1. Who is responsible for your data

PASHAN Attorneys at Law & Legal Consultancy, a limited liability company registered in the Kurdistan Region of Iraq under Registration No. 41173, is responsible for the personal data described in this policy. Our office is at The Mall, Ster Tower, Office No. 101, First Floor, Gulan Street, Erbil, Kurdistan Region of Iraq. For anything concerning your data, write to info@pashan.law or call +964 776 114 7766.

2. The data we collect

What we collect depends on how you deal with us.

  • When you contact us: your name, email address, telephone number, the organisation you represent and the content of your message.
  • When you become a client: identity and address documents, company documents, the details of the matter, correspondence, documents exchanged during the matter, invoices and payment records, and the information needed for our conflict checks and our anti-money-laundering and know-your-client obligations.
  • When you use the client portal: your sign-in email address, a protected form of your password, the matters and documents shared with you, the messages and notes you write, your notification preferences, and technical records such as sign-in times and the internet address used.
  • When a visa or residence application is prepared: for each person included, names, gender, date and place of birth, nationality and citizenship, passport details and a copy of the passport, a photograph, addresses, telephone numbers and email addresses, occupation and employer, family relationships, details of entry and residence, and the supporting documents required by the authorities.
  • When you visit the website: standard server records such as the internet address, browser type, pages visited and the time of the visit.

3. Why we use it

We use personal data to:

  • respond to enquiries and decide whether we can act;
  • provide legal services under our engagement, including preparing and filing applications, contracts and other documents, and keeping you informed through the portal, email, telephone and WhatsApp;
  • meet our legal and professional obligations, including conflict checks, anti-money-laundering and know-your-client checks, screening against sanctions, politically exposed person and other watch lists, record-keeping and tax requirements;
  • issue and collect invoices and keep our accounts;
  • run, secure and improve the website and the portal, including protecting against misuse;
  • send you information about the firm's services where you have asked for it. You can withdraw that request at any time.

Where the law requires a legal basis for processing, we rely on the performance of our engagement with you, our legal obligations, our legitimate interests in running and protecting the firm, and your consent where we have asked for it.

4. Who we share it with

We share personal data only where the matter or the law requires it, and only what is needed:

  • within the firm, with the lawyers and staff working on your matter;
  • with partner law firms and local counsel in other countries where your matter requires their involvement;
  • with courts, registries, immigration and residency authorities, banks and other bodies to which an application, filing or document must be submitted on your instructions;
  • with providers who help us operate, such as hosting, email, messaging and screening services, under obligations of confidentiality;
  • with auditors, insurers and professional advisers of the firm;
  • where we are required to by law, by a court or by a regulator.

We do not sell personal data and we do not share it with anyone for their own marketing.

5. Transfers to other countries

Partner firms, authorities and service providers may be outside the Kurdistan Region of Iraq, for example in the United Arab Emirates or the United Kingdom. When data leaves the Region we share only what the matter requires and we rely on contractual confidentiality commitments and the safeguards available under the laws that apply to the recipient.

6. How long we keep it

Client files, including the documents and application data in them, are generally kept for ten years after the matter closes, or longer where the law, a professional rule or a continuing engagement requires. Enquiries that do not lead to an engagement are kept for up to twelve months. Portal technical records are kept for up to twelve months. When data is no longer needed it is deleted or anonymised.

7. How we protect it

The website and the portal are served over encrypted connections. Access to client information in the firm's systems is limited by role, every significant action is recorded in an audit log, sign-in attempts are rate-limited, and our staff are bound by professional confidentiality. No system is completely secure; if you believe your data or your portal account has been compromised, tell us at once at info@pashan.law.

8. Your rights

Subject to the law that applies to you, you may ask us to confirm what personal data we hold about you, to correct it, to delete it, to restrict or object to its use, or to provide a copy in a usable format, and you may withdraw a consent you have given. Write to info@pashan.law. We may ask you to confirm your identity, and we may keep data where a legal or professional obligation requires us to. If you are not satisfied with our response you may complain to the authority responsible for data protection in your country.

9. Cookies and similar technology

The website and the portal use only the cookies needed to keep you signed in, to protect forms against misuse and to remember your display preferences. We do not use advertising or tracking cookies. The website loads typefaces from Google Fonts; when a page loads, your browser requests those files from Google, which may record your internet address under Google's own privacy policy.

10. Children

The website and the portal are not directed at children. We process information about minors only within an engagement, for example a family residence application, on the instructions of a parent or guardian.

11. Changes to this policy

We may update this policy from time to time. The date of the latest version is shown at the top of this page. Significant changes will be announced on the website or, for clients, through the portal.

12. Contact

For questions about this policy or about your personal data, write to info@pashan.law, call +964 776 114 7766, or write to PASHAN Attorneys at Law & Legal Consultancy, The Mall, Ster Tower, Office No. 101, First Floor, Gulan Street, Erbil, Kurdistan Region of Iraq.