Version dd. 07.03.2021
At Stone Bridge Capital (MFO) Ltd (hereinafter referred to as "we", "us", "our" or "SBC"), we are committed to protect privacy of information and personal data entrusted to us. We handle private information in an open, transparent manner.
THE PRIVACY STATEMENT SET BELOW, APPLIES TO PERSONAL DATA PROCESSED BY SBC, REGISTERED IN THE REPUBLIC OF CYPRUS UNDER REGISTRATION NUMBER HE371697 WITH REGISTERED OFFICE ADDRESS AT EPTANISOU 28, NICOLAOU & ZAVOS CENTER, OFFICE 402, AGIOS NICOLAOS, 3100 LIMASSOL, CYPRUS. IT DESCRIBES WHAT PERSONAL DATA OR INFORMATION WE GATHER ABOUT YOU, WHEN AND WHY WE USE THAT INFORMATION FOR AND TO WHOM WE GIVE THE INFORMATION. IT DEMONSTRATES YOUR RIGHTS IN RELATION TO YOUR DATA AND INDICATES WHOM YOU CAN CONTACT FOR ADDITIONAL INFORMATION OR QUERIES.
Read more about this privacy statement by referring to the specific paragraphs below:
To whom this privacy statement applies to and what it covers?
The legal grounds we use for processing personal information.
TO WHOM THIS PRIVACY STATEMENT APPLIES TO AND WHAT IT COVERS?
You can find how we will collect, handle, store and protect personal information about you when:
a) providing services to you or to our clients;
b) you use “our Website”;
c) we perform any other activities that form part of the operation of our business.
We may refer to information that identify or may identify you or that may otherwise relate to you as “personal data” or “personal information”. We may also sometimes collectively refer to collecting, handling, using, protecting and storing your personal information as “processing” such personal information.
When we refer to “our Website” or “this Website” in this policy, we mean the specific webpages of SBC at www.stonebridgecapital.eu.
Particular instances that we share your personal information with other members of the SBC and other third parties (for example, our service providers or suppliers) are described below.
WHAT INFORMATION DO WE COLLECT AND WHERE DO WE COLLECT IT FROM?
In the course of providing services to you as a client and particularly when performing due diligence checks in connection with our services (or discussing possible services we might provide to you as a prospective client), we may collect or obtain personal data about you. We may also collect personal data from you when you use our Website.
We may collect or obtain such data because you give them to us (for example in a form on our Website or through our “know-your-client” procedures), because other people give that data to us (for example your employer or adviser, or third party service providers that we use to help operate our business), or because it is publicly available.
The personal data that we collect or obtain may include without limitation: your name; age; date of birth; ID number; e-mail address; home address; country of residence; family circumstances (for example, your marital status and number of dependents); employment and education details (for example, the organization you work for, your job title and your education details); financial and tax-related information (for example your income and tax residency); your IP address; your browser type and language; your access times; complaint details; and other similar information.
The personal data that we may collect may also include ‘sensitive’ or ‘special categories’ of personal data, such as details about your health (for example, in relation to life and medical insurance), ethnic or racial origin. Please note that, when the processing of sensitive personal data is not allowed by law, an explicit consent from you will be required whenever we may have to obtain sensitive personal data about you so as to provide our services.
The types of personal data and special categories of personal data that we collect may vary depending on the nature of the services that we provide to you, or how you use our Website. In some rare circumstances, we might also gather other special categories of personal data about you, for example as a result of legal requirements imposed on us.
Where we have no direct contractual relationship with you but obtain your personal data about you by our client, we take steps to ensure that the client has complied with the privacy laws and regulations relevant to that information; this may include, for example, that the client has provided you with the relevant information notices in relation to how your personal data will be processed and disclosed to third parties such as Stone Bridge Capital (MFO) Ltd and has obtained any necessary consents for us to process your personal data as described in this privacy statement and/or our engagement with the client.
We understand the importance of protecting children’s privacy. Our Website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children. For the purposes of this privacy statement, “children” are individuals under the age of fourteen.
HOW WE USE INFORMATION ABOUT YOU?
We will only process your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
A) Where we need to perform the contract we have entered with you or in order to take certain steps prior to entering into a contract with you. We will use your personal data to provide you with our services. As part of this, we may use your personal data in the course of correspondence relating to the services. Such correspondence may be with you or other members of the Stone Bridge Capital (MFO) Ltd Network and our service providers or competent authorities. We may also use your personal data to conduct due diligence checks relating to the services. Because we provide a wide range of services to our clients, the way we use personal data in relation to our services also varies. For example, we might use personal data: when we provide business consulting and/or project management services to clients. If you do not provide the personal data we request from you, we may not be able to offer or continue offering our services to you.
B) Where we need to comply with a legal obligation. We are required to comply with certain legal and regulatory obligations, as well as certain industry standards, which may involve the processing of personal data. We may, for example, need to carry out identity verifications through our “know-your-client” procedures, set-up anti-money laundering controls and comply with our tax reporting obligations. We may also need to provide information to a public body or law enforcement agency when we are so required.
