Please learn the next Privateness Assertion (the “Assertion”) rigorously to know how and why our net servers use your private knowledge so as so that you can entry and browse
our web site https://www.henleypassportindex.com/ (the “Web site”).
Henley & Companions
Henley & Companions Group is a world group of corporations which supplies citizenship and residence planning companies to purchasers and advisory companies to governments everywhere in the world.
Henley & Companions Group is made up of various authorized entities, particulars of which may be discovered right here. This Privateness Assertion (the “Assertion”) is issued on behalf of Henley & Companions Group so after we point out “Henley & Companions”, “we”, “us”, “our” on this Assertion, we’re referring to the related entity within the Henley & Companions Group liable for processing your knowledge. We’ll let you understand which entity would be the knowledge controller to your knowledge while you receive any of our companies.
Henley & Companions Group Holdings Ltd (Firm Registration No. C 58006), of Malta, is the Information Controller and liable for this Web site.
Our full particulars are:
Henley & Companions Group Holdings Ltd
Degree 4, Aragon Home,
St. Julian’s STJ 3140
Cellphone: + 356 2138 7400
We’ve structured our Web site so that you could go to us on the Web with out figuring out your self or revealing any private info.
When you select to supply us with private info, we’ll defend such info and use it solely within the methods as described beneath.
Objective of this Assertion
We’re dedicated to respecting and defending your privateness always. Henley & Companions is not going to promote, hire, switch, or in any other case make out there to others any details about any individual visiting our Web site besides as expressly supplied for on this Assertion.
The aim of this Assertion is to:
- set out the kind of private knowledge Henley & Companions will accumulate from you and the way we’ll use your private info – particularly see part A “Private Information we accumulate from you”.
- the idea on which any private knowledge is processed by Henley & Companions – see sections B “How we use your info” and C “Authorized foundation for processing”.
- make you conscious of how Henley & Companions will deal with your private knowledge;
- make clear Henley & Companions obligations beneath the information safety rules as regards to processing your private knowledge lawfully and responsibly; and
- inform you of your knowledge safety rights – see part Ok “Your rights as an information topic”.
We course of your private knowledge in an acceptable and lawful method, in accordance with relevant knowledge safety rules and the Normal Information Safety Regulation EU 2016/679 (the “GDPR”) which is in power as of 25 Might 2018.
We’ll adjust to native knowledge safety legal guidelines in jurisdictions we function in and to take action the private info we maintain about you have to be:
- utilized by us lawfully, pretty and in a clear approach;
- collected just for legitimate functions that we now have clearly defined to you and never utilized in any approach that’s incompatible with these functions;
- related to the needs we now have instructed you about and restricted solely to these functions;
- correct and saved updated;
- saved solely so long as mandatory for the needs we now have instructed you about; and
- saved securely.
This Assertion ought to be learn together with our Cookie Coverage and some other Privateness Discover we could present on particular events after we are amassing or processing private knowledge about you so that you’re absolutely conscious of how and why we’re utilizing your knowledge.
This Assertion was final up to date in Might 2018.
A. PERSONAL DATA WE COLLECT FROM YOU
Via this Web site, you could contact our representatives and acquire info referring to the residence and/or citizenship packages or the companies supplied by Henley & Companions Group and begin the method of acquiring any of the companies in which you’ll have an interest. You might also contact us if you’re in search of a profession alternative, or want us to offer you additional info to help your press/media work. You might also contact us for normal inquiries or if you’re planning to be a provider to us.
We’ll accumulate and course of the next private knowledge about you:
1. Data You Give Us
These are private particulars and embrace your first title, final title, nationality, nation of residence, e-mail tackle and telephone quantity. They may also embrace info on which companies you have an interest in or particulars about your enquiry. The data you give us may embrace knowledge about any advertising and marketing desire.
Such info could also be supplied by you within the following circumstances: (i) by filling in an enquiry kind on the Web site; (ii) by corresponding with us by submit, telephone e-mail or in any other case while you apply for our companies; (iii) subscribe to our companies or publications; (iv) request advertising and marketing to be despatched to you; (v) give us some suggestions or (vi) to start out negotiations for or getting into right into a contract to provide items and/or companies to us.
To the extent you interact our companies or the place you may apply for a job alternative you could be required to supply additional info. The place you’re a enterprise person, we may require additional info earlier than we enter right into a industrial relationship with you.
Such additional info could embrace cost particulars akin to banking info, VAT quantity and/or tax ID to ensure that us to course of funds in relation to our companies. We may require you to supply us with info that is perhaps wanted to determine and function proof of your identification akin to copies of your passport or nationwide ID. The place you’re a job applicant you can be required to supply a duplicate of your up-to-date CV.
The place we’re amassing or processing additional info we’ll offer you separate Privateness Notices which additional describe how and why we’re utilizing your private knowledge.
