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Intel Ledger is your reliable partner in the field of consulting. Privacy Policy -

Politica sulla Privacy

Linerum OU (referred to as ‘we’, ‘us’, ‘our’, ‘Intel Ledger’) is committed to protecting your privacy and handling your data openly and transparently. The personal data we collect and process depends on the product or service requested and agreed upon in each case. The same commitment is applicable also when you use our website.

 

This privacy statement:

  • Provides an overview of how Intel Ledger collects and processes your personal data and tells you about your rights under the Processing of Personal Data (Protection of Individuals).
  • It is addressed to natural persons who transact with us in accordance with the services we offer in any way other than in an employment relationship.
  • It is addressed to natural persons who are either current or potential customers of Intel Ledger or are authorised representatives/agents or beneficial owners of legal entities or of natural persons/who are current or potential customers of Intel Ledger or employees of legal entities to whom we provide services.
  • It is addressed to natural persons who had a business relationship with Intel Ledger in the past and contained information about when we share your personal data with other members of Intel Ledger and third parties (for example, banks, auditors, our service providers or suppliers).
  • It aims to provide you with information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when raising an enquiry and/or during our contractual relationship.

 

In this privacy statement, your data is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal data or any such action as “processing” such personal data.

1. Definitions and Interpretation

In this Privacy Policy, the following terms shall have the following meanings:

  • Content means any text, graphics, images, audio, video, software, data compilations and any other information capable of being stored in a computer that appears on or forms part of this website.
  • Cookie means a small text file placed on your computer by Intel Ledger when you visit certain parts of our website. This allows us to identify recurring visitors and analyse their browsing habits within the website. To find out more about how we use cookies.
  • Personal Data have the meaning given to them in the GDPR, which is any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Intel Ledger means Linerum OU, its subsidiaries, affiliates, divisions, contractors and all of its and their data sources and suppliers.
  • Service means collectively any services provided by Intel Ledger either now or in the future.
  • System means any online communications infrastructure that Intel Ledger makes available through the website either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links.
  • User/Users means any third party that accesses the website and is not employed by Seamark.
  • You mean any person dealing with us or connected to the entities to which we provide services (including but not limited to trusts and companies). For example, you may be a client, intermediary, associate, family member, guardian, representative, advisor, director, settlor, beneficiary, trustee, protector, other officer or appointee, attorney, introducer, supplier, service provider, lender, borrower, or employee or agent of any of the above.

2. What personal data do we process, and where do we collect it from

We collect and process different types of personal data related to our activities, including when you use our website and when you contact or request information. We receive this personal data from our customers (potential and current) in person or via their representatives, suppliers and/or associates in the context of our business relationship.

We may also collect and process personal data, which we lawfully obtain from you and third parties, e.g. public authorities and companies that introduce you to us.

If you are a prospective customer or an authorised representative/agent or beneficial owner of a legal entity, or a natural person/who is a prospective customer, the relevant personal data which we collect may include:

Name, address, contact details (telephone, email), identification data, birth date, place of birth (city and country), marital status, employed/self-employed, if you hold/held a prominent public function (for Politically Exposed Persons), Foreign Account Tax Compliance Act / Common Reporting Standard info, authentication data (e.g. signature).

3. Children’s data

We understand the importance of protecting children’s privacy. We may collect personal data in relation to children only provided that we have first obtained their parents’ or legal guardian’s consent or unless otherwise permitted under law. For this privacy statement, “children” are individuals who are under the age of eighteen (18).

4. Whether you have an obligation to provide us with your personal data

So that we may be in a position to proceed with a business relationship with you, you must provide your personal data, which are necessary for the required commencement and execution of a business relationship and the performance of our contractual obligations. We are furthermore obligated to collect such personal data given the provisions of the money laundering law, which require that we verify your identity before entering into a contract or a business relationship with you or the legal entity for which you are the authorised representative/agent or beneficial owner. You must, therefore, provide us with your identity card/passport, your full name, place of birth (city and country), and your residential address so that we may comply with our statutory obligation as mentioned above.

Kindly note that if you fail to provide us with the required data, we may be prevented from conducting business with you, and we may be unable to provide our services to you or an entity connected to you. Also, the failure to provide certain personal data in certain circumstances may trigger a requirement for us or any of our employees or agents to consider whether to disclose under applicable legislation against money laundering and the financing of terrorism.

