Privacy Policy for Data Subjects in the European Countries

Introduction

Welcome to Anderson Mori & Tomotsune group ("AMT Group")'s Privacy Policy (the “Policy”).

AMT Group respects your privacy and is committed to protecting your Personal Data. We comply with the European Data Protection regulation (EU 2016/679) and the local laws applicable in the various countries in which we operate, including the GDPR/UK Data Protection Act 2018 .

This Policy will inform you as to how we look after your Personal Data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this Policy by referring to Section 10 Glossary below.

1.Important information and who we are

a) Purpose of this Policy
AMT Group is an international law firm with its headquarters in Tokyo. Anderson Mori & Tomotsune UK Limited (“AMT London”) or Anderson Mori & Tomotsune EU (“AMT Brussels”), as applicable, controls the collection and processing of any Personal Data that you provide to us in relation to this website. Where services are provided to you by other entities within the AMT Group, the entity providing the service will be responsible for your Personal Data. This notice applies to all such entities.
This Policy aims to give you information on how AMT Group collects and processes your Personal Data through your use of this website.
This website is not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them.
b) Controller
AMT Group is made up of different legal entities, details of which can be found here . This Policy is issued on behalf of the AMT Group. As such, when we mention “AMT Group”, “we”, “us” or “our” in this Policy, we are referring to the relevant company in the AMT Group responsible for processing your data.
In relation to the data subjects in the UK and EU, AMT London or AMT Brussels, as applicable, is the controller and responsible for this website.
c) Changes to the Policy
We keep our Policy under regular review. This version was last updated in May 2025. Historic versions can be obtained by contacting us.
It is important that the Personal Data we hold about you is accurate and current.

2.The data we collect from you

a) Types of Personal Data collected
The Personal Data that we collect, and how we collect it, depends upon how you interact with us. Categories of Personal Data that we collect include:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, identification papers (e.g., copy of passport), delivery address, email address and telephone numbers.
- Biographical Information such as job title, employer, photograph and video or audio content including you.
- Billing and Financial Data includes bank account, billing address and payment information such details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services, or, alternatively, details of services that we have purchased from you.
- Marketing and Communication Data includes your preferences in receiving marketing from us and our third parties and your communication preferences, your interests, preferences, feedback and survey responses.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Policy.
This website may include links to Third-Party Links, such as websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
b) If you fail to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data upon request, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3.How is your Personal Data collected?

Methods of collection of Personal Data
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity Data, Contact Data, Biographical Information, or Billing and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
  - apply for our legal services or for a job with us;
  - subscribe to our publications;
  - request marketing to be sent to you;
  - enter a competition, promotion or survey;
  - register for one of our events;
  - visit one of our buildings subject to necessary security checks (or when we collect your image via CCTV); or
  - give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
- Third parties or publicly available sources. Most of the Personal Data that we collect about you will be information that you provide to us voluntarily. In some circumstances we may also receive information from:
  - other AMT entities;
  - our clients, when we handle Personal Data on their behalf;
  - legal and regulatory bodies;
  - third party Processors;
  - credit reference agencies;
  - our external advisors, such as accountants, auditors, lawyers and other outside professional advisors to AMT Group, subject to binding contractual obligations of confidentiality;
  - any purchaser of our business;
  - any relevant third party provider, where our Sites and our Apps use third party advertising, plugins or content;
  - other companies providing services to us.
- Some of these third-party sources may include publicly available sources of information.
- We will receive Personal Data about you from various third parties and public sources as set out below:
  - Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK, European authorities that provide company register information such as European Business Registry Association and Commercial Registration of Japan.

4.How we use your Personal Data?

a) Legal basis for using your Personal Data
We are allowed to use your Personal Data under the following circumstances:
- We have obtained your prior consent for a specific purpose;
- Where we need to perform the contract, we are about to enter into or have entered into with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, fundamental rights, or freedoms;
- Where we need to comply with a legal obligation.
- We only process Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) where the processing is necessary, for example to provide legal advice, comply with our legal or regulatory obligations, for example, our professional obligations and in the field of employment and social security law, or to establish, exercise or defend legal claims.
- We do not conduct any automated decision-making in the processing of your Personal Data that results in legal effects concerning you or significantly affects you in a similar manner.
Please refer to Section 10 Glossary to find out more about the types of lawful basis that we will rely on to process your Personal Data.