C) Where we have appropriate legitimate interests to use your personal data. In some cases, we may process your personal data to pursue business interests of our own or of third parties, provided your interests and fundamental rights do not override such interests. More specifically, we process your personal data:
- to maintain our accounts and records;
- to enhance the security of our network and information systems;
- to identify, prevent and investigate fraud and other unlawful activities;
- to safeguard the security of our people, premises and assets and prevent trespassing through video surveillance;
- to manage our infrastructure, business operations and comply with internal policies and procedures;
- for financial accounting, invoicing and risk analysis purposes;
- to modify, personalize or otherwise improve our services;
- to defend, investigate or prosecute legal claims;
- for recruitment and business development purposes;
- in order to receive professional advice from our advisors including our lawyers, accountants and consultants.
(D) Where you have given us your consent. We will only ask for your consent when we wish to provide marketing information to you in relation to our products and/or services that we think might be of interest to you. If you give us your consent, we may also contact you for market or research purposes from time to time.
You may withdraw your consent to such processing at any time by contacting email@example.com or by clicking on the “Unsubscribe” function in any marketing communications, including emails, that we send to you.
THE LEGAL GROUNDS WE USE FOR PROCESSING PERSONAL INFORMATION.
To the extent that we process any sensitive personal data relating to you for any of the purposes outlined above, we will do so because either:
a) you have given us your explicit consent to process that data;
b) the processing is necessary to carry out our obligations under employment, social security or social protection law;
c) the processing is necessary for the establishment, exercise or defense of legal claims;
d) you have made the data manifestly public.
In addition to the purposes connected to the operation of our business above, we may also use your personal data collected via our Website:
a) to manage and improve our Website;
b) to tailor the content of our Website and to draw your attention to information about our products and services that may be of interest to you, for example our seminars or presentations;
c) to manage and respond to any request you submit through our Website.
WHO WE DISCLOSE YOUR INFORMATION TO?
In connection with one or more of the purposes outlined in this privacy statement, we may disclose details about you to: other members of the Stone Bridge Capital (MFO) Ltd network; third parties that provide services to us and/or the Stone Bridge Capital (MFO) Ltd network including service promoting partners such as advertising agencies; competent authorities (including courts and authorities regulating us or another member of the Stone Bridge Capital (MFO) Ltd network); your employer and/or their advisers; your advisers; credit reference agencies or other organizations that help us make business decisions and mitigate the risk of potential fraud and misconduct, third parties who are involved in a potential or actual sale of all or a portion of Stone Bridge Capital (MFO) Ltd’s business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) and other third parties that reasonably require access to personal data relating to you for one or more of the purposes outlined in this privacy statement.
Our Website may host various social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Importantly, any personal information that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users and, therefore, we cannot guarantee that any information that you contribute to any Social Media Applications will be handled in accordance with this privacy statement.
Please note that some of the recipients of your personal data referenced above may be based in countries outside of the European Union. In such cases, we will ensure that there are adequate measures and safeguards in place to protect your personal data that comply with our legal obligations and that direct recipients shall provide the same level of protection as within the European Union.
In addition, we may request you to provide us with your specific consent in cases of transfers to countries where no adequacy mechanism is in place.
Further details of the transfers described above and the adequate safeguards used by Stone Bridge Capital (MFO) Ltd in respect of such transfers (including copies of relevant agreements) are also available from us by contacting Stone Bridge Capital (MFO) Ltd at firstname.lastname@example.org.
We may share non-personal, de-identified and aggregated information with other members of the Stone Bridge Capital (MFO) Ltd network for research and statistical purposes.
PROTECTION OF YOUR PERSONAL INFORMATION.
We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up to date. These measures include:
a) education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
b) administrative and technical controls to restrict access to personal data on a ‘need to know’ basis;
technological security measures, including fire walls, encryption and anti-virus software;
c) physical security measures, such as staff security passes to access our premises.
HOW LONG WE KEEP YOUR INFORMATION FOR?
We will hold your personal data on our systems for the longest of the following periods:
a) as long as is necessary for the relevant activity or services;
b) any retention period that is required by law;
c) the end of the period in which litigation or investigations might arise in respect of the services;
d) any retention period as per Stone Bridge Capital (MFO) Ltd’s official retention policy.
You have various rights, under the Data Protection regulation, in relation to your personal data. In particular, you have a right to:
A) Receive access to your personal data. You may request to obtain from ourselves a copy of the personal data we hold about you and to check that we are lawfully processing it.
B) Request correction (rectification) of the personal data about you which we process. This provides you with the opportunity to have any incomplete or inaccurate data we hold and process about you, completed and/or corrected.
C) Request erasure of your personal information. This right provides you with the opportunity request from us to erase personal data concerning you (known as the ‘right to be forgotten) where there is no good reason for us to continue to process it. Additionally, you also have the right to ask us to erase your data where you have exercised your right to object to processing (see Object to processing below).
