Privacy Policy

1. Introduction

LB Consult (hereinafter the "Firm", "LB Consult", "we", "us" or "our") respects your right to privacy and is committed to protecting personal data in accordance with applicable Ukrainian legislation and, where applicable, international data protection requirements.

This Privacy Policy (the "Policy") explains what personal data we collect, how we obtain it, the purposes and legal grounds for its processing, how we protect it, and the rights available to individuals whose personal data we process.

This Policy applies to individuals who visit or use our website at www.lbconsult.com.ua (the "Website"), contact the Firm, subscribe to our publications, register for events, apply for employment or otherwise interact with us through the Website.

This Policy should be read together with applicable engagement agreements, confidentiality arrangements and other documents governing the provision of legal services.

Important distinction concerning advocate-client secrecy

This Policy does not replace, restrict or waive the statutory protection of advocate-client secrecy (Ukrainian: «адвокатська таємниця») established under the Law of Ukraine No. 5076-VI "On the Bar and Practice of Law".

Information protected by advocate-client secrecy is subject to the specific legal and professional requirements applicable to advocacy activities. The provisions of this Policy concerning personal data processing do not diminish those protections.

2. Personal Data We Collect

Depending on how you interact with the Firm, we may collect and process the following categories of personal data.

2.1. Website visitors

When you visit the Website, we may automatically collect certain technical information, including:

• Internet Protocol (IP) address;
• date and time of access;
• browser type and version;
• operating system and device information;
• language and regional settings;
• pages visited and time spent on the Website;
• referring website or source;
• technical logs and information concerning interactions with the Website.

2.2. Individuals contacting the Firm

If you contact us through the Website, by email or by other communication channels, we may collect:

• full name;
• email address;
• telephone number;
• company or organisation name;
• professional position;
• subject and content of your enquiry;
• other information voluntarily provided by you.

2.3. Prospective and existing clients

Where you request or receive legal services, we may process information necessary for preliminary assessment, client identification, conflict-of-interest checks and the provision of legal assistance. Depending on the nature of the matter, this may include:

• personal identification and contact information;
• professional and business information;
• information about relevant legal matters, disputes and transactions;
• information concerning counterparties and other persons involved in a matter;
• documents and correspondence provided to the Firm;
• information necessary to comply with applicable legal and professional requirements.

Certain information received in connection with advocacy activities may constitute advocate-client secrecy and is protected accordingly under Ukrainian law.

2.4. Recruitment applicants

If you apply for a position at the Firm, we may collect:

• full name and contact details;
• curriculum vitae and cover letter;
• education and professional qualifications;
• employment history and professional experience;
• references, where provided or lawfully obtained;
• information concerning your suitability for the relevant position;
• other information voluntarily submitted as part of the recruitment process.

2.5. Newsletter and marketing subscribers

If you subscribe to our newsletters, legal updates or publications, we may collect your name, email address and communication preferences.

We may also record whether newsletters have been delivered, opened or interacted with, where such tracking is used and permitted by applicable law.

2.6. Event participants

If you register for or participate in an event organised by the Firm, we may collect your name, professional position, organisation, contact details and information necessary to administer the event.

2.7. Special categories of personal data

We do not intentionally request special categories of personal data through the Website unless they are necessary for a specific lawful purpose.

If you voluntarily provide information concerning health, biometric data, criminal proceedings or other sensitive matters in connection with a legal enquiry, such information will be handled in accordance with applicable legal requirements and, where relevant, the rules governing advocate-client secrecy.

3. How We Collect Personal Data

We may obtain personal data through the following channels:

• directly from you when you complete a contact form or communicate with us;
• when you subscribe to newsletters or legal publications;
• when you apply for employment;
• when you register for an event;
• when you request information about our legal services;
• automatically through cookies, server logs and similar technologies, where applicable;
• from publicly available sources and other lawful sources, where necessary for client identification, conflict-of-interest checks or the provision of legal services;
• from third parties, where permitted by law and necessary for the relevant purpose.

Providing personal data through the Website is generally voluntary. However, certain information may be necessary for us to respond to your enquiry or provide a requested service. If you choose not to provide the information required for a particular purpose, we may be unable to process your request.

4. Purposes of Personal Data Processing

We process personal data for the following purposes:

• to respond to enquiries and requests submitted through the Website;
• to communicate with prospective and existing clients;
• to assess requests for legal assistance and determine whether the Firm can accept an engagement;
• to conduct conflict-of-interest checks;
• to provide legal services and manage professional relationships;
• to comply with applicable Ukrainian legislation and professional obligations;
• to administer recruitment and evaluate employment applications;
• to distribute newsletters, legal updates and publications, where permitted;
• to organise events, seminars and professional activities;
• to administer and improve the Website;
• to analyse Website performance and user experience, where permitted;
• to protect the Firm's legal rights, property, systems and legitimate interests;
• to prevent fraud, unauthorised access and misuse of the Website;
• to establish, exercise or defend legal claims;
• to comply with lawful requests from competent public authorities.