The place we’re required to gather private knowledge by regulation, or beneath the phrases of a contract we now have with you and also you fail to supply that knowledge when requested, we could not be capable of carry out the companies as agreed or we could not be capable of enter right into a contract with you however we’ll notify you if so on the time. We could need to terminate that contract with you in consequence.
2. Data We Accumulate About You From Our Web site
Everytime you go to our Web site we’ll robotically accumulate the next:
- Technical info: together with the IP tackle used to attach your pc to the Web, your login info, browser kind and model, the complete Uniform Useful resource Locators (URL), clickstream to, by means of and from our Web site (together with date and time) in addition to different info relating to your expertise on our Web site akin to web page response instances, obtain errors, size of visits to sure pages, web page interplay info (akin to scrolling, clicks, and mouse-overs), strategies used to browse away from the web page.
- Location Data: We could obtain details about your location. We could decide your location by means of your IP tackle and, when accessing the Web site by means of a cell gadget, through the use of the information that we accumulate from this gadget. This consists of details about the wi-fi networks or cell towers close to your cell gadget on the time of entry.
3. Data we obtain from different sources
We could obtain private knowledge about you from numerous third events and publicly out there sources as set out beneath:
- Technical Information from Google Analytics Promoting Options, together with Google AdWords, Fb Pixel’s, Google Tag Supervisor, Amiando, Microsoft Dynamics, LinkedIn, Gmail and different Adhoc paid media partnerships.
- Identification, Contact and Background Information from publicly out there sources, compliance databases and/or compliance and due diligence service suppliers inside and out of doors the EU so we will verify you’re a appropriate consumer of or provider to us.
B. HOW WE USE YOUR INFORMATION
1. Data you give to us
We will use this info:
- to facilitate the supply of companies which you request and the place we have to carry out the contract we’re about to enter into or have entered into with you;
- the place it’s mandatory for our professional pursuits (or these of a 3rd get together) and your pursuits and basic rights don’t override these pursuits;
- the place we have to adjust to a authorized or regulatory obligation;
- to resolve any points which you will have reported and supply help associated companies; or
- handle the provider relationship you will have with us.
2. Data we accumulate about you from our Web site
We will use this info:
- to manage our Web site and for inside operations, together with troubleshooting and in an effort to hold our Web site protected and safe;
- to enhance our Web site to make sure that content material is offered in the simplest method for you; and
- to make sure that content material displayed on the Web site is offered in a user-friendly method.
3. Data we accumulate about you from our Web site
We’ll mix info we obtain from different sources with info you present to us and knowledge which we accumulate from you. We’ll use your info just for functions as described within the paragraphs above.
C. LEGAL BASIS FOR PROCESSING
We will solely course of your private knowledge insofar as that is mandatory for us to have the ability to present the companies we provide and/or for the needs indicated on this Assertion.
We may course of your private knowledge on the idea of any professional curiosity or in an effort to adjust to any authorized obligations at regulation. This may occasionally embrace the train or protection of authorized claims or in an effort to adjust to an order of any court docket, tribunal or authority or disclosure to a authorities or regulatory entity.
Typically we don’t depend on consent as a authorized foundation for processing your private knowledge. Nonetheless the place your consent is required we’ll offer you a kind requesting (express) consent to take action.
You’ll obtain advertising and marketing communication when you have requested such advertising and marketing info from us by offering us together with your particulars by means of this Web site and have consented and opted-in to receiving such info. The place we now have entered right into a enterprise relationship, i.e. a contract, with you we could inform you about our actions, gives or different info which we consider can be helpful to you in accordance with our professional curiosity.
We’ll centralize the supply of promoting communications by means of Henley & Companions South Africa (Pty) Ltd, a Henley & Companions entity primarily based in South Africa. The aim of doing so is to make sure that you obtain the advertising and marketing communications you will have consented to and that no additional advertising and marketing info is shipped to you. Since, in sure circumstances this may represent a switch of non-public knowledge exterior the European Financial Space (the “EEA”), please check with Part E “Disclosure of your info” beneath which additional outlines the style through which we switch private knowledge exterior the EEA and the suitable safeguards we undertake.
We is not going to share your private knowledge with any third get together for advertising and marketing functions with out your express consent.
You’ve gotten the correct to withdraw consent or to object to obtain advertising and marketing info at any time by contacting [email protected] or clicking unsubscribe. When you select to not consent or to object to any one of many functions listed herein or withdraw your consent at any time, we’ll nonetheless be capable of present our companies, nonetheless, we might not be capable of offer you the complete vary of companies which we provide and it could have an effect on the effectivity with which we offer the companies you request.