D) Object to processing of your personal data, including profiling, where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
E) If you object to processing for direct marketing purposes, then we shall stop the processing of your personal data for such purposes.
F) Request the restriction of processing of your personal data. With this right you are able to ask us to suspend the processing of your personal data if:
- the said data is not accurate;
- it has been used unlawfully but you do not wish for us to delete it;
- it is not relevant any more, 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 are allowed to keep using it.
G) Request to receive a copy of your personal data in a format that is structured and commonly used and transfer such data to other organisations. You may request the transfer of your personal data directly by us to other organizations [data portability]
H) Withdraw your consent with regard to the processing of your personal data for certain purposes at any time. Note that any withdrawal of consent shall not affect the lawfulness of processing which was based on consent before it was withdrawn or revoked by you.
To exercise any of your rights, or if you have any other questions about our use of your personal data, please send an email to email@example.com or write to us to the address below:
Stone Bridge Capital (MFO) Ltd,
Eptanisou 28, Nicolaou & Zavos Center, Office 402,
Agios Nicolaos, 3100 Limassol, Cyprus.
You may also use these contact details if you wish to make a complaint to us relating to your privacy.
RIGHT TO COMPLAIN.
If you are unhappy with the way we have handled your personal data or any privacy query or request that you have raised with us, you have a right to complain to the Office of the Commissioner for Personal Data Protection in Cyprus. If you would like to be directed to the Office of the Commissioner, please contact us.
CHANGES TO THIS PRIVACY STATEMENT.
We may modify or amend this privacy statement from time to time.
To let you know when we make changes to this privacy statement, we will amend the revision date at the top. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.
In order to provide you with a more personalized and responsive service we need to remember and store information about how you use this Website. This is done using small text files called cookies. Cookies contain small amounts of information and are downloaded to your computer or other device by a server for this Website. Your web browser then sends these cookies back to this Website on each subsequent visit so that it can recognize you and remember things like your user preferences. You can find more detailed information about cookies and how they work at www.aboutcookies.org.
Some of the cookies we use are necessary to enable you to move around the Website and use its features such as accessing secure areas that may contain content for registered users.
We also use functional cookies to record information about the choices you have made and to allow us to tailor the site to our users; for example, to remember your language or region or that you have already completed a survey. This information is usually anonymized and is not used for any other purpose.
We or our service providers also use analytic services to help us understand how effective our content is, what interests our users have, and to improve how this Website works. In addition, we use web beacons or tracking pixels to count visitor numbers and performance cookies to track how many individual users access this Website and how often. This information is used for statistical purposes only and it is not our intention to use such information to personally identify any user. However, if you have registered and signed into this Website we may combine this information with information from our web analytic services and cookies to analyze how you use this Website in more detail.
This Website does not use Targeting Cookies to deliver targeted advertising to Website visitors.
You may provide us with your acceptance, by ticking the ‘Accept and close’ box, meaning that you consent that we can place cookies on your computer or device as explained above. However, you can control and manage cookies in various ways. Please bear in mind that removing or blocking cookies can impact on your user experience and parts of this Website may no longer be fully accessible.
Most browsers will allow you to see what cookies you have and delete them on an individual basis or block cookies from particular or all websites. Be aware that any preference you have set will be lost if you delete all cookies, including your preference to opt-out from cookies as this itself requires an opt-out cookie to have been set. For more information on how to modify your browser settings to block or filter cookies, see www.aboutcookies.org.
You can opt-out of having your anonymized browsing activity within websites recorded by analytics cookies. We use the following service providers and you can learn more about their privacy policies and how to opt-out of their cookies by clicking on following links:
A local shared object or flash cookie is like most other browser cookies except that it can store additional types of information. These cookies cannot be controlled using the mechanisms listed above. Some parts of this Website use these types of cookies to store user preferences for media player functionality and without them some video content may not play properly. These cookies can be controlled manually by visiting the Adobe website.
We sometimes use external web services on this Website to display content within the web pages of this Website, for example to display images, show videos or run polls. As with the social buttons, we cannot prevent these sites, or external domains, from collecting information on your use of this embedded content.
We may also use tracking technologies to determine whether you have read, clicked on, or forwarded certain email communications we send to you so that we can make our communications more helpful and interesting. If you do not wish us to confirm whether you have opened, clicked on or forwarded our communications, you will need to unsubscribe, as it is not possible for us to send these emails without tracking enabled. Registered subscribers can update their communication preferences at any time by contacting us, or you can unsubscribe following the instructions in the individual email communications you receive from us.
We may modify or amend this Cookie Notice from time to time at our discretion. When we make changes to this notice, we will amend the revision date at the top of this page, and such modified or amended Cookie Notice shall be effective as to you and your information as of that revision date. We encourage you to periodically review this Cookie Notice to be informed about how we are using cookies.
© 2021 Stone Bridge Capital (MFO) Ltd
the company duly registered in the Republic of Cyprus with registration number HE371697