We will not use personal data for purposes incompatible with the purposes for which it was collected unless permitted or required by applicable law.

5. Legal Grounds for Processing Personal Data

The Firm processes personal data in accordance with the Law of Ukraine No. 2297-VI "On Personal Data Protection" and other applicable legislation. Depending on the circumstances, the grounds for processing may include:

• your voluntary consent to the processing of personal data;
• the necessity of processing in connection with the conclusion or performance of an agreement;
• the necessity of processing to comply with legal obligations applicable to the Firm;
• the exercise of rights and performance of obligations arising from applicable Ukrainian legislation governing advocacy activities;
• the protection of the Firm's legitimate interests, provided that such processing is lawful and does not unlawfully prejudice the rights and freedoms of the relevant individual;
• other grounds expressly permitted by applicable legislation.

Where processing is based on consent, you may withdraw that consent, subject to applicable legal requirements. Withdrawal does not affect the lawfulness of processing carried out before withdrawal or processing based on another applicable legal ground.

6. Advocate-Client Secrecy and Professional Confidentiality

6.1. Legal framework

LB Consult is a registered Advocate Bureau (Адвокатське бюро) operating under Article 14 of the Law of Ukraine No. 5076-VI "On the Bar and Practice of Law".

The Firm conducts advocacy activities in accordance with Ukrainian legislation, including the statutory requirements concerning advocate-client secrecy, professional independence, confidentiality and the prevention of conflicts of interest.

The Firm recognises and strictly observes the principle of advocate-client secrecy (Ukrainian: «адвокатська таємниця»), primarily governed by Articles 21, 22 and 23 of the Law of Ukraine "On the Bar and Practice of Law", together with the applicable Rules of Advocate Ethics.

6.2. Scope of advocate-client secrecy

In accordance with Article 22 of the Law, advocate-client secrecy includes information concerning a client that becomes known to an advocate, an advocate's assistant, an advocate's trainee or a person employed by an advocate, an advocate bureau or an advocate association in connection with the provision of legal assistance. Such information includes, without limitation:

• information concerning the identity, personal circumstances, activities and affairs of a client;
• the matters on which a person approached an advocate, advocate bureau or advocate association;
• information provided in connection with the provision of legal assistance;
• the content of legal advice, consultations, recommendations and explanations;
• documents prepared, received or reviewed by an advocate in connection with professional activities;
• correspondence and communications between an advocate and a client;
• case files, evidence, legal opinions and other professional materials;
• information stored electronically or on other information media;
• other information and documents obtained in connection with advocacy activities.

The statutory protection also applies in the circumstances expressly established by Article 22, including where a person approaches an advocate, advocate bureau or advocate association and is refused an agreement on grounds provided by law.

6.3. Duty of confidentiality

The Firm ensures that advocates and other persons subject to applicable statutory or contractual confidentiality obligations protect confidential information from unauthorised disclosure, access or use.

Under Article 10 of the Rules of Advocate Ethics, the professional duty of confidentiality is not limited in time. This obligation continues after the completion or termination of a legal engagement and, where applicable, after the termination of employment or other professional relationships.

6.4. Disclosure of protected information

Information constituting advocate-client secrecy shall not be disclosed except in circumstances permitted by Ukrainian legislation and applicable professional ethical rules.

The Firm will respect the statutory protections governing such information and will not treat ordinary consent to Website data processing as a general waiver of advocate-client secrecy.

Where disclosure is legally permitted or required, the Firm will limit disclosure to the extent legally justified and necessary.

6.5. Statutory guarantees

The Firm recognises the guarantees of advocacy activities established by Article 23 of the Law of Ukraine "On the Bar and Practice of Law", including applicable safeguards concerning professional communications, documents and information protected by advocate-client secrecy.

6.6. Electronic information and document security

The Firm applies appropriate organisational and technical measures to protect electronic correspondence, digital documents, databases, case files and other confidential materials.

Access is restricted to authorised persons who require the relevant information for legitimate professional purposes.

6.7. Website enquiries

Information submitted through the Website is handled confidentially.

Where information becomes subject to the statutory regime of advocate-client secrecy, it will receive the protection required by Ukrainian law, including, where applicable, before a formal legal services agreement has been concluded.

Submitting information through the Website does not, by itself, establish an attorney-client relationship or guarantee acceptance of a legal engagement.

We recommend that you avoid sending extensive confidential documents or unnecessary sensitive information through general Website contact forms before appropriate communication arrangements have been established.

6.8. Status of LB Consult

LB Consult Advocate Bureau, its advocates and other persons covered by Article 22 of the Law are subject to the statutory obligations concerning advocate-client secrecy.

