Privacy notice

Ganado Management Limited privacy notice

Ganado Advocates (Malta) privacy notice

This version was last updated on 23rd April 2025

1. Introduction

Welcome to Ganado Advocates’ privacy notice (the “Notice”).

Ganado Advocates of 171, Old Bakery Street, Valletta VLT 1455, Malta (“Ganado”; “we”; “us”; “our”) respects your privacy and values its importance, and is wholly committed to protecting your personal data.

We are providing this Notice as the controller of your personal data. We process all personal data in an appropriate and lawful manner, in accordance with the Data Protection Act, Chapter 586 of the laws of Malta, and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), as may be amended from time to time.

This Notice explains how we will process your personal data when you:

approach and engage us to provide legal and advisory services (the “Services”);
receive the various Services that you may request from us during the course of this engagement; and/or
visit and use our website https://ganado.com (the “Website” or the “Site”), regardless of where you visit and use it from.

It also covers any data that you may provide for our newsletters, legislative updates, events and other marketing and promotional communications.

Where you are a client and a legal entity (i.e. not a natural person), we will also request and collect personal data about your directors, representatives, officers, authorised signatories, shareholders and ultimate beneficial owners (“UBOs”) (typically for anti-money laundering (“AML”), due diligence and other vetting requirements) (which we refer to in this Notice as an “individual connected to a business”). This Notice also explains how we process personal data about such individuals and should therefore be circulated accordingly. You must ensure that they are made aware of this Notice and the individual rights and information it sets out prior to us receiving their information (whether obtained directly, obtained from you or from other sources). If you, or anyone else on your behalf, has provided or provides information on an individual connected to your business to us (or any entity associated with Ganado), you or they must first ensure that you or they have that individual’s authorisation to do so and will be required to confirm the same to us.

Kindly note that, by engaging us as your lawyers or other advisors, you enter into a contractual relationship with Ganado, as subject to and governed by our Letter of Engagement. This Letter of Engagement stipulates that we will process your personal data in accordance with the practices set out in this Notice.

Please refer to the Glossary to understand the meaning of some of the terms used in this Notice.

When accessing our website, we may automatically collect certain information, in particular your IP Address. Please refer to our IP and Cookie Policy, for more information about how our website uses cookies.

2. Important information and who we are

This Notice aims to ensure that you are fully informed on how we will process your personal data in the scenarios set out in the Introduction (and also applies to any data that you may provide for marketing and promotional communications). It informs you about the items of personal data which we will collect about you and describes how we will handle it (regardless of the way you interact with us, directly or indirectly, whether by email or otherwise). It also provides information on how to exercise your rights as a data subject.

It is important that you read this Notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.

This Notice supplements the other notices and is not intended to override them.

Controller

Ganado (as defined above) is associated with various entities, most particularly its service companies Ganado Services Limited (C 10785) (“GSL”) and Ganado Management Limited (C 94704) (“GML”), both private limited liability companies, having their registered office at 171, Old Bakery Street, Valletta, VLT 1455, Malta.

We are the controller of any personal data which we collect or receive and process in connection with (i) the Services and/or (ii) the Website. Our associated entities may be controllers of your personal data in their own right, whether jointly with Ganado or as entirely independent controllers. For instance, GSL regularly assists Ganado in providing corporate services for its clients, which may give rise to certain data processing activities by GSL that are separate and autonomous to those conducted by Ganado.

These associated entities have their own separate data protection notices which will be made available to you if and when they process personal data about you.

We have a dedicated data protection team which serves as our internal data protection contact point and is responsible for overseeing queries in relation to this Notice and generally any requests made in relation to personal data.

If you have any question about this Notice, including any requests to exercise your legal rights (which are outlined in Section 10), please contact us using the contact details set out below. Please also use the words ‘Data Protection Matter’ in the subject line.

Our full details are as follows.

Contact details

Full name of legal entity: Ganado Advocates.

Email address: dp@ganado.com

Postal address: 171, Old Bakery Street, Valletta VLT 1455, Malta.

Duty to inform us of changes

It is imperative that the personal data we hold about you is accurate and current at all times. Otherwise, this will impair our ability to provide you with the requested Services (amongst other potential and salient issues). Please keep us informed if your personal data changes during the course of our engagement and professional relationship with you.

Third-party links

The Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notice or policies. We strongly encourage you to read the privacy notice of every website you visit, particularly when leaving our Site.

Minors

The Site is not intended for minors, and we do not knowingly collect data relating to minors except and unless necessary to provide you with the Services that you may request from us (most commonly, where they concern your family, including your children).

We will treat any information relating to minors which is disclosed to us in connection with the Services in a sensitive manner and with the utmost confidentiality.

3. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

In the course of any client engagement, Ganado will need to collect, use and occasionally disclose personal data for various purposes associated with the scope of the Services that we provide, either for yourself (the client) or your organisation (where you are an individual connected to a business). Given the broad spectrum of our potential Services, we cannot realistically provide an exhaustive list of all the items of personal data which we may need to process about our clients and/or the individuals connected to their business.

However, to ensure transparency, we have made an attempt to group and categorise below the different kinds of personal data about our clients or mere users of the Site that we (Ganado) may generally need to collect, process, use, share and store. For the reasons explained above, these data categories are mostly indicative and not exhaustive.

Identity Data includes first name, maiden name, last name, title, identity document number, gender, nationality, employment status, organisation, occupation and (in the context of the Site) username or similar identifier;

Contact Data includes billing, mailing and email address and contact numbers;

In the context of those clients who are legal persons, we may have to collect Identity and Contact Data about the following individuals connected to their business:

- directors;
- legal and judicial representatives;
- company secretary and other officers (for example, money laundering reporting officers, data protection officers and risk officers);
- internal (‘in-house’) legal counsel;
- auditors;
- shareholders and ultimate beneficial owners (UBOs);
- founders and board of administrators in the case of Foundation;
- settlors, beneficiaries, protectors and trustees in the case of a Trust

Compliance Data (AML and KYC) includes the following due diligence information and documentation relating to our clients and/or the individuals connected to their business : (i) copy of an identity document and utility billl; (ii) professional references; (iv) screening database checks; and (iv) any other documentation that may be mandated by applicable anti-money laundering or sanctions laws, or the Financial Intelligence Analysis Unit, or any other competent authority or related legislation;

Assistance Data includes the following information about our clients:

- the client’s legal or business requirements, situation, plans, interests and targets or objectives;
- the Services requested by, and provided to, the client;
- counter and adverse parties, related parties, parties in interest, business partners, witnesses, investors, assets, shareholders, security holders, guarantors, buyers, sellers and customers of the client, and Court decisions or orders issued in favour or against the client (to the extent relevant and necessary to provide the Services).

The above may also entail the collection, processing and retention of contracts, agreements, public deeds, testamentary dispositions, judicial acts and Court decisions pertaining to the client (as applicable and necessary for the Services).

Financial Data includes the bank account details of the client together with details about any payment methods used by the client to settle our invoices and, as may be necessary under the particular circumstances, the financial status and creditworthiness of the client.

Transaction Data includes details about (i) invoices issued to the client (including date of settlement and means of settlement), (ii) payments made to and from the client and (iii) any outstanding invoices due by the client.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices which you (whether a client or otherwise) use to access and browse the Website.

Profile Data includes information about the legal areas that may be of interest or relevance to you (based on the Services that you request from us), your feedback and survey responses.

Usage Data includes information about how you (whether a client or otherwise) use our Website.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties or associated entities and your communication preferences. This may include information whether you have subscribed or unsubscribed from any of our mailing lists, attended any of our events or accepted any of our invitations.

We will also collect, use and process any other personal information that you voluntarily choose to provide or disclose to us where relevant and necessary in order to provide the Services that you have requested from us. Any such information that we receive from you would fall under the ‘Assistance Data’ category.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the Website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Notice.

If you fail to provide personal data

Where we need to collect personal data by law, or pursuant to our terms of business and engagement, and you fail to provide that data when requested, we may not be able to assist you or provide you with your requested Services. In certain cases, particularly where it relates to Compliance Data, we may even need to exercise our prerogative to terminate the Services and your engagement with us, or otherwise decline to enter into professional relationship with you (as applicable). We will notify you if this is the case at the time.

Special categories of personal data

We may also need to occasionally process certain special categories of personal data about you as part of our statutory due diligence and sanction screening requirements. This may comprise personal data revealing your political opinions or affiliations, and also personal data relating to criminal convictions and offences or related security measures.

Below are the circumstances and purposes for which this may take place:

Initial and on-going customer due diligence checks: determination of whether or not the customer and certain persons related to the customer are “politically exposed persons” in terms of applicable AML legislation; and
Initial and on-going customer due diligence checks: due diligence checks via RiskScreen, WorldCheck, Google Searches, databases of regulatory or supervisory authorities, and other publicly accessible sources.

As a lawful basis, the processing of this data is necessary for reasons of substantial public interest on the basis of an EU or national law (namely, AML related) or otherwise relates to data which has been manifestly made public by the data subject.

There may be other occasions where we may need to process your sensitive personal data, namely where:

the processing is necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law or regulation; or
the processing is necessary for the establishment, exercise or defence of legal rights.

In other cases, for example where required as part of the Service provision, we will rely on your authorisation to process the special category of personal data.

The lawyers and other advisors that form part of Ganado are bound by strict professional secrecy obligations.

4. How is your personal data collected?

We generally use different methods to collect data from and about you including through:

Direct Interactions. You may give us your Identity, Contact, Compliance, Financial, Assistance and Marketing and Communications Data by completing our engagement letter, filling in and submitting our client forms (such as our ‘Contact Form’ at: https://www.ganado.com/contact),or by corresponding with us by post, phone, email or otherwise or during face-to-face meetings.

This includes personal data you provide when you:

- approach us to assist you on a particular matter;
- discuss with us the assistance that you require (whether via meetings, telcos or email correspondence);
- enter into a formal engagement with us;
- request further assistance from us;
- contact us with complaints or legal queries;
- complete an enquiry form;
- report issues or generally provide feedback;
- submit the Compliance Data that we request;
- request marketing to be sent to you;
- express interest and/or attend any of our seminars or other hosted events;
- participate in a survey or our webinars;
- subscribe to our newsletters and updates.

