Effective date: 17/07/2020
SUMMARY OF HOW WE USE YOUR DATA
- What do we do with your information and what is the legal basis for this use? Istari Global Limited as well as its affiliates, subsidiaries and related entities (also referred to as "Istari", "we" or "us"), use your personal data to provide you with the services you request from us, to inform you of our services and for other purposes as set out in this notice.
- Disclosure: Data is shared with companies in the Istari group, third party service providers and professional advisers.
- Your rights: You have certain rights in relation to your personal data under applicable laws, including a right to object to some of the processing which Istari carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.
INFORMATION WHICH WE MAY OBTAIN ABOUT YOU
We collect and process personal data about you when you interact with us and our websites (e.g. submitting an online form to us via our website). This includes:
- your contact information (e.g. name, telephone number, email address, organisation, department, job title);
- your marketing preferences, including any consents you have given us (if applicable);
- information related to the browser or device you use to access our sites, including where available, your IP address, operating system and browser type, for system administration and security reasons and to collect aggregate information.
WHAT INFORMATION ABOUT YOU DO WE RECEIVE FROM THIRD PARTIES?
- your contact information and information related to your profile, when you interact with us on social media platforms such as Facebook, LinkedIn, and Twitter (depending on your privacy preferences on those platforms);
- usage and technical information through cookies and related tracking technologies, such as Google Analytics (please see our Cookie Notice for more details).
WHAT WE DO WITH YOUR INFORMATION AND WHAT IS THE LEGAL BASIS FOR THIS?
We may use your personal data for the following purposes:
- as required by Istari to conduct our business and pursue our legitimate interests, in particular:
- responding to requests which you have submitted via our site or telephone or email or any other means and to deal with on-going matters relating to such requests;
- communicating with you about your application for recruitment purposes, to respond to your inquiries and schedule interviews, and to verify the details you have supplied;
- presenting content from our site in the way that we consider most effective;
- as part of our efforts to keep our sites safe and secure, to run our business, provide administration and IT services, network security, to prevent or detect fraud misrepresentation, security incidents or crime, in accordance with applicable law;
- using information you provide to investigate any complaints received from you or from others, about our website or our services;
- using data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation);
- notifying you about changes to our services, where applicable.
- where you give us consent (if required):
- providing you with information relating to Istari or promotional details about services that may be of interest to you, as well as marketing mailings (electronic or otherwise) or other communications;
- placing cookies and using similar technologies in accordance with our Cookie Notice and the information provided to you when those technologies are used;
- on other occasions where we ask you for consent, we will use the data for the purpose which we explain at the time.
- for purposes which are required by applicable law, such as:
- in response to requests by government or law enforcement authorities conducting an investigation;
- to comply with the requirements imposed by law or any court order.
WITHDRAWING CONSENT OR OTHERWISE OBJECTING TO DIRECT MARKETING
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
WHO WILL WE SHARE THIS DATA WITH, WHERE AND WHEN?
Istari may disclose your personal data to the following categories of recipients (in all cases, only when necessary to fulfil their functions):
- our staff (including employees and external consultants), professional advisors (including lawyers, auditors, etc.) and agents.
- third party service providers which process your personal data on behalf of Istari and who are bound by contractual obligations to keep your personal data confidential and appropriately secure. In particular, we use third party providers of website hosting, backend service provider, analytics, crash reporting, and email marketing.
- government authorities, regulatory agencies and law enforcement officials, if required for the purposes specified above, if mandated by law, or if required for the legal protection of our legitimate interests in compliance with applicable laws.
- if there is a corporate sale, merger, reorganisation, insolvency event or other similar event.
We have offices in UK, Singapore, Germany and US. Therefore, where required to perform our contract with you or for our wider business purposes, the information that we hold about you will be transferred to, and stored at, a destination in UK, Singapore, Germany and US.
In situations where we transfer your personal data to countries outside of UK or the EEA to an organisation in a country which is not subject to an adequacy decision by the EU Commission or considered adequate as determined by applicable data protection laws, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the applicable laws by using the European Commission approved Standard Contractual Clauses, an appropriate Privacy Shield certification, a vendor's Processor Binding Corporate Rules or by relying on such other data transfer mechanisms as available under applicable data protection laws.
Where we transfer Personal data to another Istari entity outside of UK or the EEA, we use the European Commission approved Standard Contractual Clauses. A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.
WHAT RIGHTS DO I HAVE?
Subject to applicable laws, you may have rights in relation to your personal data. Such rights include:
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us using the details set out below. If you are in the EEA/UK and you have unresolved concerns, you have the right to complain to an EEA/UK data protection authority where you live, work or where you believe a breach may have occurred.
We will aim to respond to all legitimate requests as soon as we reasonably can and in any event within one month. If we think that it will take us longer than one month, we’ll let you know why and keep you updated. Where you make any requests, we might ask for specific information to confirm your identity as a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. This might include asking for further information in relation to your request to be able to speed up our response.
HOW TO GET IN TOUCH WITH US
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at email@example.com with “privacy” in the subject line, or by writing to ISTARI GLOBAL LIMITED, 8th Floor 20 Farringdon Street, London, United Kingdom, EC4A 4AB.
HOW LONG WILL YOU RETAIN MY DATA?
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future. For personal data we collected for recruitment purposes, we will retain your personal data only for as long as we need it for Istari's legitimate interest in accordance with applicable law, for the purposes of the recruitment process and, once this process is finished, for an appropriate period so as to be able to deal with any legal claims linked to the application process.
Which Istari entity is my data controller, and which affiliates might my data be shared with?
The data controller for your information is Istari Global Limited. Depending on where you are, we may share your personal data with our affiliates so that we can response to your request or for our wider business purposes. You can obtain the identity and contact details on our affiliates with who we share your personal data by contacting us using the details set out above in this notice.
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.