WHAT PERSONAL DATA DO WE COLLECT?
We collect personal data that are claimed in the way of Compliance procedure proceeding.
We typically process the following types of personal data about customers:
- Name and surname and contact information such as residential/mailing address, telephone number, email address, job title;
- Valid passport copy;
- Biographical information which may confirm customers identity including your date of birth, tax identification number, identity card details, country of domicile;
- Details relating customers source of funds, expenditures, assets and liabilities, as well as bank account details;
- Reference Letter from reputable persons, solicitors or financial organizations;
- Details relating current occupation, place of work, education, marital status,
- Details to assess whether customer may represent a political exposed person or money laundering risk
We may also receive personal data from a third party acting on your behalf, such as a notaries, banks representative, customers representative requesting for services proceeding for you.
HOW DO WE USE PERSONAL DATA?
We use personal data only as permitted by a proper legal basis, such as to fulfill our agreements, documents, application forms on behalf of your name, Compliance procedure proceeding on behalf of your name, Due Diligence procedure proceeding on behalf of your name, for other purposes you have expressly consented to, for purposes based on our legitimate business interests, or as required by law. For example, we may use your personal data to:
- Reserve, manage, and modify the documents, forms and records concerning your deals
- Notify you of any changes or important information regarding your deals
- Receive and follow any special needs or requests
- Register you to receive our newsletter or other communications per your request
- Provide surveys or other methods by which we can monitor and improve our performance
- Respond to your inquiries and communications
- Resolve disputes or enforce our rights
WITH WHOM DO WE SHARE PERSONAL DATA?
We will not sell any of your personal data to any outside organization for their own marketing or other purposes. We only disclose your personal data to third parties as reasonably necessary to carry out the services which you requested from us. For example, we may share personal data with:
- Banks and payment systems where you are going to open account;
- Notaries, solicitors other authorized persons who will prepare and proceed your deals;
- Authorities which receive the personal data within the legastive framework, including the Due Dilligence procedure which is conducted according to the AML.
- Offical representatives of partners or third parties which are involved in your transactions, if in advance you haven’t restricted them accessing your personal data.
- Legal and governmental authorities or other third parties, to the extent required to comply with a legal order or applicable law.
If we need to transfer personal data from the EU to a country outside the EU, we take reasonable steps to ensure such personal data is appropriately protected. For jurisdictions that are not the subject of a data privacy adequacy decision by the European Commission, we use binding corporate rules, EU model clauses, or other permitted mechanisms to ensure an appropriate level of data privacy and security. We may remain liable for any onward transfer of personal data that we export from the EU.
HOW DO WE PROTECT PERSONAL DATA?
We use appropriate technical and organisational measures to ensure a level of security appropriate to the risk presented by processing, in particular any unauthorized or unlawful processing, of your personal data.
YOUR RIGHT TO REQUEST ACCESS, MODIFICATION, AND DELETION
You have the right to request access to the personal data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of applicable law. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than yourself. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Data. In some circumstances we may charge a reasonable fee for access to your information. If we deny your request, we will provide you with a written explanation of the reasons for our determination.
We generally retain your Personal data only as long as may be reasonably necessary to carry out the purposes set forth in this Policy. Please note that we reserve the right to maintain proper business and transactional records as permitted or required by law, even if such records contain your personal data.
Where we are processing your personal data based on your consent, you have the right at any time to withdraw such consent by contacting us at Phone + 372 6143 135 or e-mail: email@example.com. Please note that we may continue to process such personal data only if supported by another lawful basis (such as to fulfill our obligations to you, in connection with our legitimate business interest, or as required by law).
INQUIRIES OR COMPLAINTS
If you have any questions or complaints about our data processing practices, please first contact us at firstname.lastname@example.org If we are unable to resolve your complaint, you also have the right to raise your inquiry or complaint with the applicable data protection authority in your home country.
We are typically the data controller, as that term is used in applicable privacy laws, for any personal data that we collect from you. However, when we collect personal data about you from a third party (e.g., banks, notaries, legal representative), the third party may be the data collector for such data and we may be the data processor. If we are acting as the data processor, we will only process the relevant personal data as requested by the data controller, and may need to refer any inquiries from you to the applicable data controller.
CHANGES TO THIS POLICY
We may change this Policy from time to time. We will comply with any legal requirements regarding the provision of notice, but will always post the then-current version of this Policy on the Site. If any proposed changes affect the use or disclosure of personal data collected under a prior version of the Policy, we will take reasonable attempts to notify you (for example by posting a notice on the Site or emailing you) in advance to offer you a reasonable opportunity to object to any such changes. Please monitor this Policy from time to time to ensure you are apprised of our current privacy practices.
If you have any questions or complaints about this Policy or our privacy practices, or to exercise any of your rights stated in this Policy, please contact us at email@example.com