Through our provision of the Services to you or your organisation. This may encompass each of the data categories listed in Section 3 (namely, Identity, Contact, Compliance, Financial, Transaction and Assistance Data).
During the course of dealings with you for or on behalf of your organisation or a client.This may encompass most of the data categories listed in Section 3, but will generally vary on a case-by-case basis.
Automated technologies or interactions.When you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources.We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the parties such as analytics providers, advertising networks and search information providers.
- Financial and Transaction Data from our banks.
- Identity, Contact, Compliance and Assistance Data from publicly available sources such as public court documents, the Malta Registry of Companies, the Malta Ship Registry, companies and shipping registers of other jurisdictions, and from electronic data searches, online search tools (which may be subscription or license based), anti-fraud databases and other third party databases, sanctions lists, and general searches carried out via online search engines (e.g. Google).
- Identity, Contact, Compliance and Assistance Data from instructing law firms or other clients.
- Financial Data from credit reference agencies.

If you attend an event or meeting at our offices, we may hold images of you captured by our CCTV cameras.

5. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where you wish to formally engage us;
Where we are providing you with your requested Services;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with our obligations to third parties (this includes our professional duties to the Courts of Malta and our obligations to regulators)

We do not generally rely on consent as a legal basis for processing your personal data, other than in relation to third party direct marketing communications. You have the right to withdraw consent to such marketing at any time by contacting us, as indicated below.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data pursuant to more than one lawful ground or basis, depending on the specific purpose for which we are using your data.

Please contact us at dp@ganado.com if you need details or wish to enquire about the specific lawful basis we are relying on to process your personal data where more than one lawful basis has been set out in the table below.

Purpose/Activity

Type of Data

Lawful Basis for Processing

Onboarding Requirements

(a) ‘New client onboarding’

– to onboard new client engagements and comply with our internal policies and procedures; and

– to assess and take an informed decision on whether we will enter into a client relationship with you.

(b) To enter into a formal client engagement with you and commence the service provision.

(a) Identity;

(b) Contact;

(d) Assistance; and

(e) Financial.

(a) Performance of a contract with you.

(b) Necessary to comply with a legal obligation.

(c) Necessary for our legitimate interests (to determine whether we can or want to enter into a professional relationship with you, to determine whether we can assist you on the matter for which you have approached us, to carry out internal conflict clearance searches and to verify your ability to meet financial commitments that may result from your requested scope of assistance).

AML and “KYC” Processes

(a) To fulfil our regulatory and legal obligations relating to the prevention of money laundering, fraud prevention, counter-terrorist financing, politically-exposed-persons checks, sanctions checks and any other “know your client” checks.

This includes verifying your identity; and screening against lists maintained by a third party which assists with this process (such as sanctions lists).

(b) To fulfil our other due diligence and KYC internal compliance policies and requirements.

(c) To fulfil any external mandatory reporting obligations that we may, from time to time, have to the local and overseas public and regulatory authorities and/or law enforcement agencies (including the MFSA or the FIAU) or tax authorities.

(a) Identity;

(b) Contact;

(d) Assistance*

*provided that we are exempted from professional secrecy obligations in case of disclosure and reporting.

(a) Necessary to comply with a legal obligation.

(b) Necessary for our legitimate interests (to establish and verify the identity of our clients, even where the requested assistance does not amount to a ‘relevant activity’, for internal risk assessment and internal management).

Service Provision

(a) To provide you or your organisation with the requested Services.

(b) To improve the provision of those Services to you or your organisation.

(a) Identity;

(b) Contact;

(a) Performance of a contract with you.

(b) Necessary to comply with professional obligations and ethical duties.

(a) For billing and invoice purposes.

(b) To collect and recover money which is owed to us (debt recovery).

(a) Identity;

(b) Contact;

(d) Financial; and

(e) Transaction.

(a) Performance of a contract with you.

(b) Necessary to comply with a legal obligation (accounting and other record-keeping requirements).

(c) Necessary for our legitimate interests (to recover debts due to us, to keep track of the Services provided to the client and their status or outcome, to be able to revisit such matters if new issues arise).

Relationship Management

To manage our professional relationship with you (as a client or where the client is your organisation), which may include to:

(a) notify you about changes to our terms of business or privacy notices;

(b) deal with your enquiries, requests, complaints or reported issues;

(d) ask you to participate in a survey;

(e) request feedback from you;

(f) advise you of industry and legislative updates;

(g) inform you about our events and seminars (including webinars);

(h) provide you with information about our Services; and

(i) provide you with any other information or materials that you have requested to receive from us.

(a) Identity;

(b) Contact;

(d) Usage;

(e) Profile; and

(f) Marketing and Communications.

(a) Performance of a contract with you.

(b) Necessary for our legitimate interests (for client relationship handling and management, to study business growth and possible trends regarding our service areas, to enable a review and assessment of our service provision, to develop and grow our business).

Business and Financial Management

(a) To run our business in an efficient and proper manner.

(b) To enable third parties to provide us with services necessary for the client.

(d) To investigate and respond to client complaints.

(a) Identity;

(b) Contact;

(d) Usage;

(e) Profile; and

(f) Marketing and Communications.

(a) Necessary for our legitimate interests (for administering, managing and operating the affairs of our business properly, including managing our financial position, business capability, planning, communications, corporate governance, audit, insurance, sales, to prevent fraud and to maintain the confidentiality of communications, and in the context of a business reorganisation or group restructuring exercise).

(b) Necessary to comply with a legal obligation.

(a) To detect, investigate and prevent and/or report:

– breaches of internal and regulatory policies; and/or

– fraudulent activity and/or any other criminal activity.

(b) To assist and cooperate in any criminal or regulatory investigations against you, as may be required of us.

(a) Identity;

(b) Contact;

(d) Assistance;

(e) Financial; and

(f) Transaction.

(a) Necessary to comply with a legal obligation.

(b) Necessary for our legitimate interests (regulator relations, business reputation).

(a) To administer and protect our firm, business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

(b) To manage the performance and security of our equipment, IT systems and electronic platforms, including administering access rights.

(a) Identity;

(b) Contact;

(d) Usage.

(a) Necessary for our legitimate interests (for running and administering our firm and business (including IT support), systems administration, network security, to prevent fraud and to maintain the confidentiality of communications, and in the context of a business reorganisation or group restructuring exercise).

(b) Necessary to comply with a legal obligation.

Marketing and Business Growth

(a) To carry out market research campaigns.

(b) To market our Services to you by email or other means if you have subscribed to one of our mailing lists (where you are not a client).

(c) To deliver relevant Website content and advertisements to you, and measure or understand the effectiveness of the advertising we serve to you.

(a) Identity;

(b) Contact;

(d) Usage;

(e) Profile; and

(f) Marketing and Communications.

(a) Necessary for our legitimate interests (to develop our lines of Services and grow our business, to define our clients and their industries or sectors, to keep our Services and the Website updated and relevant, and to inform our marketing strategy).

(b) On the basis of your consent, in the absence of a client relationship.

To permit Ganado to pursue available remedies or limit any damages that Ganado may sustain.

(a) Identity;

(b) Contact;

(d) Financial;

(e) Transaction; and

(f) Marketing and Communications.

(a) Performance of a contract with you.

(b) Necessary for our legitimate interests.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around advertising and marketing. Through your Identity, Contact, Technical, Usage and Profile Data, we are able to form a view on what we think you or your organisation may want or need in terms of legal and advisory services. This is how we decide which of our Services may be of most relevance or interest for you and/or your organisation.

You may receive marketing communications from us (which may consist of newsletters, industry and legislative updates, mailshots, publications and/or information about our events, seminars and webinars) where:

you have entered into a client or business partner relationship with Ganado, regardless of whether a formal engagement letter has been signed; and
provided you have not opted out of receiving marketing from us (see Your right to objectbelow).

Where the above does not apply to you, we will only send you our marketing communications where you have expressly consented to receive them from us.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third parties (including our associated corporate entities) for marketing purposes.

Opting out

You can ask us to stop sending you marketing communications (unsubscribe) at any time by following the opt-out (unsubscribe) links on any marketing communication sent to you.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly. This Notice should be read in conjunction with our IP address and cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, or we are obliged to process your data by applicable laws or court / enforceable orders.

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at dp@ganado.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without the need to obtain your consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

We may transfer your personal data to our affiliated entities GSL and GML (based in Malta) for the following purposes:

to facilitate and administer your business relationship with us;
as part of our regular reporting activities on company performances;
to consolidate our reporting and accounting procedures;
to ensure business efficiency (all above being part of our legitimate interests), and/or
where necessary to achieve or further any of the purposes in Section ‎5

In addition, we may also have to grant access to, disclose or share your personal data with the parties set out below, including your submitted applications, questionnaires and declaration forms, for the purposes in Section ‎5 above:

Other law firms or professional advisors involved in the provision of the Services to you (including instructing law firms, law firms with whom we are collaborating or law firms that we have engaged for you at your request or on your behalf);
Suppliers and external agencies that we engage to process information on our or your behalf, including to provide you with the Services you may have requested;
To any relevant party in connection with our anti-money laundering, anti-fraud or ‘KYC’ requirements or policies (including third party service providers which carry out sanctions checks on our behalf);
Third-party payment processors, such as payment services providers and banks;
Our professional advisers (including our auditors, accountants, financial advisers, and legal counsel);
To regulators, government bodies and tax authorities (local and overseas) when required by applicable laws and/or regulations);
To any relevant party, claimant, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims in accordance with applicable law and regulation;
To any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences in accordance with applicable law; and
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets (successors in title). Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

Furthermore, we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our documented instructions.

We may also disclose your data if we are under a duty to disclose or share your personal data to comply with any legal obligation, judgment or under an order from a court, tribunal or authority. This includes exchanging information with regulatory bodies in Malta or if applicable, overseas, public bodies including the Police and other organisations and may undertake credit or fraud searches with relevant agencies for the purposes of fraud detection and prevention.

We may also transfer your personal data to applicable governmental and regulatory authorities, agencies and other public bodies in order to comply with our legal obligations. We may also transfer your personal data when we are required to do so by any judicial body, court order or order issued by a police authority.

