DATA PROTECTION POLICY
Heron Advisors sagl, (“Heron”, “we” or “us”), is a provider of corporate finance services.
For the purposes of data protection law, Heron is a data controller in respect of your Personal Data. You can find contact details for the data controllers within Heron, by contacting Heron in accordance with the “Our Contact Information” section below.
02.OUR COMMITMENT TO PRIVACY
We believe that the responsible use of Personal Data collected is critical to our business objectives and reputation. As part of our commitment to privacy, we have adopted this Policy.
03.SOURCES OF PERSONAL DATA WE COLLECT
Heron will collect Personal Data about you, subject to applicable law, from a variety of sources as follows:
— When you provide it to us (e.g. sending us emails, signing an agreement, filling forms, contacting us via telephone or visiting or making an enquiry through our website, or by any other means).
— In the ordinary course of our relationship with you (e.g. in the course of managing your transactions).
— Where you apply for a job with us, we may collect from you and third parties (where relevant) additional Personal Data such as your CV and any references.
— That you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), to the extent that you choose to make your profile publicly visible).
— From third parties who provide it to us (e.g., your employer; our clients; credit reference agencies; law enforcement authorities; etc.).
— From third parties, where you purchase any of our services through such third parties.
— When you visit our website or use any features or resources available on or through a website. When you visit a website, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a site and other technical communications information), some of which may constitute Personal Data.
— Heron may also record the phone calls with clients, potential clients and third parties, both inbound and outbound calls.
— In accordance with financial regulations, Heron may also record the phone calls with clients, potential clients and third parties, both inbound and outbound calls.
Where you provide Personal Data on behalf of another individual, you are responsible for notifying that individual that you have provided their Personal Data to us and directing them to this Policy so they can see how we will process their Personal Data.
04.THE PURPOSE AND LEGAL BASIS OF PERSONAL DATA PROCESSING
We will process Personal Data in order to:
— provide you with a personalised service;
— provide you with information on market trends and opportunities;
— to engage in marketing and business development activities and understand the effectiveness of our marketing;
— verify your identity (including for fraud prevention purposes), assess your ability to meet your financial commitments (if any) and manage Heron’s relationship with you and/or the client to whom you are connected;
— to perform the contract with you or a client/supplier to whom you are connected;
— improve our services;
— keep our site and systems safe and secure;
— to carry out financial risk assessments, risk mitigation activities and for risk reporting and risk management;
— to comply with Heron’s legal and regulatory obligations. This includes reporting to the relevant authorities, complying with anti-money laundering obligations and tax reporting obligations;
— understand our clients and their business objectives;
— update and enhance client records;
— defend against or exercise legal claims and investigate complaints; and
— inspection procedures.
The legal basis for processing your Personal Data for the purpose specified in this section is:
— Consent – we may need your consent to use your Personal Data. You can withdraw your consent by contacting us in accordance with the “Our Contact Information” section below.
— Performance of a contract – we may need to collect and use your personal data to enter into a contract with you or to perform our obligations under a contract with you or a client to whom you are connected.
— Legitimate interest – we may use your personal data for our legitimate interests.
— Compliance with law or regulation – we may use your personal data as necessary to comply with applicable law/regulation.
05.MARKETING MATERIALS, EVENT INVITATIONS AND NEWS
We may process your Personal Data in order to send our publications, marketing materials, event invitations and news (the “Marketing Materials”) about Heron.
The legal basis for processing your data for the purpose specified in this section is your consent, as well as the legitimate interest of Heron.
If you do not wish to receive Marketing Materials from us you can opt out at any time by contacting Heron using the details set out in the “Our Contact Information” section below. Your request will be analyzed and answered within one (1) month from receipt by us. Such withdrawal does not affect the legality of the operations for processing of your Personal Data prior to it. You may still receive other information directly from Heron staff and employees you are in touch with based on the legal grounds applicable for the case (e.g. performance of a contract).
06.TRANSFER OF DATA
We may instruct third party suppliers to perform services such as software support, e-marketing campaigns, hosting our website, etc. on our behalf. In such cases we take the necessary contractual steps to ensure the adequate protection of your Personal Data. Your Personal Data will not be given to other third parties, apart from in limited circumstances such as when we host a joint event with a third party and you register to attend it. In such cases, you will be informed in advance that this is a joint event and if you register to attend it, your contact data will be shared with the other event organizers.
In accordance with the relevant provisions, you have the right to:
— Confirm whether Heron is processing Personal Data that concerns you, and access to the Personal Data Heron holds about you.
— Request the rectification of Personal Data.
— Request the removal of Personal Data in certain circumstances (there may be cases where Heron is legally entitled to retain it such as the defense against potential claims).
— Request the limitation of the processing of your Personal Data (again, there may be cases where Heron is legally entitled to continue processing your Personal Data).
— Object to the processing of your Personal Data, in which case, Heron shall cease to process your Personal Data (except where Heron is legally entitled to continue processing your Personal Data);
— Receive, in a structured, widely-used format that can be mechanically read, the Personal Data that concern you and that you have provided to Heron or request that Heron transfers them directly to another controller when technically possible.
— Withdraw the consent granted, although in certain circumstances it may be lawful for Heron to continue processing your Personal Data where Heron has another legitimate reason (other than consent) for doing so.
— Lodge a complaint with the relevant data protection authority if you think that any of your rights have been infringed by the Heron.
— You can exercise your rights by contacting Heron using the details set out in the “Our Contact Information” section below. Your request will be analyzed and answered within one (1) month from receipt by us.
You can find out more information about your rights by contacting the relevant data protection authority. We can, on request, tell you which data protection authority is relevant to the processing of your personal data.
The Personal Data provided will be kept for the period determined by various criteria including: (i) legal obligation of conservation; (ii) term of the contractual relationship and service of any responsibilities derived from said relationship; and (iii) If and when applicable request of removal by the interested party.
Keeping your Personal Data secure is of utmost importance to us. We take appropriate technical and organizational measures according to industry standards to keep your information secure and protect it from unauthorized use or damage, both online and offline. For security reasons we cannot disclose these measures in details.
10.DATA PROTECTION OFFICER INFORMATION
For any doubts or queries about your personal data you may contact with the data protection officer of Heron by sending an email to firstname.lastname@example.org