E. DISCLOSURE OF YOUR INFORMATION
We could disclose your private knowledge to any of our worldwide places of work/corporations forming a part of Henley & Companions Group who could act as joint knowledge controllers or knowledge processors to the corporate which would be the knowledge controller to your knowledge while you receive our companies and/or could present administration, controls and reporting companies. For a full record of the Henley & Companions Group corporations who could obtain this info, please click on right here. All Henley & Companions Group corporations respect and defend the safety of your private knowledge in accordance with the relevant regulation (together with the GDPR) and apply the safety measures and safeguards as described beneath.
We could must share private knowledge with authorities companies and authorities within the nation the place you search to acquire residence or citizenship. We will solely present the mandatory info in an effort to carry out companies beneath our contract with you.
We could require to share your knowledge with native brokers or different service suppliers (of their capability as knowledge processors) which is important for us to supply the companies you request. These native brokers and suppliers retailer and course of your knowledge on the idea of strict confidentiality and topic to the suitable safety measures and safeguards in place as described beneath.
We may share your knowledge with different third events of their capability as knowledge controllers akin to authorized, tax, actual property, immigration or different advisors and consultants, (worldwide) banks for cost particulars or third events offering different or further companies or items to you akin to actual property companies/house owners/builders who you may want to interact with beneath separate phrases and situations between you and such third events. These third events can be processing your knowledge in their very own proper as knowledge controllers and their knowledge safety insurance policies and processes shall be turn into relevant.
We may disclose your knowledge if we’re beneath an obligation to reveal or share your private knowledge to adjust to any authorized obligation, judgment or beneath an order from a court docket, tribunal or authority. We may disclose your knowledge to implement our Phrases of Use, or to guard our rights, property or security, that of our companions or different customers of our Web site. This consists of exchanging info with different corporations and organizations for the needs of Anti-Cash Laundering/KYC checks, Anti-Bribery/Corruption Legal guidelines compliance and/or fraud safety.
F. TRANSFERS OF DATA TO THIRD COUNTRIES
The place we share your private knowledge with inside or exterior third events, this may increasingly contain transferring your knowledge exterior the EEA. We’ll switch your private knowledge in accordance with customary contractual clauses (European Fee: Mannequin contracts for the switch of non-public knowledge to 3rd international locations) to make sure your private knowledge is protected and transferred securely in compliance with relevant regulation, together with the GDPR.
Henley & Companions Group Holdings Ltd acts because the EU Information Consultant of all our places of work situated exterior the EEA. Chances are you’ll tackle any points, queries or considerations which you’ll have to Henley & Companions Group Holdings Ltd by sending an e-mail with ‘Information Safety’ within the topic line to the next tackle: [email protected]
G. THIRD PARTY ACCESS TO YOUR PERSONAL DATA
We work intently with third events in an effort to present you the companies you request on our Web site. These third events embrace cloud storage suppliers, analytics suppliers and search engine info suppliers. We’ll solely work with third get together suppliers that adjust to relevant legal guidelines within the jurisdictions which we function and abide by the GDPR and, if relevant, conform to be sure by the usual contractual clauses to adequately defend and safeguard your private knowledge.
H. DATA SECURITY
We’ll be certain that acceptable safety measures are taken in opposition to illegal or unauthorized processing of non-public knowledge, and in opposition to the unintended lack of, or harm to, private knowledge.
The switch of knowledge between our Web site and your gadget is protected with TLS (Transport Layer Safety) certificates. When the Web site is accessed utilizing suitable browsers, that know-how protects private info utilizing each server authentication and knowledge encryption to make sure that private info is protected and safe whereas in transit. The mainstream browser variations suitable with that know-how are the Web Explorer from model 11, the Mozilla Firefox from model 27, the Google Chrome from model 32 and the Apple Safari from model 7.
All private knowledge is saved in a safe server setting that makes use of a firewall and different superior know-how to guard in opposition to interference or unauthorized entry. Servers are situated in Malta and in Switzerland. Usernames and passwords are issued to individuals licensed to entry the private knowledge, akin to our staff, who’re sure by confidentiality to not disclose any private knowledge.
No technique of transmission of knowledge is a hundred percent (100%) safe and absolute safety can’t be assured.
I. DATA STORAGE
We will solely retailer your knowledge so long as is strictly mandatory for the needs for which it was collected i.e. to supply you our companies or for the needs of satisfying any authorized, accounting or reporting necessities. In any case, retention of knowledge shall not exceed 10 years from the date of termination or completion of the companies. This era of retention allows us to make use of the information for defending potential authorized claims, taking into consideration the relevant limitation durations beneath related legal guidelines, in addition to, if relevant, to adjust to Anti-Cash Laundering/KYC legal guidelines and rules, Anti-Bribery/Corruption Legal guidelines and rules, accounting and tax legal guidelines, relevant to sure jurisdictions which we function in.