We may also disclose your data to enforce our contractual terms with you or your entity, or to protect our rights, property or safety, that of our partners or other applicants or investors. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

7. International transfers

We do not generally transfer personal data to entities outside the EEA except as may be necessary to: (i) provide the Services, (ii) fulfil or exercise our contractual obligations, (iii) comply with our legal or regulatory obligations or (iv) assert, file or exercise a legal claim.

Where we do need to transfer your personal data to outside the EEA (whether for these stated purposes or any other purpose listed in Section ‎5 above), we will ensure a similar degree of protection is afforded to that personal data by ensuring at least one of the following safeguards exists or is otherwise implemented:

the country to which the personal data is transferred ensures an adequate level of protection for the data subject’s rights and freedoms recognised under EU data protection law;
in the absence of an adequacy decision, the data transfer is regulated by specific contracts approved by the European Commission which give personal data the same standards of protection which it has in Europe (referred to as standard contractual Sections or model Sections); or
failing the above, the transfer is necessary:

for the performance of a contract concluded in your interests between us and another person;
for important reasons of public interest;
in order to comply with a legal or regulatory obligation to which we are subject; or
for the filing, exercise or defence of legal claims.

If we have to transfer your data to outside the EEA and cannot rely on any of the mechanisms set out above, we shall request your explicit consent to do so.

Please contact us at dp@ganado.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Note however that when you instruct us to transfer or share your personal data, including with other law firms (based in or outside the EEA), we will perform any processing activity required to fulfil such instructions as your mandatories and not as an autonomous controller. As your mandatories, we will not be required to enter into a contractual mechanism, joint controller agreement or otherwise, with the recipient to whom you have instructed us to share or transfer your personal data.

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed (safeguard its integrity and confidentiality).

We also regularly review and, where practicable, improve upon these security measures.

In addition, we limit access to your personal data to those employees, agents, contractors and other professional third parties who strictly need to know this information. They will only process your personal data on our instructions and are subject to a duty of confidentiality. All our employees and agents have received appropriate training on data protection.

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

9. Data retention

Please note that Ganado considers its professional relationship with clients to be an ongoing and continuous engagement, until such time that it is terminated in accordance with our Letter of Engagement.

How long will you use my personal data for?

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm to it from unauthorised use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

With respect clients, we will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, i.e. the provision of the Services and the ongoing performance of our professional relationship with you, and

thereafter:

for the purpose of satisfying any legal, accounting, tax, record-keeping or reporting obligations to which we may be subject; and/or
to the extent that we may also need to retain your personal data to be able to assert, exercise or defend possible future legal claims against or otherwise involving you.

Generally, our retention of your personal data shall not exceed a maximum period of eleven (11) years from the termination of your engagement with Ganado. We have taken into account prescriptive periods and our statutory obligations to comply with accounting, taxation, regulatory and anti-money laundering laws, which include mandatory record-keeping requirements for set periods. Some of your data may be deleted earlier, which (in the case of records) could be dictated by the specific record period set at law.

Note that exceptionally we may need to retain your personal data, or some of it, for longer than our general maximum period, mainly for situations relating to threatened or commenced claims, disputes or litigation, ongoing or pending investigations, requests made by competent authorities or to abide by court orders.

In some circumstances you can ask us to delete your data. See Request erasure below for further information.

In other circumstances, we may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Kindly contact us at dp@ganado.com for further details about the retention periods that we apply.

Data minimisation

To the extent possible, we may anonymise the data which we hold about you when it is no longer necessary to identify you from the data which we hold about you. In some circumstances, we may even pseudonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction (rectification) of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of those rights, please contact us at dp@ganado.com.

No fee is usually charged

You will not have to pay a fee to exercise any of your data subject rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may simply refuse to comply with your request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within a period of one month from the date of receiving your request. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You have the right to:

(i) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

You may send an email to dp@ganado.com requesting information as the personal data which we process. You shall receive one copy free of charge via email of the personal data which is undergoing processing. Any further copies of the information processed shall incur a charge of €10.00.

(ii) Right to information when collecting and processing personal data about you from publicly accessible or third-party sources. When this takes places, we will inform you, within a reasonable and practicable time frame, about the third party or publicly accessible source from which we have collected your personal data.

(iii) Request correction or rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected and/or updated, though we may need to verify the accuracy of the new data you provide to us. As mentioned, it is in your interest to keep us informed of any changes or updates to your personal data which may occur during the course of your relationship with us, since this may otherwise impair our ability to provide you with your requested Services or the quality thereof.

(iv) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where:

there is no good reason for us continuing to process it;
you have successfully exercised your right to object to processing (see below);
we may have processed your information unlawfully; or
we are required to erase your personal data to comply with local law.

Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. These may include instances where the retention of your personal data is necessary to:

comply with a legal or regulatory obligation to which we are subject; or
establish, exercise or defend a legal claim.

(v) Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes (as under the Marketingin Section ‎5 above).

In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal information that override your rights and freedoms.

(vi) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

if you want us to establish the data’s accuracy;
where our use of the data is unlawful but you do not want us to erase it;
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it.
(vii) Request the transfer (data portability) of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

(viii) Withdraw your consent at any time where we are relying on consent to process your personal data (which will generally not be the case). This will not affect the lawfulness of any processing carried out before you withdrew your consent. Any processing activities that are not based on your consent will remain unaffected.

Kindly note that none of these data subject rights are absolute and must generally be weighed against our own legal obligations and legitimate interests. If a decision is taken to override your data subject request, you will be informed of this by our data protection team along with the reasons for our decision.

11. Complaints

https://idpc.org.mt/en/Pages/Home.aspx)

We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

12. Conclusion

This Notice may be updated from time to time.

Please note that if our business, or any part of it, is sold or transferred at any time, the information we hold may form part of the assets transferred, although it will still only be used in accordance with this Notice.

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Notice at any time. Please read this Notice carefully and re-visit this page from time to time to review for changes.

If you have any questions regarding this Notice, or if you would like to send us your comments, please contact us using the Contact Details indicated in this Notice.

GLOSSARY

Set out below are key definitions of certain terms which appear in this Notice:

“data subjects” means living, natural persons about whom we process personal data;
“data controller” or “controller” means any entity or individual who determines the purposes for which, and the manner in which, any personal data is processed;
“data processor” or “processor” means any entity or individual that processes data on our behalf and on our instructions (we being the data controller);
“GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
“legitimate interest” means our interest to conduct and manage our business appropriately and responsibly, to protect the reputation of our business, and to provide the best possible services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests;
“personal data” means data relating to a living individual (i.e., natural person) who can be identified from the data we possess about him or her. This includes, but is not limited to, your name and surname, address, date of birth, contact details. The term “personal information”, where and when used in this Notice, shall have the same meaning as personal data;
“processing” means any activity or set of operations that involves use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including, organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties; and
“special categories of personal data” includes information about a person’s racial or ethnic origin, political opinions, religious, philosophocal or similar beliefs, trade union membership, physical or mental health or condition or sexual life or his or her biometric data.

Ganado SARL (Luxembourg) privacy notice

Introduction

Welcome to Ganado SARL’s privacy notice (the “Notice”).

Ganado SARL, a private limited liability company (société à responsabilité limitée) with registered office at 47, Boulevard Prince Henri, L-1724 Luxembourg organised as an independent law firm and registered with the Luxembourg Bar (“Ganado”; “we”; “us”; “our”) respects your privacy and values its importance, and is wholly committed to protecting your personal data. The purpose of this Notice is to set out the basis on which we will process your personal data when:

you approach and engage us to provide you with our legal and advisory services (the “Services”);
receive the various Services that you may request from us during the course of this engagement; and/or
you visit and use our website <https://ganado.com> (the “Website” or the “Site”), regardless of where you visit and use it from.

This includes any data that you may provide for and in relation to our newsletters, legislative updates, events and other marketing and promotional communications.

This Notice informs you about the items of personal data that we may collect about you and how we will handle it, and in turn, also tells you about (i) our obligations to process your personal data responsibly, (ii) your data protection rights as a data subject and (iii) how the law protects you.

We process your data in an appropriate and lawful manner, in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) and any data protection laws, regulations and circulars in the context of GDPR (the “Data Protection Laws”).

Please refer to the Glossary to understand the meaning of some of the terms used in this Notice.

1. Important information and who we are

This Notice aims to ensure that you are fully informed on how Ganado will collect and process your personal data in the scenarios indicated above in the ‘Introduction’.

The Website is not intended for minors, and we do not knowingly collect data relating to minors except and unless where it is necessary in order to provide you with the Services that you may request from us (most commonly, where the requested Services concern your family, including your children). We will treat any information relating to minors which is disclosed to us in connection with the Services in a sensitive manner and with the utmost confidentiality.

It is important that you read this Notice together with any other privacy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Notice supplements the other notices and is not intended to override them.

Controller

Ganado (as defined above) is associated with various corporate entities, most particularly its service company Ganado Services Limited (C 10785), a private limited liability company, having its registered office at 171, Old Bakery Street, Valletta, VLT 1455, Malta (“GSL”) or Ganado Advocates.

We (Ganado SARL) are the controller and responsible for this Notice.

We are also the data controller of any personal data which we collect or receive and which we process in connection with (i) the Services and/or (ii) the Website. Our associated corporate entities may be data controllers of your personal data in their own right, whether jointly with Ganado or as entirely separate data controllers or act upon our authorised instructions as data processors.

We have a dedicated data protection team which serves as our data protection contact point and is responsible for overseeing queries in relation to this Notice and for handling any data subject requests. If you have any question about this Notice, including any requests to exercise your legal rights, please contact our data protection team using the contact details set out below. Please use the words ‘Data Protection Matter’ in the subject line.

Our full details are as follows.

Contact details

Full name of legal entity: Ganado SARL.

Email address: nhernandez@ganado.com

Postal address: 47, Boulevard Prince Henri, L-1724 Luxembourg

You have the right to lodge a complaint at any time to a competent supervisory authority on data protection matters, such as in particular the supervisory authority in the place of your habitual residence or your place of work. In the case of Luxembourg, this is the Commission Nationale pour la Protection des Données (“CNPD”). We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on May, 2020.

Third-party links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notice or policies. We strongly encourage you to read the privacy notice of every website you visit, particularly when leaving our Website.

2. Some key definitions

Set out below are key definitions of certain data protection terms which appear in this Notice.