b) Purposes for which we will use your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal Data for more than one legal basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Legal basis for processing including basis of legitimate interest
To register you as a new client	(a) Identity Data (b) Contact Data	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity Data (b) Contact Data (c) Billing and Financial Data (d) Marketing and Communication Data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Policy (b) Asking you to leave a review or take a survey	(a) Identity Data (b) Contact Data (c) Biographical Information (d) Marketing and Communications Data	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To communicate with you via any means (including via email, telephone, text message, social media, post or in person) news items and other information in which you may be interested in, subject to your prior consent; maintaining and updating your contact information where appropriate; and recording telephone calls, meetings, depositions, and other interactions in which you are involved, in accordance with applicable law.	(a) Identity Data (b) Contact Data (c) Biographical Information (d) Marketing and Communication Data	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Identity Data (b) Contact Data (c) Technical Data	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity Data (b) Contact Data (c) Biographical Information (d) Usage Data (e) Marketing and Communication Information (f) Technical Data	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical Data (b) Usage Data	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you for marketing purposes (that including third party marketing subject to your express opt-in consent).	(a) Identity Data (b) Contact Data (c) Technical Data (d) Usage Data (e) Biographical Information (f) Marketing and Communication Information	Necessary for our legitimate interests (to develop our products/services and grow our business)
To fulfill our regulatory and notarial compliance obligations; ‘Know Your Client’ checks; and confirm and verify your identity; use of credit reference agencies; and screen against government and/or law enforcement agency sanctions lists and other legal restrictions.	(a) Identity Data (b) Contact Data (c) Technical Data (d) Usage Data (e) Biographical Information	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation

c) Opting out
You can ask us to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a service purchase, warranty registration, product/service experience or other transactions.
d) Cookies
We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy .
e) Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.Disclosures of your Personal Data

We may share your Personal Data with the parties set out below for the purposes set out in the table “Purposes for which we will use your Personal Data” above.
Third Parties
We do not sell or otherwise disclose to third parties your personal information without your consent.
- Internal Third Parties as set out in the section 10 Glossary.
- External Third Parties as set out in the section 10 Glossary.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Policy.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

6.International transfers

We share your Personal Data within the AMT Group. This will involve transferring your data outside the EU and UK.

Many of our external third parties are based outside the EU and UK so their processing of your Personal Data will involve a transfer of data outside the EU or UK.

Whenever we transfer your Personal Data out of the EU or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data.
we take measures to ensure that all recipients provide an adequate level of data protection by entering into appropriate data transfer agreements based on Standard Contractual Clauses for the EU or UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EU or UK.

7.Your legal rights

a) Your rights regarding your Personal Data
Under applicable law, you may have a number of rights, including:
- Refuse to provide your Personal Data to us.
- Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
  - If you want us to establish the data's accuracy.
  - Where our use of the data is unlawful, but you do not want us to erase it.
  - Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  - You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Lodge a complaint with a supervisory authority.
b) Data privacy manager
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Policy. If you have any questions, comments or concerns about this Policy, including any requests to exercise any of your legal rights, please contact our data privacy manager using the details set out below:
EU
- Full name of legal entity: Anderson Mori & Tomotsune EU
- Email address: brussels[at]amt-law.com
- Postal address: 6th floor, Nordic House, Rue du Luxembourg 3, 1000 Brussels, Belgium
UK
- Full name of legal entity: Anderson Mori & Tomotsune UK Ltd
- Email address: london[at]amt-law.com
- Postal address: 3rd Floor, News Building, 3 London Bridge Street, London SE1 9SG
Only you or a person authorized by you may submit a request to exercise your rights regarding your personal information. Upon your contacting our data privacy manager, we will require you to provide satisfactory proof of your identity in order to ensure that your rights are respected and protected. This is to ensure that your Personal Data is disclosed only to you.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
In addition, you have the right to make a complaint at any time to the European Commission ( https://commission.europa.eu/index_en ) or Information Commissioner's Office (ICO), the UK regulator for data protection issues ( www.ico.org.uk ), as applicable. We would, however, appreciate the chance to deal with your concerns before you approach the relevant data protection authority, so please contact us in the first instance.

8.Data security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized or improper way altered, disclosed or destructed consistent with applicable data protection laws. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.

We will notify you and any applicable regulator of a breach where we are legally required to do so.

9.Data retention

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see Section 7. Your legal rights for further information.

In some circumstances we will anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

10.Glossary

Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.
Cookies means text files which are stored on your computer or other device when you visit our website. They allow us to distinguish you from other users of our website. This helps us to provide you with a positive experience when you browse our website and to improve our website.
External Third Parties means the following categories of entities:
- Service providers [acting as processors] based Japan who provide IT and system administration services.
- Professional advisers acting as processors including lawyers, based in Japan, Mainland China, Hong Kong, Viet Nam, Thailand, Singapore and Indonesia who provide consultancy and legal services.
- HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who may require reporting of processing activities in certain circumstances.
Internal Third Parties means other companies in the AMT Group acting as joint controllers or processors and who are based Japan, Mainland China, Hong Kong, Viet Nam, Thailand, Singapore and Indonesia and provide IT and system administration services and undertake leadership reporting.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Personal Data means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

Introduction

1.Important information and who we are

a) Purpose of this Policy

b) Controller

c) Changes to the Policy

2.The data we collect from you

a) Types of Personal Data collected

b) If you fail to provide Personal Data

3.How is your Personal Data collected?

Methods of collection of Personal Data

4.How we use your Personal Data?

a) Legal basis for using your Personal Data

b) Purposes for which we will use your Personal Data

c) Opting out

d) Cookies

e) Change of purpose

5.Disclosures of your Personal Data

Third Parties

6.International transfers

7.Your legal rights

a) Your rights regarding your Personal Data

b) Data privacy manager

8.Data security

9.Data retention

10.Glossary