DGA Group is a global advisory firm that helps clients protect – and grow – what they have built in today’s complex business environment. We understand the challenges and opportunities in an increasingly regulated and interconnected world. Leveraging the expertise and experience of our team at Albright Stonebridge Group, a leader in global strategy and commercial diplomacy, and a deep bench of communications, public affairs, government relations and business intelligence consultants, we help clients navigate and shape global policy, reputational and financial issues.

Who we are

DGA Group is a trading name of DGA Group LLC, an independent advisory firm with a network of affiliated companies and offices, including in the United States, Belgium, China, France, Germany, India, Singapore, the United Arab Emirates, and the United Kingdom.

About this privacy notice

When a company in the DGA Group agrees to provide services to a client it will provide an engagement letter with information about any specific privacy arrangements that apply in its location. This privacy notice provides information about the arrangements that all companies in the DGA Group adhere to in collecting and using personal data from clients. When this privacy notice refers to ‘DGA’, ‘we’ or ‘us’ it means the DGA company which has an engagement letter with a client, unless explicitly stated otherwise. When this privacy notice refers to ‘you’ or ‘your’ it means an individual associated with a potential, current or former client whose personal data DGA processes.

 

How we use your personal data

We use your personal data for the following purposes:

• Service provision: providing advice and services including extranets and other technology tools;
• Business relationship: managing and administering our relationship with you, your company or organisation including keeping records about business contacts, services and payments, including so we can customise our offering for you, develop our relationship, and target our marketing and promotional campaigns;
• Communication: sending emails, newsletters and other messages to keep you informed of legal, regulatory and other business developments, market insights, and our services;
• Events: running briefings, roundtables and other events;
• Client legal compliance: client due diligence (under anti-money laundering, sanctions screening and other crime prevention and detection laws, and regulatory requirements) which may involve automated screening checks to ensure that clients and contacts are genuine and to prevent fraud or crime;
• Website monitoring: to check the website and our other technology services are being used appropriately and to optimise their functionality;
• Site security: to provide security to our offices and other premises (normally collecting your name and contact details on entry to our buildings);
• Online security: protecting our information assets and technology platforms from unauthorised access or usage and to monitor for malware and other security threats;
• Regulatory: compliance with our legal and regulatory obligations and reporting requirements;
• Managing suppliers: who deliver services to us;
• Other business purposes: to pursue the business purposes identified in the “Legitimate Interests” section of this notice.

 

 

Our reasons (also known as ‘legal basis’) for using your personal data

We will process your personal data for a number of reasons (known as a ‘legal basis’ for processing in some locations):

• you have given us consent: for example, where you explicitly request that we share marketing information about our business;
• it is necessary to comply with legal or regulatory obligations: for example, anti-money laundering and mandatory client screening checks or disclosure to law enforcement;
• it is necessary for the performance of a contract we have with you;
• it is necessary to deal with legal claims;
• it is necessary for our legitimate business interests or those of a third party: provided this does not override any interests or rights that you have as an individual. The legitimate interests that apply to our processing of your data are listed in the “Legitimate Interests” section of this notice.

 

Legitimate interestsWe have determined that the ‘legitimate interests’ legal basis applies where we use your personal data in:

• providing advisory services;
• managing our business and relationship with you or your company or organisation;
• understanding and responding to inquiries and client feedback;
• understanding how our clients use our services and websites;
• identifying what our clients want and developing our relationship with you, your company or organisation;
• improving our services and offerings;
• ensuring our systems and premises are secure;
• managing our supply chain;
• developing relationships with business partners;
• operating suppressors to exclude you from direct marketing if you unsubscribe;
• sharing data in connection with acquisitions and transfers of our business.

 

Our reasons for using ‘special category’ and criminal offence data

‘Special category’ data in the EU and certain other locations refers to sensitive data such as racial or ethnic origin, religious beliefs, or health data. Along with data about criminal convictions, additional protections apply to the processing of ‘special category’ data. We will process this type of personal data where:

• we have your explicit consent for the particular processing;
• this is necessary to protect your vital interests or those of another person, for example, in medical emergencies;
• you have manifestly made the data public, for example, where you have published it on social media;
• this is necessary to deal with legal claims: for example, involving court proceedings;
• this is necessary for substantial public interest: for example to prevent or detect unlawful acts;
• this is permitted by applicable law: outside the EU and other jurisdictions where these restrictions apply.

 

With whom do we share your data?

We share your information with others as follows

• DGA Group LLC and related legal entities: including their management, staff and contractors where necessary in order to provide advisory services;
• Suppliers: who support our business including IT and communication suppliers, outsourced business support, marketing and advertising agencies, back up and DR suppliers. Our suppliers have to meet minimum standards as to information security and they will only be provided data necessary for their function;

• Shared service centres: operated by DGA Group LLC or third parties including for client on-boarding, IT services, marketing, risk management and office support services;
• Law enforcement bodies and our regulators: or other competent authorities in accordance with legal requirements or good practice;
• Appropriate parties in the event of emergencies: in particular to protect health and safety of our clients, staff and organisations;
• Your company or organisation: in relation to us providing advisory services;
• Screening service providers: so that we can comply with legal obligations in relation to the prevention or protection of crime, ant-money laundering, sanctions screening and other required checks;
• Advertising networks and analytics service providers: to support and display ads on our website, apps and other social media tools;
• Third parties: in the context of the acquisition or transfer of any part of our business or in connection with business re-organisation;
• Other delegates: where your name will appear on the attendee list for events where you have told us you plan to attend.