“Consent Form” refers to separate documents which we might from time to time provide you where we ask for your explicit consent for any processing which is not for purposes set out in this Notice.

“Data subjects” means living individuals (i.e. natural persons) about whom we collect and process personal data.

“Data controller” or “controller” means any entity or individual who determines the purposes for which, and the manner in which, any personal data is processed.

“Data processor” or “processor” means any entity or individual that processes data on our behalf and on our instructions (we being the data controller).

“Personal data” means data relating to a living individual (i.e. natural person) who can be identified from the data (information) we hold or possess. This includes, but is not limited to, your name and surname (including maiden name where applicable), address, date of birth, nationality, gender, civil status, tax status, identity card number & passport number, contact details (including mobile and home phone number and personal email address), photographic image, bank account details, emergency contact information as well as online identifiers. The term “personal information”, where and when used in this Notice, shall be taken have the same meaning as personal data.

“Processing” means any activity that involves use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including, organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.

“Sensitive personal data”, “sensitive data” or “special categories of personal data” includes information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. This type of sensitive data can only be processed under strict conditions.

Note that personal data does not include information relating to a legal person (for example, a company or other legal entity). In that regard, information such as a company name, its company number, registered address and VAT number does not amount to personal data in terms of the Data Protection Laws. Therefore, the collection and use of information strictly pertaining to a legal person does not give rise to data controller obligations at law. We will still naturally treat any and all such information in a confidential manner, in accordance with our standard practices and professional secrecy obligations.

3. The data we collect about you

In the course of its engagement and professional relationship with you, Ganado will need to collect, use, and sometimes, disclose various items of personal data about you for various purposes associated with the scope of the Services that we provide, as requested and directed by you or by your organisation. Given the broad spectrum of our potential Services to you or to your organisation, it is both impractical and almost impossible to exhaustively list all the items of personal data which we may need to collect, use or disclose about you.

Identity Data includes first name, maiden name, last name, title, identity document number, gender, nationality, employment status, organisation, occupation and (in the context of the Site) username or similar identifier.

Contact Data includes billing address, mailing address, email address and contact numbers.

In the context of our corporate clients and the other legal entities that we assist, we may collect Identity and Contact Data about the following persons:

- directors;
- legal and judicial representatives;
- company secretary and other officers (for example, MLROs, DPOs and risk officers);
- internal (‘in-house’) legal counsel;
- auditors;
- shareholders and ultimate beneficial owners (UBOs);
- founders and board of administrators in the case of Foundation;
- settlors, beneficiaries, protectors and trustees in the case of a Trust.

Compliance Data (AML and KYC) includes the following due diligence information and documentation relating to our clients, or their respective UBO, shareholders, founders, beneficiaries, directors, representatives and/or administrators (as applicable) where the client is a legal person: (i) copy of identity document, (ii) copy of a recently issued utility bill, (iii) professional references, (iv) ‘KYC’ (database) checks and (iv) any other documentation which may be mandated from time to time the Luxembourg law of 12 November 2004 on the fight against money laundering and terrorist financing (“AML CTF Law”), the CSSF Regulation N° 12-02 of 14 December 2012 on the fight against money laundering and terrorist financing and any other laws, circulars or regulation in the context of the fight against money laundering and terrorist financing implemented in Luxembourg from time to time.

Assistance Data includes the following information about our clients:

(i) the client’s legal requirements, situation, plans, interests and targets or objectives;

(ii) the Services requested by, and provided to, the client;

(iii) counter and adverse parties, related parties, parties in interest, business partners, witnesses, investors, assets, shareholders, security holders, guarantors, buyers, sellers and customers of the client, and Court decisions or orders issued in favour or against the client (as strictly relevant and necessary to provide the Services).

Financial Data includes the client’s bank account details, together with details about any payment methods used by the client to settle our invoices (which we under particular circumstances use to establish creditworthiness and financial status);

Transaction Data includes details about (i) invoices issued to the client (including date of settlement and means of settlement), (ii) payments made to and from the client and (iii) any outstanding invoices due by the client;

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices which you (whether a client or otherwise) use to access and browse the Site;

Profile Data includes information about legal areas that may be of interest to you (based on the Services provided), your feedback and survey responses;

Usage Data includes information about how you use our Site; and

Marketing and Communications Data includes your preferences in receiving marketing from us, our associated entities or third parties, and your communication preferences. This may include information on whether you have subscribed or unsubscribed from our mailing lists, attended our events or accepted our invitations

If you fail to provide personal data

Where we need to collect personal data by law, or pursuant to our terms of business and engagement, and you fail to provide that data when requested, we might not be able to assist you or provide you with your requested Services. In certain cases, particularly where it relates to Compliance Data, we may even need to exercise our prerogative to terminate the Services and your engagement with us or otherwise decline to enter into client relationship with you (as applicable). We will notify you if this is the case at the time.

Special categories of personal data

Below are the circumstances and purposes for which this may take place:

Initial and on-going customer due diligence checks: determination of whether or not the customer and certain persons related to the customer are “politically exposed persons” in terms of applicable AML legislation; and
Initial and on-going customer due diligence checks: due diligence checks via RiskScreen, WorldCheck, Google Searches, databases of regulatory or supervisory authorities, and other publicly accessible sources.

There may be other occasions where we may need to process your sensitive personal data, namely where:

the processing is necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law or regulation; or
the processing is necessary for the establishment, exercise or defence of legal rights.

In other cases, for example where required as part of the Service provision, we will rely on your authorisation to process the special category of personal data.

The lawyers and other advisors that form part of Ganado are bound by strict professional secrecy obligations.

4. How is your personal data collected?

We generally use different methods to collect data from and about you including through:

Direct Interactions. You may give us your Identity, Contact, Compliance, Financial, Assistance and Marketing and Communications Data by completing our letter of engagement, filling in our forms (such as our ‘Contact Form’ accessible at: https://www.ganado.com/contact), or by corresponding with us by post, phone, email or otherwise or during face-to-face meetings. This includes personal data you provide when you:
- approach us to assist you on a particular matter;
- discuss with us the assistance that you require (whether via meetings, telcos or email correspondence);
- enter into a formal engagement with us;
- request further assistance from us;
- contact us with complaints or legal queries;
- complete an enquiry form;
- report issues;
- submit the Compliance Data that we request;
- request marketing to be sent to you;
- express interest and/or attend any of our seminars or other hosted events;
- participate in a survey or our webinars;
- subscribe to our newsletters and updates;
- give us some feedback.
- Through our provision of the Services to you or to your organisation. This may encompass all of the data categories listed in Clause 3 (namely, Identity, Contact, Compliance, Financial, Transaction and Assistance Data).
- During the course of dealings with you for or on behalf of your organisation or a client. This may encompass most of the data categories listed in Clause 3, but will generally vary on a case-by-case basis.
- Automated technologies or interactions. When you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  - Technical Data from the following parties:

(a) analytics providers;

(b) advertising networks; and

- Financial and Transaction Data from our banks.
- Identity, Contact, Compliance and Assistance Data from publicly available sources such as public court documents, the Luxembourg Register of Commerce and Companies, Luxembourg Register of Beneficial Owners, companies and registers of other jurisdictions, and from electronic data searches, online search tools (which may be subscription or license based), anti-fraud databases and other third party databases, sanctions lists and general searches carried out via online search engines (e.g. Google).
- Identity, Contact, Compliance and Assistance Data from instructing law firms or other clients.
- Financial Data from credit reference agencies.

If you attend an event or meeting at our offices, we may hold images of you captured by our CCTV cameras.

5. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where you wish to formally engage us;
Where we are providing you with your requested Services;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with our legal and professional obligations to third parties (this includes our professional duties and our own legal obligations)

We do not generally rely on consent as a legal basis for processing your personal data, other than in relation to sending third party direct marketing communications. You have the right to withdraw consent to such marketing at any time by contacting us, as indicated below.

