Protection of your privacy and the security of your personal data are very important to ALPHABETH QUANT I LIMITED.
If you do not accept these policies, you should immediately discontinue your use of our website. By using our website, providing personal information, and/or using any of our services, you agree that:
This is referred to as the “Data Protection Legislation”, which includes:
In these cases, the provision of your personal data will be a contractual requirement or a requirement relating to entering into a contract, and you will be obliged to provide the personal data we require in order to comply with our legal obligations and provide the services to you under that contract. Without this information, we may not be able to provide you with our services or respond to queries or requests that you submit to us. You may, however, visit our website anonymously. Additionally, we may also process certain special categories of data. This data would only be collected and processed with either your explicit consent or where we are lawfully permitted to do so without your consent (e.g. personal data which is manifestly made public by you). Such processing would be for limited purposes such as fraud prevention, prevention of money laundering, financial crime and terrorist financing, or in order to represent you in civil or criminal proceedings. Such data may include matters such as:
How do we collect the information? We collect your personal data in the following manner:
We always ensure we respect your privacy rights. This means we can only collect your personal data if we have a lawful basis for doing so. If the data is particularly sensitive we may need additional justification. In most cases, we may rely on the following grounds:
In most cases, we collect personal data that you choose to provide to us so that we can provide you with a service you have requested from us such as provision of legal advice for example. The relevant information is then used by us to communicate with you on any matter relating to the conduct of your instructions in general. Specifically, if you are a client, this would be providing the services set out in our engagement letter and in accordance with applicable terms of business (as may be amended) and as necessary for the performance of our contract with you. If you choose not to provide certain information, we may not be able to provide you with some services. We also process information relating to our employees, and prospective applicants, for general employment and recruitment purposes. These purposes will be disclosed in more detail at the time we collect personal data from such persons.
In connection with the provision of our services, personal data may also be transferred outside of Gibraltar. This may include countries or territories outside of the United Kingdom or the European Economic Area (“EEA”) where necessary (e.g. in the context of international legal proceedings or cross-jurisdictional legal services, or because we use service providers outside the EEA). The EEA includes countries in European Union as well as Iceland, Lichtenstein, and Norway. Under the Data Protection Legislation, personal data can flow fairly freely from Gibraltar to the United Kingdom or to the EEA (note that the same may not be true for inward transfers to Gibraltar from the EEA, as it is no longer part of the EU). However, certain restrictions exist where personal data is being transferred to a ‘third country’ outside the EEA or the United Kingdom and these are referred to as “restricted transfers”. Generally, we will only perform restricted transfers where the transfer will be adequately protected by measures such as the following:
In the absence of adequacy regulations or appropriate safeguards, we may also rely on derogations for specific situations as set forth in Article 49 of the Gibraltar GDPR. In particular, we may collect and transfer your personal data outside the EEA:
Finally, we may also perform restricted transfers in ‘one-off’ cases where a transfer is not repetitive, concerns a limited number of data subjects, and is necessary for the purposes of compelling legitimate interests pursued by us, which are not overridden by your interests or rights and freedoms, and only after we have assessed all relevant circumstances.
Retention periods are determined based on the type and nature of the information and the legal or regulatory requirements that apply. We shall retain a record of our engagement with all our clients, as well as all files and documentation relating to clients and/or the particular matter that forms the basis of the contractual relationship for a minimum period of 6 (six) years from the end of the business relationship described in the relevant engagement documentation, unless:
We are committed to taking appropriate measures designed to keep your personal data secure. Our technical, administrative, and physical procedures are designed to protect personal data and non-personal data from loss, theft, misuse, and accidental, unlawful or unauthorized access, disclosure, alteration, use, and destruction. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. We implement security measures across the firm to ensure our client's data is protected within secured and encrypted servers we control, which are located in Gibraltar. We may also keep hard copy records of this personal information in physical storage facilities with access restricted solely to our personnel. We also take steps to monitor access to and modification of your information by our contractors, advisers, consultants, and staff members, and ensure that they are aware of and properly trained in their obligations for managing your privacy. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities. If you have any further questions about the security of your personal information, you can contact us at the details below.
We use reasonable physical, electronic, and procedural safeguards to protect the personal information that we obtain from you from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please note that we are not responsible for the security of any data you are transmitting over the Internet, or any data you are storing, posting or providing directly to a third party’s website, which is governed by that party’s policies. Please note that no method of transmission over the Internet or method of electronic storage is 100% secure and we cannot ensure or warrant the security of any information you transmit to us. Transfer of your data via these means is therefore at your own risk.
The accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data is known as a “data breach”. The Gibraltar GDPR imposes requirements on businesses to identify, assess and report breaches in a timely manner (within 72 hours). We undertake to inform you if your personal data is compromised and there is a high risk to your rights and freedoms as a result.
As noted above, Gibraltar has its own data protection laws that apply certain EU laws, with such modifications as are necessary. Depending on your particular circumstances, you may also have additional rights if you live or work outside of Gibraltar. For example, the EU GDPR may apply to you if you are based in the EEA. Under the Data Protection Legislation in Gibraltar, if you are a natural person (in other words, a human being and not a company), you have the right to:
Contact information of Data Controller
Your right to complain
Governing Law and Jurisdiction
Privacy Protections for Children Using the Internet
Protecting children’s privacy is important to us. For that reason, we do not collect or maintain information on our website from those we actually know are under the age of 16, nor is any part of our website targeted to attract anyone under 16. We request that all visitors to our website who are under 16 not disclose or provide any personal data and discontinue the use of our website.
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