AlleyBe Limited (hereinafter “AlleyBe”, “we”, “us”, or “our”) is committed to guarantee and safeguard the protection of your personal data, being either one of our Clients or Users, in line with our responsibilities under the General Data Protection Regulation. This Privacy Statement describes how we collect, process, use and disclose personal data and specifies the rights of individuals who provide us with their personal data either directly or indirectly.
For the purposes of this Statement, the term Client or Clients shall refer to any individual who either directly or indirectly requests and obtains our Services and the term User or Users shall refer to visitors of our website and/or visitors of our microsites and/or subscribers of our mailing list. References to “you” or “your” shall be construed to refer to you, the reader of this statement, being either our Client or User.
Personal data refers to information relating to an identified or identifiable individual natural person. The term processing of personal data refers to procedures whether in automated or manual mode, in which personal data is collected, recorded, organised, structured, stored, adapted or altered, retrieved, consulted, used, disclosed by transmission, disseminated or otherwise made available, alignment, or combination, restriction, erasure or destruction.
2. Purpose of this Privacy Statement
The purpose of this Privacy Statement is to set out:
- the personal data that will be collected from you;
- the legal basis of the processing of your personal data;
- our obligations under the General Data Protection Regulation with regards to the processing of your personal data;
- your data protection rights.
In processing personal data AlleyBe ensures that it adheres with the General Data Protection Regulation (Regulation (EU) 2016/579) and ensures that the said data is:
- processed lawfully, fairly and in a transparent manner;
- collected for specified, legitimate and explicit purposes and not further processed in a manner that is incompatible with those purposes;
- processed in a manner that is adequate, relevant and limited to what is necessary for the purposes of processing;
- processed accurately and kept up to date;
- kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal data was processed; and
- processed securely.
3. Who are we?
4. Collection of Personal Data
Personal Data of Clients and Users is collected and processed by AlleyBe in accordance with the purpose underlying such processing. AlleyBe is responsible for the treatment and purposes that will be given to personal data.
AlleyBe uses various methods of processing of personal data namely:
a) Information you give to us in furtherance of being provided with a Service.
The information you give us depends on the Service requested from us, and can include information such as name, surname, passport number, passport issuing country, passport expiry date, nationality, date and place of birth, residential address, phone number, email address, information on tax residency such as country of tax residence and tax identification number, and other information as may be related to the Service you are requesting including information on personal tax matters, wealth, banking , family and other matters related to business involvements, academic and work background, investments and other financial interests. Once we collect your personal data, you will be provided with a Data Protection Statement which further describes how and why we are processing your information.
Where we are obliged to process your personal data in fulfilment of a legal requirement to which we are subject, or in pursuance of performing an obligation under a contract which we have with you, and you fail to provide us with that data, we may not be able to perform the Services as agreed upon.
When information is collected in your regard from a third party, we ensure that such third party would be acting on your instructions.
b) Visiting our website.
Whenever you visit and browse our website, we will automatically collect the following information on you:
- the browser types and versions used,
- the operating system used by the accessing system,
- the website from which an accessing system reaches our website (referrer),
- the date and time of access to the Internet site,
- an Internet protocol address (IP address),
- the Internet service provider of the accessing system, and
- any other similar data and information that may be used in the event of attacks on our information technology systems.
c) Subscribing to our mailing list.
When you subscribe to our mailing list, we will process data including your name, surname, email address and contact details to provide you with material related to the services we offer. You have the right to unsubscribe from our mailing list at any time.
d) Third party information.
AlleyBe may use third party information through various analytics facilities to obtain reports and analyse the effectives of our website and microsites.
5. Legal Basis for Processing.
Our policy restricts us to collect only personal data as is required and necessary in pursuance of a one or more of the following:
- on the basis of a legal obligation to which we are subject;
- in pursuance of the performance of a contract to which you and we are party;
- based on your express consent.
6. How do we use your information?
The information you give us shall be used in pursuance of the provision of our services, in fulfilment of a contract we are about to enter or have entered with you, where it is required in pursuance of the fulfilment of a legal obligation to which we are subject or a legitimate interest, in pursuance of addressing any complaints or reports you might have lodged with us, or to manage our relationship with you, and in accordance with the consent you would have expressly given to us.
The information we collect from our website is used to administer our website for internal operations and to keep our website safe, to improve it and ensure effective content, and to ensure a user-friendly display.
The information you provided us for marketing purposes will be used to send you communication relating to the services we offer. You will only receive such marketing material if you have expressly consented and opted-in to receive such information.