Purposes for which we will use your personal data

Note that we may process your personal data pursuant to more than one lawful ground or basis, depending on the specific purpose for which we are using your data. Please contact us at nhernandez@ganado.com if you need details or wish to enquire about the specific lawful basis we are relying on to process your personal data where more than one lawful basis has been set out in the table above.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
(a) To determine whether Ganado will enter into a professional relationship with you;(b) To determine whether Ganado can assist you and provide you with the requested Services; and(c) To enter into a formal engagement with you.	(a) Identity;(b) Contact;(c) Compliance;(d) Assistance; and(e) Financial.	(a) Performance of a contract with you or in order to take steps at your request prior to entering into such a contract.(b) Necessary for our legitimate interests (to determine whether we can or want to enter into a professional relationship with you, to determine whether we can assist you on the matter for which you have approached us, to carry out internal conflict clearance searches and to verify your ability to meet financial commitments that may result from your requested scope of assistance).
(a) To establish and verify your identity; (b) To fulfil our other internal compliance policies and requirements; (c) To comply with our obligations under the AML CTF Law, and others laws or regulations that may be applicable to us in terms of client due diligence and AML requirements; and (d) To fulfil external mandatory reporting obligations that we may have to the FIAU, the CSSF, the Police and any other (including overseas) public, regulatory, law enforcement or tax authorities.	(a) Identity;(b) Contact;(c) Compliance; and (d) Assistance* *provided that we are exempted from professional secrecy obligations in case of disclosure and reporting.	(a) Necessary to comply with a legal obligation. (b) Necessary for our legitimate interests (to establish and verify the identity of our clients, even where the requested assistance does not amount to a ‘relevant activity’, for internal risk assessment and internal management).
(a) To provide you or your organisation with the requested Services; (b) To improve the provision of those Services to you or your organisation.	(a) Identity;(b) Contact;(c) Compliance.	(a) Performance of a contract with you.(b) Necessary to comply with professional obligations and ethical duties.
(a) For billing and invoice purposes; (b) To collect and recover money which is owed to us (debt recovery). (c) Internal record keeping (including files).	(a) Identity;(b) Contact;(c) Assistance;(d) Financial; and(e) Transaction.	(a) Performance of a contract with you. (b) Necessary to comply with a legal obligation (accounting and other record-keeping requirements). (c) Necessary for our legitimate interests (to recover debts due to us, to keep track of the Services provided to the client and their status or outcome, to be able to revisit such matters if new issues arise).
To manage our professional relationship with you (as a client or where the client is your organisation), which may include to: (a) notify you about changes to our terms of business or privacy notices; (b) deal with your enquiries, requests, complaints or reported issues; (c) contact you in the course of providing the requested Services; (d) ask you to participate in a survey; (e) request feedback from you; (f) advise you of industry and legislative updates, (g) inform you about our events and seminars (including webinars); (h) provide you with information about our Services, and (h) provide you with any other information or materials that you have requested to receive from us.	(a) Identity;(b) Contact;(c) Assistance;(d) Usage;(e) Profile; and (f) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (for client relationship handling and management, to study business growth and possible trends regarding our service areas, to enable a review and assessment of our service provision, to develop and grow our business).
(a) To detect, prevent and/or report fraud or any other criminal activity that comes to our knowledge and attention.(b) To assist and cooperate in any criminal or regulatory investigations against you, as may be required of us.	(a) Identity;(b) Contact;(c) Compliance;(d) Assistance;(e) Financial; and(f) Transaction.	Necessary to comply with a legal obligation.
To administer and protect our firm, business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Identity;(b) Contact;(c) Technical; and(d) Usage.	(a) Necessary for our legitimate interests (for running and administering our firm and business (including IT support), systems administration, network security, to prevent fraud and to maintain the confidentiality of communications, and in the context of a business reorganisation or group restructuring exercise). (b) Necessary to comply with a legal obligation.
(a) To carry out market research campaigns; (b) To market our Services to you by email or other means if you have subscribe to one of our mailing lists (where you are not a client); (c) To deliver relevant Website content and advertisements to you, and measure or understand the effectiveness of the advertising we serve to you.	(a) Identity;(b) Contact;(c) Technical ;(d) Usage;(e) Profile; and (f) Marketing and Communications.	(a) Necessary for our legitimate interests (to develop our lines of Services and grow our business, to define our clients and their industries or sectors, to keep our Services and the Website updated and relevant, and to inform our marketing strategy.). (b) On the basis of your consent, in the absence of a client relationship.
To permit Ganado to pursue available remedies or limit any damages that Ganado may sustain.	(a) Identity;(b) Contact;(c) Assistance;(d) Financial;(e) Transaction; and (f) Marketing and Communications.	(a) Performance of a contract with you.(b) Necessary for our legitimate interests.

“Legitimate Interest” means our interest to conduct and manage our business affairs appropriately and responsibly, to protect the reputation of our business and firm, and to provide our clients with the best possible service and the users of the Site with a secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at the following email address: nhernandez@ganado.

“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. This includes our Letter of Engagement or other terms of business.

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Marketing

You may receive marketing communications from us (which may consist of newsletters, industry and legislative updates, mailshots, publications and/or information about our events, seminars and webinars) where:

you have entered into a client or business partner relationship with Ganado, regardless of whether a formal engagement letter has been signed or otherwise; and
provided you have not opted out of receiving marketing from us (see Your right to object below).

Where the above does not apply to you, we will only send you our marketing communications where you have expressly consented to receive them from us.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third parties (including our associated corporate entities) for marketing purposes.

Opting out

You can ask us to stop sending you marketing communications (unsubscribe) at any time by following the opt-out (unsubscribe) links on any marketing communication sent to you

Cookies

Change of purpose

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at nhernandez@ganado.com.

6. Disclosures of your personal data

We may have to grant access to, disclose or share your personal data with the parties set out below for the purposes set out in the table in Clause ‎5 above:

Our associated corporate entities including Ganado Advocates and Ganado Services Limited (C 10785), 171, Old Bakery Street, Valletta, VLT 1455, Malta;
Other law firms involved in the provision of the Services to you (including instructing law firms, law firms with whom we are collaborating or law firms that we have engaged for you at your request or on your behalf).
Suppliers and external agencies that we engage to process information on our and/or your behalf, including to provide you with the information and/or materials that you have requested.
Service providers, including those that provide IT support and system administration services for Ganado.
Professional advisers such as consultants, bankers, professional indemnity insurers, brokers and auditors.
The tax authorities, regulators and other authorities, including the Courts of Luxembourg, the Financial Intelligence Analysis Unit, the Police and the CSSF.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets (successors in title). Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our documented instructions.

7. International transfers

We do not generally transfer your personal data to entities outside the European Economic Area (“EEA”) except as may be necessary to: (i) provide you with the requested Services, (ii) fulfil our contractual obligations to you or exercise our contractual obligations against you, (iii) comply with our legal or regulatory obligations or (iv) assert, file or exercise a legal claim. Where we do need to transfer your personal data to outside the EEA (whether for these stated purposes or any other purpose listed in Clause ‎5 above), we will ensure a similar degree of protection is afforded to that personal data by ensuring at least one of the following safeguards applies or is otherwise implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
In the absence of an adequacy decision, we will use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us at nhernandez@ganado.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. Data security

We also regularly review and, where practicable, improve upon these security measures.

In addition, we limit access to your personal data to those employees, agents, contractors and other professional third parties who strictly need to know this information. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. All our employees and agents have received appropriate training on data protection.

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

9. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it (the provision of the Services and the ongoing performance of our professional relationship with you) and, thereafter, for the purpose of satisfying any legal, accounting, tax, anti-money laundering and regulatory reporting requirements or obligations to which we may be subject and/or to the extent that we may also need to retain your personal data to be able to assert, exercise or defend possible future legal claims against or otherwise involving you.

By and large, our retention of your personal data shall not exceed the period of five (5) years from the termination of your engagement with Ganado. This retention period enables us to make use of your personal data for potential AML reporting obligations to the FIAU (a legal obligation) and/or for the assertion, filing or defence of possible legal claims by or against you (taking into account applicable statutes of limitation and prescriptive periods). In certain cases, we may need to retain your personal data for a longer period to comply with applicable accounting and tax laws. There may also be instances where the need to retain personal data for longer periods is dictated by the nature of the services provided.

In some circumstances you can ask us to delete your data. See request erasure below for further information.

Kindly contact us at nhernandez@ganado.com for further details about the retention periods that we apply.

Data minimisation

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction (rectification) of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of those rights, please contact us at dp@ganado.com.

No fee is usually charged

What we may need from you

Time limit to respond

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Right to informationwhen collecting and processing personal data about you from publicly accessible or third-party sources. When this takes places, we will inform you, within a reasonable and practicable time frame, about the third party or publicly accessible source from which we have collected your personal data.

Request correction or rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected and/or updated, though we may need to verify the accuracy of the new data you provide to us. As mentioned, it is in your interest to keep us informed of any changes or updates to your personal data which may occur during the course of your relationship with us, since this may otherwise impair our ability to provide you with your requested Services or the quality thereof.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where:

there is no good reason for us continuing to process it;
you have successfully exercised your right to object to processing (see below);
we may have processed your information unlawfully; or
we are required to erase your personal data to comply with local law.

comply with a legal or regulatory obligation to which we are subject; or
establish, exercise or defend a legal claim.
- Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes (as under the Marketingin Section ‎5 above).

In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal information that override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

if you want us to establish the data’s accuracy;
where our use of the data is unlawful but you do not want us to erase it;
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer (data portability) of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw your consent at any time where we are relying on consent to process your personal data (which will generally not be the case). This will not affect the lawfulness of any processing carried out before you withdrew your consent. Any processing activities that are not based on your consent will remain unaffected.

11. Complaints

https://idpc.org.mt/en/Pages/Home.aspx)

We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

12. Conclusion

This Notice may be updated from time to time.

If you have any questions regarding this Notice, or if you would like to send us your comments, please contact us using the Contact Details indicated in this Notice.

GLOSSARY

Set out below are key definitions of certain terms which appear in this Notice:

“data subjects” means living, natural persons about whom we process personal data;
“data controller” or “controller” means any entity or individual who determines the purposes for which, and the manner in which, any personal data is processed;
“data processor” or “processor” means any entity or individual that processes data on our behalf and on our instructions (we being the data controller);
“GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
“legitimate interest” means our interest to conduct and manage our business appropriately and responsibly, to protect the reputation of our business, and to provide the best possible services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests;
“personal data” means data relating to a living individual (i.e., natural person) who can be identified from the data we possess about him or her. This includes, but is not limited to, your name and surname, address, date of birth, contact details. The term “personal information”, where and when used in this Notice, shall have the same meaning as personal data;
“processing” means any activity or set of operations that involves use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including, organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties; and
“special categories of personal data” includes information about a person’s racial or ethnic origin, political opinions, religious, philosophocal or similar beliefs, trade union membership, physical or mental health or condition or sexual life or his or her biometric data.

Ganado Services Limited privacy notice

This version was last updated on 23rd April 2025

1. Introduction

Welcome to Ganado Services Limited’s privacy notice (the “Notice”).

Ganado Services Limited (C 10785) of 171, Old Bakery Street, Valletta VLT 1455, Malta (“GSL”; “we”; “us”; “our”) respects your privacy and values its importance, and is wholly committed to protecting your personal data.

GSL is authorised as a corporate service provider (“CSP”) with the Malta Financial Services Authority (“MFSA”), in accordance with the Company Service Providers Act, Chapter 529 of the laws of Malta, and offers a broad spectrum of corporate administrative services to its clients, from registered office services to full company secretarial services, including organisation of Board Meetings and Annual General Meetings in Malta (the “Services”).

This Notice explains how we will process your personal data when you:

approach and engage us to provide you with our Services, including where relating to the company or other legal person (a “corporate client”) which you own, hold, control or otherwise represent in whatever capacity;
receive the various Services that you may request from us during the course of this service relationship; and/or
visit and use our dedicated webpage https://ganado.com/corporate (the “Website” or the “Site”), regardless of where you visit and use it from.

It also covers any data that you may provide for our newsletters, legislative updates, events and other marketing and promotional communications.

Where you are a corporate client (i.e. not a natural person), we will also request and collect personal data about your directors, representatives, officers, authorised signatories, shareholders and ultimate beneficial owners (“UBOs”) (typically for anti-money laundering (“AML”), due diligence and other vetting requirements) (which we refer to in this Notice as an “individual connected to a business”). This Notice also explains how we process personal data about such individuals and should therefore be circulated accordingly.