 

Personal data about others

In some cases, you may provide personal data to us about other people (such as your customers, directors, officers, shareholders or beneficial owners). You must ensure that where legally required you have given those individuals an appropriate notice that you are providing their personal data to us and have a lawful basis for that disclosure to us.

 

Security

We will hold your personal data securely in line with physical, technical and administrative security measures. However, the transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal data, we cannot guarantee the security of your personal data transmitted and any transmission is at your own risk.

 

Where will your information be held?

We are a global advisory firm, and your personal data may be transferred out of your local jurisdiction or region. Data protection laws vary by country and those applicable in the USA and elsewhere are not equivalent to those applicable in, for example, the EU and certain other jurisdictions. Where the law applicable to the protection of your personal data requires that we have in place an appropriate safeguard for the transfer we comply with that requirement. DGA Group LLC and the network company that enters an engagement letter with your company or organisation will take steps to protect your information in line with locally applicable data protection requirements, and notify these arrangements to you.

 

How long do we keep your data?

We keep your information as long as needed for the purpose for which it is collected. This will depend on a number of factors such as whether you or your company or organisation are an existing client or have interacted with recent client mailings or bulletins or attended recent events. We will always retain your information for at least the period necessary to comply with legal, accounting or regulatory requirements. If you need further information on exact retention details for a particular type of personal data or associated with a particular use you can contact us for further details.

 

Your Rights

If you are working with one of our EU practices or our practices in certain other jurisdictions where similar rules apply, you have certain rights in relation to your personal data. The availability of these rights and the ways in which you can use them are set out below in more detail.

Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact info@dgagroup.com.

 

• Access: you are entitled to ask us if we are processing your data and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and certain other information about it;
• Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected;
• Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims;
• Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example, if you want us to establish its accuracy or the reason for processing it;
• Transfer: you may request the transfer certain of your personal data to another party;
• Objection: where we are processing your personal data based on a legitimate interests (or those of a third party) and you may challenge this. However, we may be entitled to continue processing your information. You also have the right to object where we are processing your personal information for direct marketing purposes;
• Consent: where we are processing personal data with consent, you can withdraw your consent.

 

If you want to exercise any of these rights, please contact info@dgagroup.com.

You also have a right to lodge a complaint with a data protection supervisory authority, in particular in the UK Member State in the European Union where you are habitually resident and where we are based or where an alleged infringement of data protection law has taken place. Details of the EU supervisory authorities and their contact details for complaints are available here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. In the UK, you can make a complaint to the Information Commissioner’s Office (Tel: 0303 123 1113 or at www.ico.org.uk).

 

Automated Decision-Making

Our client due diligence checks (under anti-money laundering, sanctions screening and other crime prevention and detection laws, and regulatory requirements) may involve automated screening checks and decision-making to ensure that clients and contacts are genuine and to prevent fraud or crime. These automated services typically work by scanning your identity information against databases and ‘watch lists’ held by third party screening service providers and published by governments and regulatory authorities. If your details generate a match with details in these databases and watch lists we may need to ask you for further verification information and ultimately may not be able to provide services to you.

Direct Marketing

As described in the ‘Your Rights’ section, you can opt-out of receiving direct marketing from us at any time.

We may use the information you give us on our website or other means for direct marketing purposes to provide emails, newsletters and other messages to keep you informed of industry developments, market insights and of our services, including events that we think may interest you.

You can opt-out by clicking on the “unsubscribe” link included at the end of any marketing email we send to you or by emailing us at info@dgagroup.com.

 

Cookies

We use cookies that identify your browser. They collect and store information when you visit our website about how you use it through which it is possible to record your use of the website, as well as provide you with a better service and experience when browsing and for analytics. The personal data we collect through these technologies will also be used to manage your session.

For more information about cookies and how we use them, please see our: Cookie Notice.

 

Links to third party websites

Our website, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others. The personal data that you provide through these websites is not subject to this privacy notice and the treatment of your personal data by such websites is not our responsibility.

If you follow a link to any other websites, please note that these websites have their own privacy notices which will set out how your information is collected and processed when visiting those sites.

 

Children

We do not knowingly collect information from children or other persons who are under 16 years old. If you are under 16 years old, you may not submit any personal data to us.

 

Changes to this Notice

This notice may be changed from time to time.

If we change anything important about this notice (the information we collect, how we use it or why) we will highlight those changes at the top of the notice and provide a prominent link to it for a reasonable length of time following the change.

 

How to contact us

If you would like more information about the way we manage personal data that we hold about you, please contact us using the details contained in your engagement letter or at info@dgagroup.com.