7. Data Protection Storage and Retention
The period for which your data will be stored varies depending on the purpose or purpsoes for which such data is processed.
Information you provided to us: Personal data will only be stored as is strictly necessary for the purposes for which it was collected. In any circumstance, data retention shall not exceed ten years from the date of termination of the purpose of which it was collected. The period of retention of data takes into account relevant provisions of the applicable law including legislation related to the Prevention of Money Laundering and Funding of Terrorism, accounting and tax law. The period of retention also enables us to use the data for defending potential legal claims.
Information obtained from our website: The personal data of our sites and microsites will be preserved for as long as they remain active.
Information on our mailing list: personal data you provided in pursuance of subscribing to our mailing list to receive communication related to our services, will be retained until the end of your subscription. You can subscribe at any time by pressing the unsubscribe button in our newsletters.
8. Sharing of personal data
Your personal data will not be disclosed or shared with third parties, unless otherwise indicated to you in the Data Protection Statement shared with you, in this Privacy Statement or unless consented by you. Your personal data can be shared with our group companies, namely AlleyBe Trustees Malta Limited (C75016) who may act as joint controller.
We may also share your data with other third parties, in pursuance of the provision of our services, and in accordance with the purpose of the processing and/or on the basis of your consent.
Transferring of data outside of the European Union, particularly to countries which might not have appropriate data protection safeguards in place, will be based on your consent.
9. Data Security
The processing of your data will be processed and treated in accordance with the provision of the General Data Protection Regulation. AlleyBe takes reasonable precautions to preserve your data protection rights and prevent any corruption, loss, damage or destruction of your personal data. AlleyBe has reasonable security arrangements, including where appropriate, physical, administrative, procedural, and information and communications technology measures to prevent unauthorised or accidental access, collection, use, disclosure, copying, modification, disposal or destruction of personal data. In case our systems are compromised by virtue of a data breach by third parties, and personal data rights of our Clients or Users are violated or there it is likely that that a significant risk to their rights and freedoms will be posed, AlleyBe will take all the necessary measures to inform the data subject concerned of the said breach and the supervisory authority.
AlleyBe’s employees have access to Clients’ and Users’ personal data as is strictly necessary for the performance of their duties. All employees are informed of the confidential nature of personal data, have undertaken appropriate training relating to the handling and processing of personal data and are aware of AlleyBe’s duties towards its Clients and Users.
10. Right to withdraw consent
With regards to revoking your consent to receive marketing communication from us through your subscription to our mailing list, you have the facility to press the unsubscribe button to our newsletters. This will lead to the immediate removal of your personal data from our mailing list.
Withdrawal of your consent will not affect the lawfulness of processing which we carried out on the basis of such consent, prior to its withdrawal.
Once your withdrawal request has been received, your data will no longer be processed for the purposes on the basis of which such consent was given, however, your data will still be processed in case processing is applicable under any other legitimate basis provided under the law.
11. Changes to this Privacy Statement
Any changes made to this Statement in the future will be posted on this page and made available to the public. Where appropriate, changes to the purposes of processing will be notified by email to yourself.
AlleyBe uses data storage devices, which are small text files called ‘cookies’ which are placed on your hard drive to assist in enhancing your browsing experience by displaying content that is more relevant and applicable to you and your preferences. The use of such mechanism is only on the basis of your prior consent which you give when accessing our website for the first time. In order to register on our website, you need to accept cookies as disabling of cookies may lead to impairment in viewing our content. We hereby notify you that we do not sell any data or information which is obtained through cookies or other data storage mechanisms.
13. External Links
AlleyBe’s website may contain links to other websites or online platforms. AlleyBe is not responsible and does not endorse any of the content or systems adopted on such websites nor to other third-party sites which might be linked.
14. Individual Rights
Individuals, who are our Clients or Users, as data subjects, in accordance with the provisions of the General Data Protection Regulation, have a number of rights over their personal data which is provided to us. As data controllers, we have a number of obligations towards our Clients and Users which we strive to fulfil at all times.
The following are your main rights under the General Data Protection Regulation. If you wish to read in more detail information on the rights to which you are entitled, please refer to our declaration on Personal Data Protection Rights.
- right to access to personal data;
- right to confirmation on data being processed;
- right to rectification;
- right to erasure (right to be forgotten);
- right of restriction of processing;
- right to data portability;
- right to object;
- right to withdraw consent where processing is based on consent;
- right to lodge a complaint.
15. Complaints and Request for Information
Please check back frequently to see any updates or changes to this Privacy Statement.
Last reviewed: 16th May 2018