You must ensure that they are made aware of this Notice and the individual rights and information it sets out prior to us receiving their information (whether obtained directly, obtained from you or from other sources). If you, or anyone else on your behalf, has provided or provides information on an individual connected to your business to us (or any entity associated with US), you or they must first ensure that you or they have that individual’s authorisation to do so and will be required to confirm the same to us.

Kindly note that, by engaging our services, you and/or the entity to which you are connected enter into a contractual relationship with GSL, which will be governed by our Service Agreement. That Service Agreement stipulates that we will process your personal data in accordance with the practices set out in this Notice.

Please refer to the Glossary to understand the meaning of some of the terms in this Notice.

When accessing our website, we may automatically collect certain information, in particular your IP Address. Please refer to our IP and Cookie Policy available here: https://ganado.com/ip-address-and-cookie-policy/ for more information about how our website uses cookies.

2. Important information and who we are

This Notice supplements the other notices and is not intended to override them.

Controller

GSL is associated with various corporate entities and is also a service company for Ganado Advocates of 171, Old Bakery Street, Valletta, Malta, a leading commercial law firm based in Malta (“Ganado Advocates”).

We are a controller of any personal data that we collect and process in connection with the Services or Site. Our associated entities or Ganado Advocates may be controllers of your personal data in their own right, whether jointly with us or as independent controllers.

As a particular example, GSL and Ganado Advocates have an ongoing relationship and together offer a ‘packaged’ service provision to clients, whereby:

Ganado Advocates is responsible for providing legal and advisory services; and
GSL is responsible for providing corporate administrative services;

as may be requested by the client. This may give rise to certain data processing activities by GSL that are separate and autonomous to those conducted by Ganado Advocates.

Ganado Advocates and our associated entities have their own separate data protection notices which will be made available to you if and when they process your personal data.

Ganado Advocates’ privacy notice may be accessed:

https://ganado.com/privacy-statement/#section1.

Our relationship with Ganado Advocates, GML and other associated corporate entities is regulated by a group data sharing agreement. We also have a joint dedicated data protection team, which serves as our data protection contact point and is responsible for overseeing queries in relation to this Notice and for data subject requests. If you have any question about this Notice, including any requests to exercise your legal rights, please contact our data protection team using the contact details set out below.

Our full details are as follows.

Contact details

Full name of legal entity: Ganado Services Limited (C 10785).

Email address: dp@ganado.com

Postal address: 171, Old Bakery Street, Valletta VLT 1455, Malta.

Duty to inform us of changes

It is imperative that the personal data we hold about you is accurate and current at all times. Otherwise, this will impair our ability to provide you with the requested Services (amongst other relevant issues). Please keep us informed if your personal data changes during the course of our engagement and professional relationship with you.

Third-Party Links

Minors

We will treat any information relating to minors which is disclosed to us in connection with the Services in a sensitive manner and with the utmost confidentiality.

3. The data we collect about you

In the course of any client engagement, we, GSL, will need to collect, use and occasionally disclose personal data for various purposes associated with the scope of the Services that we provide, either for yourself (the client) or your organisation (where you are an individual connected to a business). Given the broad spectrum of our potential Services, we cannot realistically provide an exhaustive list of all the items of personal data which we may need to process about our clients and/or the individuals connected to their business.

However, to ensure transparency, we have made an attempt to group and categorise below the different kinds of personal data which we process about our clients or users of our Site. For the above reasons, these data categories are mostly indicative and not exhaustive.

As mentioned above, GSL is a corporate service provider and, as such, primarily services companies and other legal entities (that is, ‘corporate clients’ and not natural persons per se). Nonetheless, please note that GSL has legal and regulatory obligations to collect, process, store and at times even to disclose personal information about the individuals who own, control or are otherwise responsible for or involved in the management and administration of its corporate clients (that is, “individuals connected to a business”). Furthermore, we also require personal information about such individuals in order to enable us to provide and perform the requested Services.

Identity Data includes first name, maiden name, last name, title, identity document number, gender, nationality, employment status, organisation, occupation and (in the context of the Site) username or similar identifier;
Contact Data includes billing, mailing and email address and contact numbers;

In the context of our corporate clients, we may have to collect Identity and Contact Data about the following individuals connected to their business:

- directors;
- legal and judicial representatives;
- company secretary and other officers (for example, money laundering reporting officers, data protection officers and risk officers);
- internal (‘in-house’) legal counsel;
- auditors;
- shareholders and ultimate beneficial owners (UBOs);
- founders and board of administrators in the case of Foundation;
- settlors, beneficiaries, protectors and trustees in the case of a Trust.

Compliance Data (AML and KYC) includes the following due diligence information and documentation relating to our clients and/or the individuals connected to their business : (i) copy of an identity document and utility billl; (ii) professional references; (iv) screening database checks; and (iv) any other documentation that may be mandated by applicable anti-money laundering or sanctions laws, or the Financial Intelligence Analysis Unit, or any other competent authority or related legislation;
Service Data includes the following information about our clients:
- the client’s legal or business requirements, situation, plans, interests and targets or objectives;
- the Services requested by, and provided to, the client;
- involved and related parties, parties in interest, business partners, investors, advisors, assets, shareholders, corporate involvements, security holders, guarantors, buyers, transactions and customers of the client, and court decisions or orders issued in favour or against the client (as relevant and necessary to provide the Services).

This may also involve the collection, processing and retention of contracts, agreements, public deeds, testamentary dispositions, judicial acts and Court decisions pertaining to the client and/or its respective owners, beneficiaries, representatives, officers and/or administrators (as required for the Services).

Financial Data includes the client’s bank account details, together with details about any payment methods used by the client to settle our invoices (which we under particular circumstances use to establish creditworthiness and financial status);
Transaction Data includes details about (i) invoices issued to the client (including date of settlement and means of settlement), (ii) payments made to and from the client and (iii) any outstanding invoices due by the client;
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices which you (whether a client or otherwise) use to access and browse the Site;
Profile Data includes information about legal areas that may be of interest to you (based on the Services provided), your feedback and survey responses;
Usage Data includes information about how you use our Site; and
Marketing and Communications Data includes your preferences in receiving marketing from us, our associated entities or third parties, and your communication preferences. This may include information on whether you have subscribed or unsubscribed from our mailing lists, attended our events or accepted our invitations.

If you fail to provide personal data

Where we need to collect personal data by law, or pursuant to the terms of our professional (service) relationship with you or your organisation, and you fail to provide that data when requested, we might not be able to provide the requested Services.

In certain cases, particularly where it relates to Compliance Data, we may even need to exercise our prerogative to terminate the Services and the existing professional (service) relationship with GSL or otherwise decline at the outset to enter into a professional (service) relationship, as may be applicable. We will notify you if this is the case at the time.

Special categories of personal data

Below are the circumstances and purposes for which this may take place:

Initial and on-going customer due diligence checks: determination of whether or not the customer and certain persons related to the customer are “politically exposed persons” in terms of applicable AML legislation; and
Initial and on-going customer due diligence checks: due diligence checks via RiskScreen, WorldCheck, Google Searches, databases of regulatory or supervisory authorities, and other publicly accessible sources.

There may be other occasions where we may need to process special categories of personal data about you, namely where:

the processing is necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law or regulation; or
the processing is necessary for the establishment, exercise or defence of legal rights.

In other cases, for example where required as part of the Service provision, we will rely on your authorisation to process the special category of personal data.

The officers and employees that form part of GSL are bound by duties of confidentiality. Professional secrecy obligations may also apply with regards to certain individuals in GSL.

4. How is your personal data collected?

We generally use different methods to collect data from and about you including through:

Direct Interactions. You may give us your Identity, Contact, Compliance, Financial, Assistance and Marketing and Communications Data by entering into our Service Agreement, filling in and submitting our client forms (such as our ‘Contact Form’ at: https://www.ganado.com/contact), or by corresponding with us by post, phone, email or otherwise or during face-to-face meetings.

This includes personal data you provide when you:

- approach us in the context of our corporate services;
- discuss with us the particular Services which you or your organisation may require (whether via meetings, telcos or email correspondence);
- you or your organisation enter into a formal service relationship with GSL;
- request further assistance or other services from us;
- request and receive legal assistance from Ganado Advocates;
- contact us with complaints or queries;
- contact us with complaints or queries;
- complete an enquiry form;
- submit the Compliance Data that we request;
- request marketing to be sent to you;
- express interest and/or attend any of our seminars or other hosted events;
- participate in a survey or our webinars;
- subscribe to our newsletters and updates;
- give us some feedback.

Through our provision of the Services to you or your organisation. This may encompass each of the data categories listed in Section 3 (namely, Identity, Contact, Compliance, Financial, Transaction and Service Data).
During the course of dealings with you for or on behalf of your organisation or a client. This may encompass most of the data categories listed in Section 3, but will generally vary on a case-by-case basis.
Automated technologies or interactions. When you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

- Technical Data from the parties such as analytics providers, advertising networks and search information providers.
- Financial and Transaction Data from our banks.
- Identity, Contact, Compliance and Service Data from publicly available sources such as public court documents, the Malta Business Registry, company registers of other jurisdictions, and from electronic data searches, online search tools (which may be subscription or license based), anti-fraud databases and other third-party databases, sanctions lists, and general searches carried out via online search engines (e.g. Google).
- Identity, Contact, Compliance and Service Data from your advisors or instructing entities, including instructing law firms.
- Financial Data from credit reference agencies.

If you attend an event or meeting at our offices, we may hold images of you captured by our CCTV cameras.

5. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where you wish to formally engage us;
Where we are providing you with your requested Services;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
Where we need to comply with our obligations to third parties (this includes our professional duties to the Courts of Malta and our obligations to regulators).

Purposes for which we will use your personal data

Note that we may process your personal data pursuant to more than one lawful ground or basis, depending on the specific purpose for which we are using your data.

Purpose/Activity

Type of Data

Lawful Basis for Processing

Onboarding Requirements

(a) ‘New client onboarding’

– to onboard new client engagements and comply with our internal policies and procedures; and

– to assess and take an informed decision on whether we will enter into a service relationship with you.

(b) To determine whether GSL can provide you with the requested Services and, as applicable, perform them on an ongoing basis.