Nothing in this Policy shall be interpreted as limiting, waiving or replacing the statutory protections afforded to advocate-client secrecy under Ukrainian law.

7. Conflict of Interest and Client Acceptance

7.1. Conflict-of-interest checks

The Firm is committed to identifying, preventing and managing conflicts of interest in accordance with applicable Ukrainian legislation, the Rules of Advocate Ethics and its internal professional procedures.

Before accepting an engagement or providing legal services, the Firm may conduct conflict-of-interest checks using information provided by prospective clients and other lawfully available sources.

Such checks may involve information relating to prospective, existing and former clients, their affiliates, counterparties, representatives and other persons involved in the relevant matter.

7.2. Refusal or termination of an engagement

The Firm reserves the right to decline an engagement, or to take other legally permissible measures concerning an existing engagement, where:

• a conflict of interest exists or may arise under applicable professional rules;
• the Firm is already representing another client whose interests conflict with those of the prospective client;
• accepting or continuing the engagement would violate applicable legislation or professional ethical obligations;
• the Firm cannot act independently and in accordance with its professional obligations;
• other legal or professional grounds for refusal or termination exist.

Any decision concerning an existing engagement will be made in accordance with applicable law, professional rules and the relevant engagement agreement.

7.3. Confidentiality of prospective client information

Information received from a prospective client during preliminary enquiries or conflict-of-interest verification will be treated as confidential.

Where the statutory requirements are satisfied, such information will also be protected by advocate-client secrecy, including in circumstances where the Firm declines to accept the engagement.

The Firm will not use information received from a prospective client for the benefit of another client or a third party in circumstances prohibited by applicable law or professional ethical rules.

7.4. No automatic attorney-client relationship

Submitting an enquiry, providing documents or information, requesting a consultation or communicating with the Firm does not, by itself:

• establish an attorney-client relationship;
• constitute acceptance of a legal engagement;
• create an obligation for the Firm to represent you;
• guarantee that the Firm will provide legal advice or take any particular action.

A professional relationship is established in accordance with applicable Ukrainian legislation and the relevant arrangements for accepting and documenting the legal engagement. Until acceptance is confirmed, you should not assume that the Firm has agreed to represent you or act on your behalf.

7.5. Retention of conflict-check information

The Firm may retain limited information received during preliminary enquiries where necessary to document conflict-of-interest checks, comply with professional obligations, protect legitimate interests or establish, exercise or defend legal claims.

Such information will be accessible only to authorised persons and processed in accordance with applicable data protection legislation and professional confidentiality requirements.

8. Cookies and Similar Technologies

The Website may use cookies and similar technologies to ensure its proper operation, improve functionality and analyse Website usage. Cookies are small text files stored on your device through your browser.

8.1. Necessary cookies

Necessary cookies support the technical operation and security of the Website, including navigation and essential functionality. These cookies may be used without consent where permitted by applicable law.

8.2. Optional cookies

The Website may use optional cookies for analytics, performance measurement, personalisation or marketing. Such cookies will be activated only where the required consent has been obtained.

8.3. Analytics

If the Firm uses third-party analytics services, such as Google Analytics, those services may collect information about Website visits, pages viewed, browsing activity and technical characteristics of devices.

The use of such services will be subject to applicable consent requirements and the relevant provider's privacy documentation (for Google, see the Google Privacy Policy).

8.4. Cookie management

You may manage or delete cookies through your browser settings and, where available, through the Website's cookie preference mechanism. Disabling certain cookies may affect the functionality of the Website.

Additional information about cookies and available preferences may be provided through the Website's cookie notice.

9. Disclosure of Personal Data to Third Parties

The Firm may disclose personal data to third parties where necessary and lawful, including:

• website hosting and IT service providers;
• providers of email and communication services;
• data storage and cybersecurity providers;
• website analytics providers, where applicable;
• document processing and translation service providers;
• event organisers and service providers;
• professional advisers and consultants;
• public authorities and governmental institutions, where legally required;
• courts and other competent bodies, in circumstances permitted by law.

The Firm may also disclose personal data in connection with a restructuring, reorganisation or transfer of its business, subject to applicable legal requirements.

Where third parties process personal data on behalf of the Firm, appropriate contractual and organisational safeguards will be implemented. The Firm does not authorise service providers to use personal data for purposes unrelated to the services they provide to the Firm, except where independently permitted or required by law.

The Firm does not sell personal data.

10. International Transfers of Personal Data

In certain circumstances, the Firm may transfer personal data outside Ukraine, including where:

• a service provider stores or processes information in another country;
• an individual is located outside Ukraine;
• legal services involve international transactions or disputes;
• communication or document management services operate internationally.

Any international transfer will be carried out in accordance with applicable Ukrainian personal data protection legislation. Where required, the Firm will implement appropriate safeguards to ensure an adequate level of protection for transferred personal data.

