+350 20076513 mail@ecsinter.gi

PRIVACY POLICY GENERAL ECS INTERNATIONAL LIMITED

PRIVACY NOTICE (GENERAL)

Welcome to our Privacy Notice. We are ECS International Limited, of Suite C, Ground Floor, Neptune House, Marina Bay, Gibraltar GX11 1AA and we are committed to being fully compliant with all applicable Gibraltar data protection legislation and the General Data Protection Regulation as applied to the Gibraltar (GDPR) in respect of personal data, as well to safeguarding the rights and freedoms of natural persons whose information the Company collects.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

WHAT IS THE PURPOSE OF THIS DOCUMENT?

DATA PROTECTION PRINCIPLES

We will comply with data protection law. This says that the personal information we hold about you must be:

THE KIND OF INFORMATION WE HOLD ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

We may also collect, store and use the following “special categories” of more sensitive personal information:

HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We collect personal information about you, our client, either directly from you or sometimes from a background check provider. We may sometimes collect additional information from third parties including credit reference agencies or other background check agencies.

HOW WE WILL USE INFORMATION ABOUT YOU

SITUATIONS IN WHICH WE WILL USE YOUR PERSONAL INFORMATION

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

IF YOU FAIL TO PROVIDE PERSONAL INFORMATION

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you or we may be prevented from complying with our legal obligations (such as our Anti-money laundering and countering the financing of terrorism obligations).

CHANGE OF PURPOSE
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION

"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about members or former members in the course of legitimate business activities with the appropriate safeguards.

DO WE NEED YOUR CONSENT?

INFORMATION ABOUT CRIMINAL CONVICTIONS

We envisage that we will hold information about criminal convictions.

We will only collect information about criminal convictions if it is appropriate given the nature of the services we provide to you and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of our initial Pre-contract discussions or we may be notified of such information directly by you in the course of your relationship with us.

AUTOMATED DECISION-MAKING

DATA SHARING

WHY MIGHT YOU SHARE MY PERSONAL INFORMATION WITH THIRD PARTIES?

We will share your personal information with third parties where required by law, where it is necessary to provide the services with you that you have contracted with us for or where we have another legitimate interest in doing so.

WHICH THIRD-PARTY SERVICE PROVIDERS PROCESS MY PERSONAL INFORMATION?

"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. The following third-party service providers process personal information about you for the following purposes:

Third Party Provider Purpose
Licenced banks The provision of banking services
Funds Investment purposes
Pension Providers Provision of pension purposes
Corporate Service Providers Provision of corporate services
HOW SECURE IS MY INFORMATION WITH THIRD-PARTY SERVICE PROVIDERS AND OTHER ENTITIES IN OUR GROUP?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

WHEN MIGHT YOU SHARE MY PERSONAL INFORMATION WITH OTHER ENTITIES IN THE GROUP?

We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

WHAT ABOUT OTHER THIRD PARTIES?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

TRANSFERRING INFORMATION OUTSIDE OF GIBRALTAR

DATA SECURITY

You can get further information about our data security measures by contacting us.

DATA RETENTION

HOW LONG WILL YOU USE MY INFORMATION FOR?

You can get further information about our data retention policies by contacting us.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION

Under certain circumstances, by law you have the right to:

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact us.

Disclaimer

ECS International Group has two primary locations from which it trades. The trading company ECS International Limited registered in Gibraltar and the trading company Baker Tilly Isle of Man in the Isle of Man respectively. The two corporate entities are regulated by the appropriate authorities in the jurisdictions in which they are registered.

ECS International Limited in Gibraltar and Baker Tilly Isle of Man in the Isle of Man are not licenced to provide investment advice and clients using our services must accept and understand this restriction to the services that we provide. We will not accept any liability whatsoever that is related to the suggestion that we have given investment advice.

It must also be understood that the ECS international Group (either of the companies) cannot provide clients with detailed taxation advice as we cannot be aware of the full circumstances of an individual’s taxation affairs. The ECS International Group may, where it has specifically agreed to do so in writing, provide specific taxation advise relating to the taxation liabilities of the entities provided to the client in the jurisdictions in which those entities are registered. Notwithstanding the written agreement to provide this advice, the ECS International Group reserves the right to retain the of specialist taxation advisers to assist in the provision of any such advice that it has agreed to provide. The cost of these specialist advisers will be borne by the client.

Clients must not interpret anything written or spoken by the ECS International Group (Staff, Officers or associated companies) in such a way that infers that the ECS International Group (and/or its staff, officers, associated companies) has given investment advice and/or taxation advice. Clients wishing to obtain such advice must retain the services of properly qualified advisers.

The information and facts that are contained in this web-site are for general information purposes only and do not constitute any form of professional advice. The ECS International Group (staff, officers and/or Companies) does not and cannot accept any liability for any losses which may be incurred by acting in reliance on information, materials or facts contained on this web-site. Any planning in relation to the use of offshore structures must be based on specific advice and must not be based on the contents of this website.