(a) Identity;

(b) Contact;

(d) Service; and

(e) Financial.

(a) Performance of a contract with you.

(b) Necessary to comply with a legal obligation.

(c) Necessary for our legitimate interests (to determine whether we can or want to enter into a service relationship with you, to determine whether we can provide the Services that you have requested, to carry out internal conflict clearance searches and verify your ability to meet financial commitments that may result from the Service provision).

AML, and “KYC” Processes

This includes: verifying your identity; and screening against lists maintained by a third party which assists with this process (such as sanctions lists).

(b) To fulfil our other due diligence and KYC internal compliance policies and requirements.

(a) Identity;

(b) Contact;

(d) Service*

*provided that we are exempted from professional secrecy obligations in case of disclosure and reporting.

(a) Necessary to comply with a legal obligation.

(b) Necessary for our legitimate interests (to establish and verify the identity of our corporate clients and individuals connected to their business, even where the requested assistance does not amount to a ‘relevant activity’, for internal risk assessment and internal management).

Service Provision

(a) To provide you or your organisation with the requested Services.

(b) To improve the provision of those Services to you or your organisation.

(a) Identity;

(b) Contact;

(a) Performance of a contract with you.

(b) Necessary to comply with professional obligations and ethical duties.

(c) Legitimate business interests (quality control, business reputation, to keep track of the Services provided and their status or outcome, to be able to revisit them should issues arise).

(a) For billing and invoice purposes.

(b) To collect and recover money which is owed to us (debt recovery).

(a) Identity;

(b) Contact;

(d) Financial; and

(e) Transaction.

(a) Performance of a contract with you.

(b) Necessary to comply with a legal obligation (accounting and other record-keeping requirements).

Relationship Management

To manage our professional relationship with you (as a client or where the client is your organisation), which may include the following:

(a) notify you about changes to our terms of business or privacy notices;

(b) deal with your enquiries, requests, complaints or reported issues;

(d) ask you to participate in a survey;

(e) request feedback from you;

(f) advise you of industry and legislative updates;

(g) inform you about our events and seminars (including webinars);

(h) provide you with information about our Services; and

(i) provide you with any other information or materials that you have requested to receive from us.

(a) Identity;

(b) Contact;

(d) Usage;

(e) Profile; and

(f) Marketing and Communications.

(a) Performance of a contract with you.

Business and Financial Management

(a) To run our business in an efficient and proper manner.

(b) To enable third parties to provide us with services necessary for the client.

(d) To investigate and respond to client complaints.

(a) Identity;

(b) Contact;

(d) Usage;

(e) Profile; and

(f) Marketing and Communications.

(b) Necessary to comply with a legal obligation.

(a) To detect, investigate and prevent and/or report:

– breaches of internal and regulatory policies; and/or

– fraudulent activity and/or any other criminal activity.

(b) To assist and cooperate in any criminal or regulatory investigations against you, as may be required of us.

(a) Identity;

(b) Contact;

(d) Service;

(e) Financial; and

(f) Transaction.

(a) Necessary to comply with a legal obligation.

(b) Necessary for our legitimate interests (regulator relations, business reputation).

(a) To administer and protect our firm, business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

(b) To manage the performance and security of our equipment, IT systems and electronic platforms, including administering access rights.

(a) Identity;

(b) Contact;

(d) Usage.

(b) Necessary to comply with a legal obligation.

Marketing and Business Growth

(a) To carry out market research campaigns.

(b) To market our Services to you by email or other means if you have subscribed to one of our mailing lists (where you are not a client).

(c) To deliver relevant Website content and advertisements to you, and measure or understand the effectiveness of the advertising we serve to you.

(a) Identity;

(b) Contact;

(d) Usage;

(e) Profile; and

(f) Marketing and Communications.

(a) Necessary for our legitimate interests (to develop our lines of Services and grow our business, to define our clients and their industries or sectors, to keep our Services and the Site updated and relevant, and to inform our marketing strategy).

(b) On the basis of your consent, in the absence of a client relationship.

To permit us to pursue available remedies or limit any damages that we may sustain.

(a) Identity;

(b) Contact;

(d) Financial;

(e) Transaction; and

(f) Marketing and Communications.

(a) Performance of a contract with you.

(b) Necessary for our legitimate interests.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around advertising and marketing. Through your Identity, Contact, Service, Technical, Usage and Profile Data, we are able to form a view on what we think you or your organisation may want or need as to legal and advisory services. This is how we decide which of our Services may be of most relevance or interest for you and/or your organisation.

you have entered into a relationship with GSL (be it as a client or as an individual connected to a business), regardless of whether there is a formal agreement; and
provided you have not opted out of receiving marketing from us (see Your right to object below).

Where the above does not apply to you, we will only send you our marketing communications where you have expressly consented to receive them from us.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third parties (including our associated corporate entities) for marketing purposes.

Opting out

You can ask us to stop sending you marketing communications (unsubscribe) at any time by following the opt-out (unsubscribe) links on any marketing communication sent to you.

Cookies

Change of purpose

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at dp@ganado.com.

6. Disclosures of your personal data

We may transfer your personal data to Ganado Advocates or any affiliated or associated entities, such as Ganado Management Limited (C 94704) for the following purposes:

to facilitate and administer your business relationship with us;
as part of our regular reporting activities on company performances;
to consolidate our reporting and accounting procedures;
to ensure business efficiency (all above being part of our legitimate interests), and/or
where necessary to achieve or further any of the purposes in Section ‎5 above.

Law firms or other professional advisors involved in the provision of the Services to you (including instructing law firms, business partners or your professional advisors);
Suppliers and external agencies that we engage to process information on our or your behalf, including to provide you with the Services you may have requested;
To any relevant party in connection with our anti-money laundering, anti-fraud or ‘KYC’ requirements or policies (including third party service providers which carry out sanctions checks on our behalf);
Third-party payment processors, such as payment services providers and banks;
Our professional advisers (including our auditors, accountants, financial advisers, and legal counsel);
To regulators, government bodies and tax authorities (local and overseas) when required by applicable laws and/or regulations);
To any relevant party, claimant, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims in accordance with applicable law and regulation;
To any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences in accordance with applicable law;
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets (successors in title). Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We may also disclose your data if we are under a duty to disclose or share your personal data to comply with any legal obligation, judgment or under an order from a court, tribunal or authority. This includes exchanging information with the Police or regulatory bodies in Malta or if applicable, overseas, and other organisations and may undertake credit or fraud searches with relevant agencies for the purposes of fraud detection and prevention.

7. International transfers

the country to which the personal data is transferred ensures an adequate level of protection for the data subject’s rights and freedoms recognised under EU data protection law;
in the absence of an adequacy decision, the data transfer is regulated by specific contracts approved by the European Commission which give personal data the same standards of protection which it has in Europe (referred to as standard contractual Sections or model Sections); or
failing the above, the transfer is necessary:

for the performance of a contract concluded in your interests between us and another person;
for important reasons of public interest;
in order to comply with a legal or regulatory obligation to which we are subject; or
for the filing, exercise or defence of legal claims.

If we have to transfer your data to outside the EEA and cannot rely on any of the mechanisms set out above, we shall request your explicit consent to do so.

Please contact us at dp@ganado.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Note however that when you instruct us to share or transfer your personal data, we will perform any processing activity required to fulfil such instructions as your mandatories or appointed officers and not as an autonomous controller.

8. Data security

We also regularly review and, where practicable, improve upon these security measures.

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

9. Data retention

Please note that GSL considers its professional (service) relationship with clients to be an ongoing and continuous relationship, until such time that it is terminated in accordance with our Service Agreement. This also applies to their respective beneficial owners, directors and other individuals connected to their business.

How long will you use my personal data for?

thereafter:

for the purpose of satisfying any legal, accounting, tax, record-keeping or reporting obligations to which we may be subject; and/or
to the extent that we may also need to retain your personal data to be able to assert, exercise or defend possible future legal claims against or otherwise involving you.

Generally, our retention of your personal data shall not exceed a maximum period of eleven (11) years from the termination of our Services to you. We have taken into account prescriptive periods and our statutory obligations to comply with accounting, taxation, regulatory and anti-money laundering laws, which include mandatory record-keeping requirements for set periods. Some of your data may be deleted earlier, which (in the case of records) could be dictated by the specific record period set at law.

In some circumstances you can ask us to delete your data. See Request erasure below for further information.

Kindly contact us at dp@ganado.com for further details about the retention periods that we apply.

Data minimisation

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction (rectification) of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of those rights, please contact us at dp@ganado.com.

No fee is usually charged

What we may need from you

Time limit to respond

You have the right to:

(iv) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where:

there is no good reason for us continuing to process it;
you have successfully exercised your right to object to processing (see below);
we may have processed your information unlawfully; or
we are required to erase your personal data to comply with local law.

comply with a legal or regulatory obligation to which we are subject; or
establish, exercise or defend a legal claim.

In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal information that override your rights and freedoms.

(vii) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

if you want us to establish the data’s accuracy;
where our use of the data is unlawful but you do not want us to erase it;
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer (data portability) of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

11. Complaints

https://idpc.org.mt/en/Pages/Home.aspx)

We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

12. Conclusion

This Notice may be updated from time to time.

If you have any questions regarding this Notice, or if you would like to send us your comments, please contact us using the Contact Details indicated in this Notice.

GLOSSARY

Set out below are key definitions of certain terms which appear in this Notice:

“data subjects” means living, natural persons about whom we process personal data;
“data controller” or “controller” means any entity or individual who determines the purposes for which, and the manner in which, any personal data is processed;
“data processor” or “processor” means any entity or individual that processes data on our behalf and on our instructions (we being the data controller);
“GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
“legitimate interest” means our interest to conduct and manage our business appropriately and responsibly, to protect the reputation of our business, and to provide the best possible services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests;
“personal data” means data relating to a living individual (i.e., natural person) who can be identified from the data we possess about him or her. This includes, but is not limited to, your name and surname, address, date of birth, contact details. The term “personal information”, where and when used in this Notice, shall have the same meaning as personal data;
“processing” means any activity or set of operations that involves use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including, organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties; and
“special categories of personal data” includes information about a person’s racial or ethnic origin, political opinions, religious, philosophical or similar beliefs, trade union membership, physical or mental health or condition or sexual life or his or her biometric data.

