In view of the contracts concluded between the professional companies of the Soter & Partners Group of companies as Contractors and the Beneficiaries – legal entities and individuals, we bring to their attention the following:

In accordance with Art. 28 of the GDPR, as client and partner (generically referred to in the contracts as Beneficiary) you grant us a general authorization as Contractor of professional services to employ and contract subcontractors for data processing in the performance of the contracted services (Subcontractors). Although as a general rule we will not disclose personal data to third parties for the purpose of providing the services, where applicable, we may:

• disclose personal data to our affiliates within Soter & Partners, Soter & Partners' contractual partners and service providers, including subcontractors or processors, indicated without limitation in the Sub-contractors List;
• disclose relevant personal data to the competent authorities in the context of the provision of the requested services, if this is necessary for the fulfillment of these purposes.

The type of subcontractors and persons to whom we may grant access to data in the course of business are published in the List of Subcontractors and will be updated periodically.

Contractual clients are also informed by email of any changes to this section. Within 30 days of being notified of the intended change, you may object to a particular newly added subcontractor on the grounds that such addition will cause a violation of applicable legal requirements. Your objection must be submitted to us in writing and shall include the express grounds for the objection and your options for a resolution to the situation, if any. If you do not communicate your objection to us within the period specified in the notice you received, the relevant subcontractor may be involved in the data processing.

Please note that we require and impose on subcontractors data protection obligations and security measures as onerous as those agreed by the customers to be imposed on them, before the subcontractor processes the data provided by you. We also emphasize that our professional company (as the Contractual Contractor) will continue to be held liable for the actions and omissions of its subcontractors.

In the event that you as the client have legitimately objected to a subcontractor and we cannot reasonably accept your objection, we will inform you accordingly, and you have the right to unilaterally terminate the service contract concluded with the professional company of our group.