+350 20076513 mail@ecsinter.gi

WEBSITE PRIVACY POLICY ECS INTERNATIONAL LIMITED

PRIVACY NOTICE (WEBSITE)

ECS International Limited and its management and Board of Directors, with a registered address at Suite C, Ground Floor, Neptune House, Marina Bay, Gibraltar GX11 1AA 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.

We, ECS International Limited, are the Controller of all Personal Data relating to our personnel and personal data used in our business for our own commercial purposes.

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how ECS International collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or enquire about a product or service.

CONTROLLER

We, ECS International, are the Controller of all Personal Data relating to our personnel and personal data used in our business for our own commercial purpose (collectively referred to as “ECS International”, “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

ECS International Limited
Suite C
Ground Floor
Neptune House
Marina Bay
Gibraltar GX11 1AA

T: +350 20076513 F: +350 20079523

mail@ecsinter.gi
www.ecsinter.gi

You have the right to make a complaint at any time to the Information Commissioner, the Gibraltar Regulatory Authority for data protection issues (http://www.gra.gi/data-protection). We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes. Historic versions can be obtained by contacting us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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

We do not collect any Special Categories of Personal Data about you (see the Glossary below for further information).

HOW IS YOUR PERSONAL DATA COLLECTED?

HOW WE USE YOUR PERSONAL DATA

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.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
Performance of a contract or undertaking pre-contractual steps with you
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside of ECS International Limited for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies link on the website.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

INTERNATIONAL TRANSFERS

We share your personal data within ECS International Limited. This may involve transferring your data outside the European Economic Area (EEA).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENCION

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us

In some circumstances you can ask us to delete your data: see the Glossary below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

If you wish to exercise any of the rights set out above, please contact us

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

GLOSSARY

DATA

Special Categories of Personal Data means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data as well as information about criminal convictions and offences.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies acting as joint controllers or processors and who are based in Gibraltar and provide IT and system administration services.

External Third Parties

YOUR LEGAL RIGHTS

You have the right to:

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.