Personal data protected by advocate-client secrecy will remain subject to applicable professional and statutory confidentiality requirements when transferred or accessed internationally.

11. Retention of Personal Data

The Firm retains personal data only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by law. Retention periods may depend on:

• the nature of the relationship with the individual;
• the purpose of processing;
• applicable legal and regulatory requirements;
• professional obligations applicable to advocates;
• the need to document conflict-of-interest checks;
• applicable limitation periods;
• the establishment, exercise or defence of legal claims.

Information relating to recruitment, newsletters, general enquiries and Website usage may be retained for different periods depending on the relevant purpose.

Information relating to legal engagements and advocate-client secrecy will be retained in accordance with applicable legislation, professional requirements and the Firm's document retention procedures.

When information is no longer required, it will be securely deleted, destroyed, anonymised or otherwise processed in accordance with applicable law.

12. Security of Personal Data

The Firm implements appropriate organisational and technical measures to protect personal data against:

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

These measures may include access controls, confidentiality obligations, secure document storage, system security measures, backups and restrictions on access to sensitive information. Access to personal data is limited to persons who require it for legitimate professional or operational purposes.

The Firm takes reasonable steps to ensure that third-party service providers processing personal data on its behalf maintain appropriate security standards. However, no method of electronic transmission or storage can be guaranteed to be completely secure.

13. Your Data Protection Rights

Subject to the conditions and limitations established by applicable Ukrainian legislation, you may have the right to:

• know the sources of collection, the location of your personal data and the purpose of its processing;
• receive information about the conditions of access to your personal data;
• access your personal data;
• receive information about whether your personal data is being processed;
• request correction or updating of inaccurate or outdated personal data;
• request deletion or destruction of personal data where legally justified;
• object to the processing of personal data in circumstances provided by law;
• withdraw consent where processing is based on consent;
• lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights or a court, as appropriate;
• exercise other rights provided by applicable Ukrainian legislation.

These rights are subject to applicable statutory exceptions and limitations, including obligations concerning advocate-client secrecy, professional duties and the rights of third parties.

A request to delete personal data does not automatically require the Firm to destroy information that must lawfully be retained or that is protected under applicable professional and legal obligations.

14. Exercise of Your Rights

To exercise your data protection rights or submit a question concerning this Policy, please contact the Firm using the contact details provided in Section 16.

Your request should identify you sufficiently for the Firm to verify your identity and understand the nature of the request. The Firm may request additional information where reasonably necessary to verify your identity or clarify your request.

Requests will be reviewed and handled within the time limits and in accordance with the procedures established by applicable Ukrainian legislation.

Please note that certain information may be withheld where disclosure would violate advocate-client secrecy, prejudice the rights of another person or be prohibited by law.

15. Third-Party Websites

The Website may contain links to third-party websites, services or online resources. The Firm is not responsible for the privacy practices, security or content of third-party websites.

We recommend reviewing the privacy policies of those websites before providing them with personal data.

16. Data Controller and Contact Information

The data controller responsible for personal data processed in connection with the Website is:

LB CONSULT
Registered legal name: LAW BUREAU "SANDULIEIEVA LB "CONSULT"
Responsible person: Victoria Sanduleeva, Managing Partner
Legal address: 10V/38 O. Arhipenko Street, Kyiv, 04211, Ukraine

Website: www.lbconsult.com.ua
Email: info@lbconsult.com.ua
Telephone: +380 99 032 2456 (Ukraine), +1 587 777 0671 (US / Canada)

For questions concerning personal data protection, privacy rights or this Policy, please contact the Firm using the above details.

For matters concerning advocate-client secrecy, please identify the relevant legal engagement or communication where possible, without including unnecessary confidential information in an initial enquiry.

17. Amendments to This Policy

The Firm may amend or update this Policy from time to time to reflect changes in applicable legislation, professional requirements, business operations, Website functionality or personal data processing practices.

The updated version will be published on the Website with the relevant effective or updated date. We recommend reviewing this Policy periodically to remain informed about how the Firm processes personal data.

Where required by applicable law, the Firm will obtain renewed consent or provide additional notice concerning material changes to its processing activities.

18. Governing Law

This Policy and the processing of personal data described herein are governed by the laws of Ukraine, including:

• the Law of Ukraine No. 2297-VI "On Personal Data Protection";
• the Law of Ukraine No. 5076-VI "On the Bar and Practice of Law";
• the applicable Rules of Advocate Ethics;
• other applicable Ukrainian legislative and regulatory acts.

Any disputes arising in connection with this Policy shall be resolved in accordance with the applicable laws and jurisdictional rules of Ukraine.

LAW BUREAU "SANDULIEIEVA LB "CONSULT"
Kyiv, Ukraine