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SCP ELI & PIERRE applies to the processing of personal data the same principles that govern its legal practice: legitimate purpose, proportionality, fairness and confidentiality. This policy precisely describes the scope of that processing, in compliance with Regulation (EU) 2016/679 (GDPR) and Togolese Law No. 2019-014 of 29 October 2019 on the protection of personal data.
Preamble
This privacy policy applies to the website elipierre-avocats.com and to all electronic exchanges with SCP ELI & PIERRE that result from it. It supplements the site's legal notice.
The data controller is SCP ELI & PIERRE, whose contact details appear in §Site editor of the legal notice.
Data collected
The site collects personal data only through the contact form. No data is collected without your knowledge — no tracker, no audience measurement, no cookie deployment.
The fields collected through the contact form are:
- Full name — to personalise the response;
- Email address — to reply to you;
- Telephone number — optional, in case of urgency or if you wish to be called;
- Type of request — to route your request to the appropriate lawyer;
- Description of your situation — limited to 2,000 characters;
- Explicit acceptance of the attorney-client privilege regime.
No sensitive data within the meaning of Article 9 of the GDPR (health, political opinions, religion, sexual orientation, etc.) is required by the form. If you transmit such information of your own initiative in the description of your matter, it will be processed with the same level of confidentiality as any lawyer's file, in accordance with attorney-client privilege.
Purposes of processing
The data collected is processed exclusively for the following purposes:
- To respond to your contact request and, where applicable, arrange an initial appointment;
- To assess whether the firm can take on your matter (in particular conflict-of-interest checks);
- To open, at your request, the client file if a matter is entrusted to the firm.
No commercial use or transfer to third parties is ever made. Your data is neither sold, rented, nor used for prospecting purposes. The firm engages in no electronic mass communication.
Legal basis
The processing rests on two cumulative legal bases within the meaning of Article 6 of the GDPR:
- Explicit consent, given through the attorney-client privilege checkbox at the foot of the contact form;
- Pre-contractual measures taken at the request of the data subject — your possible engagement request constitutes a pre-contractual measure within the meaning of Article 6.1.b) of the GDPR.
Retention period
Data submitted through the contact form is retained for a maximum period of twelve (12) months from our last exchange, unless:
- A matter is entrusted to the firm — in which case the data is integrated into the client file and kept in accordance with the lawyer's file-retention rules (in practice, ten years from file closure, in line with the profession's customs and the limitation periods applicable to professional liability);
- A legal obligation requires longer retention (for example anti-money-laundering rules, when the firm acts on a transaction falling within the scope of due-diligence obligations).
At the end of the applicable retention period, the data is irreversibly deleted from the firm's systems.
Recipients
The data collected is accessible only to the following persons, strictly within the limits of their duties:
- The Senior Partners, the Associate Lawyer and the Legal Counsel of the firm in charge of your matter;
- The Law Clerk and the Secretary of the firm, solely for administrative-management tasks;
- The firm's technical processors (site host, professional email provider), bound by contract to confidentiality and security commitments compliant with Article 28 of the GDPR.
No transfer of data outside Togo is made, save where strictly necessary for the performance of the matter entrusted — in particular when a matter requires the firm's intervention before a foreign court (Court of Arbitration of the International Chamber of Commerce in Paris, High Court of Justice in London, OAPI courts in Yaoundé). In such cases, the transfer is governed by the appropriate safeguards provided by the GDPR.
Cookies and trackers
This site uses no cookies.
No Google Analytics. No Facebook Pixel. No Hotjar. No third-party audience measurement. No consent banner to click — because there is nothing to consent to. Browsing this site places no file on your device.
This choice is deliberate. It follows directly from the firm's ethical commitment to confidentiality, and from our conviction that an institutional lawyer's website should not behave like an e-commerce site — visiting our website should leave no exploitable trace.
Only two minimal technical mechanisms operate on the browser side, with no file deployment:
- The loading of typographic fonts (self-hosted on the site server, no Google Fonts in the long run — see the production note);
- The standard browser HTTP cache, which temporarily stores static files (CSS, JS, images) to speed up browsing. This cache is fully managed by your browser, without intervention from the firm, and may be cleared at any time from its settings.
Your rights
Under the GDPR and Togolese Law No. 2019-014, you have the following rights over the data concerning you:
- Right of access
- Obtain confirmation as to whether or not data concerning you is being processed, and obtain a copy.
- Right to rectification
- Have inaccurate data corrected or incomplete data concerning you completed.
- Right to erasure
- Request deletion of your data, within the limits provided by law (unless a retention obligation applies).
- Right to restriction
- Request that processing of your data be frozen for the time necessary to verify a contestation.
- Right to portability
- Receive the data you have provided to us in a structured, commonly used, machine-readable format.
- Right to object
- Object, on grounds relating to your particular situation, to processing based on the firm's legitimate interest.
- Post-mortem rights
- Set, during your lifetime, directives concerning the fate of your data after your death.
How to exercise your rights
You may exercise these rights through one of the following two means:
- By email at contact@elipierre-avocats.com, specifying the right you wish to exercise;
- By post, to the address SCP ELI & PIERRE — 18 BP 276 Lomé 18, Togo, mentioning the reference "GDPR Request" at the head of the letter.
The firm undertakes to acknowledge receipt of your request and to reply within one month of receipt, in accordance with Article 12 of the GDPR. This period may be extended by two months for complex or multiple requests, in which case you will be informed.
For obvious reasons of security and protection of your own data, the firm may ask you to prove your identity before acting on your request.
In the event of a dispute concerning the processing of your data, you have the right to lodge a complaint with the Personal Data Protection Authority (IPDP) of Togo, an independent authority established by Law No. 2019-014. If you reside in the European Union, you may also refer the matter to the supervisory authority of your country of residence (in France, the CNIL).
Data security
The firm implements the appropriate technical and organisational measures to ensure the security, integrity and confidentiality of the data it processes:
- Mandatory HTTPS / TLS 1.3 encryption for all communications with the site, automatic HTTP → HTTPS redirection;
- Strict security headers (HSTS, CSP, X-Frame-Options, Referrer-Policy);
- No user account creation, no password storage — the attack surface is minimal;
- Multi-layer anti-spam on the contact form (server-side validation, honeypot, time-trap, IP rate limiting, language filter);
- Monthly review of third-party dependencies and application of security patches;
- Regular backups of site contents, kept on a separate, encrypted infrastructure.
Changes
This policy may be updated to reflect regulatory, case-law or technical developments. The date at the head of the page reflects the latest update. Any substantive change will be flagged on the site's home page for a reasonable period.
Point of contact within the firm
Given its size, SCP ELI & PIERRE has not appointed a dedicated Data Protection Officer. Questions relating to this policy and to the exercise of your rights are handled directly by the Senior Partner in charge of your matter or, failing that, by any person at the firm to whom you write through the channels above.
Update This policy was established on . For any question, write to the firm at contact@elipierre-avocats.com. See also the site's legal notice.