apply to all work carried out in the absence of alternative written agreement are available upon request.

 

Online Privacy Policy and Cookies Policy

We take seriously our commitment to safeguard the privacy of confidential and personal information, including personal data relating to individuals who may be clients, staff, lawyers, job applicants, website visitors, or others inside and outside the firm. This online privacy policy and cookies policy (the “Privacy Policy”) describes how we handle and protect your personal data, including what information we collect, why, and what we do with it. This Privacy Policy applies to all Untitled websites, social media sites, mobile apps (if any), as well as electronic communications such as email messages we send you. This Privacy Policy is separate and in addition to client confidentiality obligations we may owe you – please refer to the terms and conditions applicable to your engagement for further details.

 

Who decides why and how we process your personal data?

Untitled determines why and how we process your personal data. Untitled consists of various entities (the “Untitled Entities”) established in a variety of jurisdictions (such as the British Virgin Islands, Uruguay, New Zealand and the United States). In each case, your personal data will be controlled by the Untitled Entity which you have given instructions to, or with which you are otherwise dealing with or receiving communications from or the Untitled Entity which provides services to a third party which you are associated with, for example a company of which you are a director or shareholder.

 

What personal data might we collect?

We collect different types of personal data for different reasons – this may include:

• Contact information: Information such as your name, job title, postal address, home address where you provide this to us, business address, telephone number, mobile number, fax number and email address.
• Payment data: Data necessary for us to process payments and implement fraud prevention measures, including credit/debit card numbers, security code numbers and other such relevant billing details.
• Business details: Business information which we necessarily process as part of our instructions or projects we are involved in or otherwise provided by you voluntarily.
• Compliance details: Information we are legally required to collect for compliance purposes, such as ‘know your client’ information, details relevant to international sanctions and restrictive measures and information about relevant and significant litigation, which may impact our ability to act.
• Preferences: Information about your preferences, where it is relevant to the services we provide.
• Platform information: Your password and other related log-in details for platforms maintained by Untitled, where you may have access.
• Publicly available information: Information collected from publicly available resources, including but not limited to information collected from databases we use to carry out compliance checks or credit rating agencies.
• Statutory Register Information: Information about you on account of an interest or office you may hold in or certain relationships you may have with a corporate entity, partnership, trust, or other vehicle to which we provide services (each such entity, a Third-Party Entity).
• Details for events: In some cases, we may collect information about you, which may include sensitive information in relation to your health, for the purpose of tailoring our events to your needs. The processing of such data is based entirely on your consent – in the event that you do not want us to maintain such data, we may not be able to take the necessary precautions.

 

When do we collect your personal data? 

We may collect personal data about you in various cases, such as for example:

• When you or your organization seek our services – e.g. legal advice or our legal liaison, consulting or fiduciary services – or use any of our online client services;
• When you or your organization make an enquiry through our website, in person, over email or over the telephone;
• When you attend an Untitled seminar or other events we may organize, or sign up to receive communications from us;
• When a Third-Party Entity engages us to provide services and you hold an office or an interest in or have certain relationships with that Third-Party Entity; or
• When you or your organization provide services to us, or otherwise offer to do so.

In some circumstances, we may collect personal data about you from third parties – for example, we may collect personal data from your organization, other organizations with whom you have dealings including Third-Party Entities, government agencies, a credit reporting agency, an information or service provider or from a publicly available record.

 

How will we use your personal data? 

We may use your personal data for the following purposes (the “Permitted Purposes”):

• To provide legal advice or other services or things you may have requested;
• To manage and administer your or your organization’s business relationship with us, including processing payments, accounting, auditing, billing and collection or support services;
• For compliance with our legal obligations (such as record keeping obligations), compliance screening or recording obligations (such as under antitrust laws, export controls, trade sanction and embargo laws, for anti-money laundering, financial and credit check and fraud and crime prevention and detection purposes);
• To provide updates, reminders, requests and directions relevant to the role or capacity in which you are interested in a Third-Party Entity;
• To analyze and improve our services and communications to you;
• To protect the security of and managing access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and to detect security threats, fraud or other criminal or malicious activities;
• For insurance purposes;
• To monitor and assess compliance with our policies and standards;
• To identify persons authorised to trade on behalf of our clients, customers, suppliers and/or service providers;
• To comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory, law enforcement and tax reporting bodies;
• On instruction or request from your organization or a relevant Third-Party Entity;
• To communicate with you through the channels you have approved to keep you up to date on the latest legal developments, announcements, and other information about our services, products and technologies – including client briefings, newsletters and other information – as well as events we may organize;
• To comply with court orders and exercises and/or defend our legal rights; and/or
• For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us.