5. Why do we process your data, and on what legal basis

As mentioned earlier, we are committed to protecting your privacy and handling your data openly and transparently. As such, we process your personal data in accordance with the GDPR and the local data protection law for one or more of the following reasons:

 

For the performance of a contract

 

We process personal data to perform administrative and other professional services based on contracts with our customers but also to complete our acceptance procedure to enter into a contract with prospective customers.

The purpose of personal processing data depends on the requirements for each product or service. The contract terms and conditions provide more details of the relevant purposes.

 

You have provided your consent 

 

Provided that you have given us your specific consent for processing (other than for the reasons set out hereinabove), then the lawfulness of such processing is based on that consent. You have the right to revoke consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected.

6. Who receives your personal data

In the course of the performance of our contractual and statutory obligations, your personal data may be provided to various departments within the Company but also other affiliated companies. Various service providers and suppliers may also receive your personal data so that we may perform our obligations. Such service providers and suppliers enter into contractual agreements with either the Company or directly with the companies for which we provide services. They observe confidentiality and data protection according to the data protection law and GDPR.

It must be noted that we may disclose data about you for any of the reasons set out hereinabove, or if we are legally required to do so, if we are authorised under our contractual and statutory obligations or if you have given your consent. All data processors appointed by us to process personal data on our behalf are bound by a contract to comply with the GDPR provisions.

7. To what extent there is automated decision-making, and whether does profiling takes place

In establishing and carrying out a business relationship, we generally do not use automated decision-making. We may process some of your data automatically to assess certain personal aspects (profiling), to enter into or perform a contract with you in the following cases:

  • Data assessments are carried out to combat money laundering and fraud. These measures may also serve to protect you.
  • To calculate your company’s risk under the Prevention and Suppression of Money laundering and Terrorist Financing Law.

8. How long do we keep your personal information for

We will keep your personal data for as long as we have a business relationship with you or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.

Once our business relationship with you has ended, we may keep your data for at least four (4) years.

 We may keep your data for longer than 4 years if we cannot delete it for legal, regulatory or technical reasons.

For prospective customer personal data [or authorised representatives/agents or beneficial owners of a legal entity prospective customer], we shall keep your personal data for 5 months from the date of withdrawal of your application for administrative services and/or other services we offer. As soon as the 5 months period has lapsed, we will destroy that personal data. For the applications we reject, the personal data we receive will be destroyed immediately unless otherwise advised by you. 

9. Your data protection rights

You have the following rights in terms of the personal data we hold about you:

 

  • Receive access to your data. This enables you to, e.g. receive a copy of the personal data we hold about you and to check that we are lawfully processing it. To receive such a copy, you can request it by sending an email. 
  • Request correction [rectification] of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to erase your personal data [known as the ‘right to be forgotten’] where there is no good reason for us to continue to process it.
  • Object to processing of your personal data where we are relying on a legitimate interest, and there is something about your particular situation which makes you want to object to processing on this ground. If you object, we will no longer process your data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.
  • Request the restriction of processing of your personal data. This enables you to ask us to restrict the processing of your personal data, i.e. use it only for certain things, if:

 

  • It is not accurate.
  • It has been used unlawfully, but you do not wish for us to delete it.
  • It is not relevant anymore, but you want us to keep it for use in possible legal claims.
  • You have already asked us to stop using your personal data, but you are waiting for us to confirm if we have legitimate grounds to use your data.

 

  • Request to receive a copy of the personal data concerning you in a format that is structured and commonly used and transmits such data to other organisations. You also have the right to have your data transmitted directly by ourselves to other organisations you will name (known as the right to data portability).
  • Withdraw the consent that you gave us with regard to the processing of your personal data at any time. Note that any withdrawal of consent shall not affect the lawfulness of processing based on consent before it was withdrawn or revoked by you.
  • Right to complain. If you have exercised any or all of your data protection rights and still feel that we have not adequately addressed your concerns about how we use your personal data, you have the right to complain by sending an email. 

 

To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us by sending an email.

10. Data Security

Data security is of great importance to Intel Ledger. To protect your Personal Data, we have put in place appropriate measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

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

11. Changes to this privacy statement

We may modify or amend this privacy statement from time to time. We will notify you when we make changes to this privacy statement. However, we encourage you to review this statement periodically to be informed about how we process and protect your personal information.

Contact Us

Don’t hesitate to contact us if you have any questions.