J. DATA MINIMIZATION
At any time when and to the extent attainable, we anonymize the information which we maintain about you when it’s not essential to establish you from the information which we maintain about you.
Ok. YOUR RIGHTS AS A DATA SUBJECT
You’re entitled to train the next rights beneath the GDPR:
a. Proper to Entry Data
You’ve gotten the correct to request info as as to whether or not your private knowledge is being processed by Henley & Companions in addition to info as to how and why it’s processed. Chances are you’ll ship an e-mail to [email protected] requesting info as to the private knowledge which is present process processing. You shall obtain one (1) digital copy freed from cost through e-mail. We could cost an affordable price in case your request is clearly unfounded, repetitive or extreme through which case we may refuse to conform together with your request in these circumstances.
b. Proper to object
Chances are you’ll contact us at any time at [email protected] to ask us to not course of your private knowledge for advertising and marketing functions e.g. receiving info from us about upcoming occasions, newsletters and publications and your knowledge will not be processed for such functions.
c. Proper to correction
You’ve gotten the correct to acquire correction of any inaccurate private knowledge about you that we now have processed, replace any knowledge which is out-of-date and the correct to have incomplete private knowledge accomplished, together with via a supplementary assertion.
d. Proper to erasure
You’ve gotten the correct to acquire the erasure of non-public knowledge we now have regarding you when your private knowledge is not required the place:
- you withdraw your consent to us processing your private knowledge;
- your private knowledge not must be processed; or
- your private knowledge has been unlawfully processed.
e. Proper to Restriction of Processing
You’ve gotten the correct to limit our processing actions the place:
- you contest the accuracy of this private knowledge, for a interval enabling Henley & Companions to confirm the accuracy of the identical private knowledge;
- our processing is deemed illegal, and also you oppose the erasure of your private knowledge and request restriction of its use as an alternative;
- we not want your private knowledge for the needs said on this Assertion, however you require it for the institution, exercising or defending of authorized claims; or
you will have objected to our processing pending the verification whether or not the professional grounds of our processing actions overrode these pertaining to you.
f. Proper to Restriction of Processing
As from 25 Might 2018, you shall have the correct to obtain your private knowledge in a structured and machine-readable format and transmit this knowledge to a different Date Controller (as outlined within the GDPR).
L. RIGHT TO WITHDRAW CONSENT
The place you’ll have supplied your consent to the gathering, processing and switch of your private info for a particular goal eg advertising and marketing, you will have the correct to withdraw your consent for that particular processing at any time or you could withdraw your consent to this Assertion. To withdraw your consent, please contact [email protected] This is not going to have an effect on the lawfulness of processing which we carried out on the idea of such consent earlier than its withdrawal. As soon as we now have obtained notification that you’ve got withdrawn your consent, we’ll not course of your info for that goal except we now have one other professional foundation for doing so in regulation. Withdrawal of consent to this Assertion will end in us having to terminate our companies instantly.
M. QUALITY OF WEBSITE AND OVERALL EXPERIENCE
In order to enhance the standard and general person expertise of the Web site in addition to facilitate occasion bookings and consumer occasion registrations, we’re utilizing Google Analytics Promoting Options, in addition to Xing Occasions, a subsidiary model of New Work SE, and Microsoft Dynamics CRM.
If you need to opt-out of Google Analytics for show promoting, you could accomplish that through the use of the Advertisements Choice Supervisor.
As well as, there’s additionally a Google Analytics Decide-Out browser add-on you could obtain at https://instruments.google.com/dlpage/gaoptout.
Chances are you’ll withdraw your consent given for any of the needs listed above at any time. This doesn’t have an effect on the lawfulness of your private knowledge for these functions previous to your withdrawal. Chances are you’ll ship us an e-mail at [email protected] indicating your withdrawal of consent and specify which processing actions such withdrawal pertains to.
We welcome any feedback, complaints and queries in relation to knowledge safety. As indicated above you could contact our Information Safety Officer at [email protected] and we will strive our greatest to take care of any challenge or concern you’ll have.
If we fail to deal with your considerations you will have the correct to lodge a criticism with the Data and Information Safety Commissioner (“IDPC”) at www.dataprotection.gov.mt because the related nationwide supervisory authority on all knowledge safety issues.
O. CHANGES TO THIS PRIVACY STATEMENT
Any adjustments we make to this Assertion sooner or later can be posted on this web page, and the place acceptable, notified to you through e-mail.
You probably have any questions relating to this Assertion, or if you need to ship us your feedback, please contact us at present or alternatively write to us utilizing the small print beneath:
Henley & Companions Group Holdings Ltd
Degree 4, Aragon Home,
St. Julian’s STJ 3140
Cellphone: + 356 2138 7400
Please examine again continuously to see any updates or adjustments to this Assertion.