 

Where you have expressly given us your consent, we may process your personal data also for the following purposes:

 

• For customer surveys, marketing campaigns, market analysis, sweepstakes, contests or other promotional activities or events; or
• To collect information about your preferences to create a user profile to personalize and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).

 

You will always have the opportunity to opt out of receiving such communications at any time.

 

How will we share your personal data?

We may share your personal data in the following circumstances:

• We may share your personal data between the Untitled Entities on a confidential basis where this is required for the purpose of providing legal advice or other products and services, as well as for administrative, billing and other business purposes;
• If you are an Untitled client, or you are otherwise contracted by, are an agent of, or otherwise represent an Untitled client, we may disclose your personal data to:
• Other legal specialists (including mediators), consultants or experts engaged in your matter; or
• Law firms for the purpose of obtaining legal advice on your behalf in jurisdictions where we do not practice, as may be relevant;
• If we have collected your personal data in the course of providing legal services to any of our clients, we may disclose it to that client, and where permitted by law to others for the purpose of providing those services;
• We may disclose your contact details on a confidential basis to third parties for the purposes of collecting your feedback on the firm’s service provision, to help us measure our performance and to improve and promote our services;
• We may share your personal data with companies providing services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such personal data is shared;
• We may share your personal data with any third party to whom we assign or novate any of our rights or obligations;
• We may share your personal data with courts, law enforcement authorities, regulators or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process;
• We may also instruct service providers within or outside Untitled, domestically or abroad, e.g. shared service centers, to process personal data for the Permitted Purposes on our behalf and in accordance with our instructions only. Untitled will retain control over and will remain fully responsible for your personal data and will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers;
• We may also use aggregated personal data and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.

 

We will otherwise only disclose your personal data when you direct us or give us permission to do so, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.

 

Can you refuse to share your personal data with us? 

In general, we receive your personal data where you provide this on a voluntary basis, and there will typically be no detrimental effect for you if you wish not to provide this or otherwise withhold your consent for it to be processed. However, there are certain cases where we will unfortunately be unable to act without receiving such data, for example where we need to carry out legally required compliance screening or require such data to process your instructions or orders, or otherwise to provide you with our online services or communications. Where it is not possible for us to provide you with what you request without the relevant personal data, we will let you know accordingly.

 

How do we keep your personal data safe? 

We take appropriate technical and organizational measures to keep your personal data confidential and secure, in accordance with our internal policies and procedures regarding storage of, access to and disclosure of personal data. We may keep your personal data in our electronic systems, in the systems of our contractors, or in paper files.

 

Personal data we receive from you about other people

Where you provide us with the personal data of other people, such as your employees, directors of your companies, or other persons you may have dealings with, you must ensure that you are entitled to disclose that personal data to us and furthermore that, without being required to take further steps, we can collect, use and disclose that data in the manner described in this policy. More specifically, you must ensure that the individual whose personal data you are sharing with us is aware of the matters discussed in this Privacy Policy, as these are relevant to that individual, including our identity, how to get in touch with us, the purposes for which we collect data, our disclosure practices, and the rights of the individual in relation to our holding of the data.

 

Transfers of personal data abroad

Untitled is active across the world – this means that we may transfer your personal data abroad if required to do so for the Permitted Purposes. In certain cases, this may include transferring data to countries which do not offer the same level of protection as the laws of your country.

 

How long do we keep your personal data? 

We delete your personal data once it is no longer reasonably necessary for us to keep it for the Permitted Purposes. Importantly, Untitled will keep your personal data as necessary for the purposes of defending or making legal claims until the end of the period during which we may retain the data and otherwise until the settlement of any such claims, as relevant.

 

What rights do you have? 

Subject to certain conditions under applicable legislation, you have the right to:

• request a copy of the personal data which we hold about you;
• have any inaccurate data we hold about you corrected;
• object or restrict our use of your personal data; and/or
• submit a complaint if you have concerns about the way in which we are handling your data.

To do any of the above, please contact us at emilia.roggiero@untitled-slc.com. To enable us to process your request, we may require that you provide us with proof of your identity, such as by providing us with a copy of a valid form of identification – this is to ensure that we appropriately protect the personal data we hold from unauthorized access requests and comply with our security obligations. We may charge you a reasonable administrative fee for any unreasonable or excessive requests we may receive, and for any additional copies of the data you may request. In relation to complaints, we will promptly respond to your requests and complaints. In the event that you are unhappy with our response, you may submit a complaint to the relevant privacy regulator. We can provide you with the details of the relevant regulator upon request.

 

Correcting and updating your personal data

Where any personal data you have provided us with has changed, or where you believe the personal data, we hold is inaccurate, please let us know at emilia.roggiero@untitled-slc.com. In addition, please note that if you hold an office or are interested in or have certain relationships with a Third-Party Entity to which we provide services, you and/or the Third Party Entity may have a contractual or legal obligation to notify us of any change within a prescribed time period. We cannot be responsible for any loss that may arise due to us having any inaccurate, incomplete, inauthentic, or otherwise deficient personal data which you or a Third-Party Entity have provided to us. Please also let us know if you wish to withdraw any request.

 

Cookies

Like many websites, our websites use cookies to remember your preferences and generally help to improve your online experience, as well as to provide us with anonymous information to check the usefulness of our websites and help us improve them. A Cookie is a text file containing small amounts of information which is downloaded to your device when you visit our website (untitled-slc.com). The Cookie is sent back to our website on each subsequent visit allowing us, the website owner, to better understand how our visitors are consuming our content through analytics so that we can enhance that content and – as stated above – generally improve the visitor’s experience. Cookies may be placed on your computer and/or mobile device by both us and by third parties with whom we have a relationship, such as web analytics services. You may refuse cookies by activating the setting on your browser. However, if you select this setting, you may not have the same user experience. To learn more about how to manage cookies, visit www.allaboutcookies.org/manage-cookies/ (please note that this website is not connected to us, and we are not responsible for its content).

 

Web Beacons

On certain web pages or in emails we send you, we may utilize a technology called a “web beacon”. We may use web beacons to help determine which email messages sent by us were opened and whether a message was acted upon. Web beacons also help analyze the effectiveness of websites by measuring the number of visitors to a site or how many visitors clicked on key elements of a site.

 

Social Plugins

Untitled uses social sharing widgets on our websites that enable interaction with social networks. Through these platforms and features, we may receive some personally identifiable information about you, and this Privacy Policy applies to that information as well. In addition, third party social networking platforms and blogging platforms have their own privacy policies which explain how the third parties that provide them will use and protect your information, and we encourage you to read them.

 

Changes to our Privacy Policy

This Privacy Policy was last updated on 1 October 2021. We have the right to update the contents of this Privacy Policy from time to time to reflect any changes in the way in which we process your personal data or to reflect legal requirements as these may change. In case of updates, we will post the revised Privacy Policy on our website. Changes will take effect as soon as the revised version is made available on our websites.

 

 

Terms of Use

Copyright 

All information on this website or any of our apps, including but not limited to designs, logos, text, graphics, information architecture, coding, documents, and information (content), is the property of Untitled. The copyright, trademarks and other intellectual property in the content are owned by Untitled or its licensors. You may read the content and make copies for your own personal use. You may also download/print documents and information from this website for the purposes of reading it or circulation within your organization so long as any copies you make are complete, unaltered and are properly attributed to Untitled. If you wish to use the information for any other purpose, you must obtain our prior written consent. If you wish to ask for such permission or to obtain further information, please contact emilia.roggiero@untitled-slc.com. 

 

Linkin

You may not create any electronic links to this website without our prior consent. Please send any such requests to emilia.roggiero@untitled-slc.com. The linked sites included in this website are not under the control of Untitled and are included for convenience only. We do not endorse or accept any responsibility for any content on or any software downloaded from any website linked to this website. The inclusion of any link does not imply an endorsement by Untitled of the linked website nor a relationship between us and the organization providing the linked website.

Disclaimer. The content of this website and our apps is for general information purposes only for the clients and professional contacts of Untitled. No other use of the content is permitted without the prior written consent of Untitled. The content does not purport to be comprehensive, nor does it constitute legal advice and it should not be relied on or treated as a substitute for legal advice. While every effort has been made to ensure that the information contained on this website is complete and accurate at the date of publication, Untitled gives no warranty as to the adequacy, accuracy or completeness of the information contained on this website, and accepts no liability arising from any inaccuracy or omissions in or the use of or reliance on the information contained in this website. Untitled accepts no responsibility for any loss of whatsoever sort and howsoever arising which might occur from reliance by any person on the content of this website. You should take formal legal advice on any particular matter from a competent attorney licensed in the relevant jurisdiction. If you require legal advice on a matter, please contact your usual contact at Untitled or email emilia.roggiero@untitled-slc.com

 

Links to Other Websites 

This website contains links to other websites. Untitled is not responsible for the content, accuracy or opinions expressed in such websites, and such websites are not investigated, monitored, or checked for accuracy or completeness by Untitled. The firm does not necessarily endorse, and is not responsible for, any third-party content that may be accessed through this website. Untitled provides these links to you only as a convenience and the inclusion of any link does not imply recommendation, approval or endorsement by our firm.