Ganado Management Limited privacy notice

This version was last updated on 23rd April 2025

1. Introduction

Welcome to Ganado Management Limited’s privacy notice (the “Notice”).

Ganado Management Limited (C 94704) of 171, Old Bakery Street, Valletta VLT 1455, Malta (“GML”; “we”; “us”; “our”) respects your privacy and values its importance, and is wholly committed to protecting your personal data.

GML is associated with various corporate entities, including Ganado Services Limited (C 10785) (“GSL”), and is also a service company for Ganado Advocates of 171, Old Bakery Street, Valletta, VLT 1455, Malta, a leading commercial law firm based in Malta (“Ganado Advocates”). GML primarily handles the regulatory, technical, and administrative upkeep of vessels and owning companies as well as other corporate entities incorporated in Malta and, within that context, offers a broad spectrum of administrative services to its clients, ranging from general administrative services (such as the filing of vessel certificate renewals on behalf of its clients) to acting as a process and/or resident agent for its client (the “Services”).

This Notice explains how we will process your personal data when you:

approach and engage us to provide you with our Services, including where relating to the company or other legal person (a “corporate client”) which you own, hold, control or otherwise represent in whatever capacity; and/or
receive the various Services that you may request from us during the course of this service relationship.

It also covers any data that you may provide for our newsletters, legislative updates, events and other marketing and promotional communications.

You must ensure that they are made aware of this Notice and the individual rights and information it sets out prior to us receiving their information (whether obtained directly, obtained from you or from other sources). If you, or anyone else on your behalf, has provided or provides information on an individual connected to your business to us (or any entity associated with us), you or they must first ensure that you or they have that individual’s authorisation to do so and will be required to confirm the same to us.

Kindly note that, by engaging our services, you and/or the entity to which you are connected enter into a contractual relationship with GML, which will be governed by our Service Agreement. That Service Agreement stipulates that we will process your personal data in accordance with the practices set out in this Notice.

Please refer to the Glossary to understand the meaning of some of the terms used in this Notice.

2. Important information and who we are

This Notice supplements the other notices and is not intended to override them.

Controller

We are a controller of any personal data that we collect and process in connection with the Services. Our associated entities or Ganado Advocates may be controllers of your personal data in their own right, whether jointly with us or as independent controllers.

As a particular example, GML and Ganado Advocates have an ongoing relationship and together offer a ‘packaged’ service provision to clients, whereby:

Ganado Advocates is responsible for providing legal and advisory services; and
GML is responsible for providing the relevant administrative services;

as may be requested by the client. This may give rise to certain data processing activities by GML that are separate and autonomous to those conducted by Ganado Advocates.

Ganado Advocates and our associated entities have their own separate data protection notices which will be made available to you if and when they process your personal data.

Ganado Advocates’ privacy notice may be accessed:

https://ganado.com/privacy-statement/#section1.

GML and Ganado Advocates have a joint data protection team. This data protection team serves as our data protection contact point and is responsible for overseeing queries in relation to this Notice and generally any requests made in relation to personal data.

Our relationship with Ganado Advocates, GSL and other associated corporate entities is regulated by a group data sharing agreement. We also have a joint dedicated data protection team, which serves as our data protection contact point and is responsible for overseeing queries in relation to this Notice and for data subject requests. If you have any question about this Notice, including any requests to exercise your legal rights, please contact our data protection team using the contact details set out below.

Our full details are as follows.

Contact details

Full name of legal entity: Ganado Management Limited (C 94704).

Email address: dp@ganado.com

Postal address: 171, Old Bakery Street, Valletta VLT 1455, Malta.

Duty to inform us of changes

It is imperative that the personal data we hold about you is accurate and current at all times. Otherwise, this will impair our ability to provide you with the requested Services (amongst other relevant issues). Please keep us informed if your personal data changes during the course of our engagement and professional relationship with you.

3. The data we collect about you

In the course of any client engagement, we, GML, will need to collect, use and occasionally disclose personal data for various purposes associated with the scope of the Services that we provide, either for yourself (the client) or your entity (where you are an individual connected to a business). Given the broad spectrum of our potential Services, we cannot realistically provide an exhaustive list of all the items of personal data which we may need to process about our clients and/or the individuals connected to their business.

However, to ensure transparency, we have made an attempt to group and categorise below the different kinds of personal data which we process about our clients. For the reasons explained above, these data categories are mostly indicative and not exhaustive.

GML primarily services companies and other legal entities (that is, ‘corporate clients’ and not natural persons per se). Note, however, that GML has express legitimate interests to collect, process, store and at times even to disclose personal information about the individuals who own, control or are otherwise responsible for or involved in the management and administration of its corporate clients (that is, “individuals connected to a business”). Furthermore, we also require personal data about such individuals in order to enable us to provide and perform the Services which you have requested.

Identity Dataincludes first name, maiden name, last name, title, identity document number, gender, nationality, corporate involvements, and role and/or occupation;
Contact Dataincludes billing, mailing and email address and contact numbers;

In the context of our corporate clients, we may have to collect Identity and Contact Data about the following individuals connected to their business:

- directors;
- legal and judicial representatives;
- company secretary and other officers (for example, money laundering reporting officers, data protection officers and risk officers);
- internal (‘in-house’) legal counsel;
- auditors;
- shareholders and ultimate beneficial owners (UBOs);
- founders and board of administrators in the case of Foundation;
- settlors, beneficiaries, protectors and trustees in the case of a Trust.

Compliance Data (AML and KYC) includes the following due diligence information and documentation relating to our clients and/or the individuals connected to their business : (i) copy of an identity document and utility billl; (ii) professional references; (iv) screening database checks; and (iv) any other documentation that may from time to time be mandated or otherwise required at law to collect.
Service Data includes the following information about our clients:
- the client’s legal or business requirements, situation, plans, interests and targets or objectives;
- the Services requested by, and provided to, the client;
- involved and related parties, parties in interest, business partners, investors, advisors, assets, shareholders, corporate involvements, security holders, guarantors, buyers, transactions and customers of the client, and court decisions or orders issued in favour or against the client (as relevant and necessary to provide the Services).

Financial Data includes the client’s bank account details, together with details about any payment methods used by the client to settle our invoices (which we under particular circumstances use to establish creditworthiness and financial status);
Transaction Data includes details about (i) invoices issued to the client (including date of settlement and means of settlement), (ii) payments made to and from the client and (iii) any outstanding invoices due by the client;
Profile Data includes information about legal areas that may be of interest to you (based on the Services provided), your feedback and survey responses; and
Marketing and Communications Data includes your preferences in receiving marketing from us, our associated entities or third parties, and your communication preferences. This may include information on whether you have subscribed or unsubscribed from our mailing lists, attended our events or accepted our invitations.

If you fail to provide personal data

In certain cases, particularly where it relates to Compliance Data, we may even need to exercise our prerogative to terminate the Services and the existing professional (service) relationship with GML or otherwise decline at the outset to enter into a professional (service) relationship, as may be applicable. We will notify you if this is the case at the time.

Special categories of personal data

We may also need to occasionally process certain special categories of personal data about you, including for statutory due diligence and sanction screening requirements. This may comprise personal data revealing your political opinions or affiliations, and also personal data relating to criminal convictions and offences or related security measures.

There may be other occasions where we may need to process special categories of personal data about you, namely where:

the processing is necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law or regulation; or
the processing is necessary for the establishment, exercise or defence of legal rights.

In other cases, for example where required as part of the Service provision, we will rely on your authorisation to process the special category of personal data.

The officers and employees that form part of GML are bound by duties of confidentiality. Professional secrecy obligations may also apply with regards to certain individuals in GML.

4. How is your personal data collected?

We generally use different methods to collect data from and about you including through:

Direct Interactions. You may give us your Identity, Contact, Compliance, Financial, Assistance and Marketing and Communications Data by entering into our Service Agreement, filling in and submitting our client forms (such as our ‘Contact Form’ at: https://www.ganado.com/contact),or by corresponding with us by post, phone, email or otherwise or during face-to-face meetings.

This includes personal data you provide when you:

- approach us in the context of our corporate services;
- discuss with us the particular Services which you or your organisation may require (whether via meetings, telcos or email correspondence);
- you or your organisation enter into a formal service relationship with GML;
- request further assistance or other services from us;
- request and receive legal assistance from Ganado Advocates;
- contact us with complaints or queries;
- contact us with complaints or queries;
- complete an enquiry form;
- submit the Compliance Data that we request;
- request marketing to be sent to you;
- express interest and/or attend any of our seminars or other hosted events;
- participate in a survey or our webinars;
- subscribe to our newsletters and updates;
- give us some feedback.
Through our provision of the Services to you or your organisation. This may encompass each of the data categories listed in Section 3 (namely, Identity, Contact, Compliance, Financial, Transaction and Service Data).
During the course of dealings with you for or on behalf of your organisation or a client.This may encompass most of the data categories listed in Section 3, but will generally vary on a case-by-case basis.
Third parties or publicly available sources.We may receive personal data about you from various third parties and public sources as set out below:
- Financial and Transaction Datafrom our banks.
- Identity, Contact, Compliance and Service Datafrom publicly available sources such as public court documents, the Malta Business Registry, company registers of other jurisdictions, and from electronic data searches, online search tools (which may be subscription or license based), anti-fraud databases and other third-party databases, sanctions lists, and general searches carried out via online search engines (e.g. Google).
- Identity, Contact, Compliance and Service Datafrom your advisors or instructing entities, including instructing law firms.
- Financial Datafrom credit reference agencies.

If you attend an event or meeting at our offices, we may hold images of you captured by our CCTV cameras.

5. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where you wish to formally engage us;
Where we are providing you with your requested Services;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
Where we need to comply with our obligations to third parties (this includes our professional duties to the Courts of Malta and our obligations to regulators).

Purposes for which we will use your personal data

Note that we may process your personal data pursuant to more than one lawful ground or basis, depending on the specific purpose for which we are using your data.

Purpose/Activity

Type of Data

Lawful Basis for Processing

Onboarding Requirements

(a) ‘New client onboarding’

– to onboard new client engagements and comply with our internal policies and procedures; and

– to assess and take an informed decision on whether we will enter into a service relationship with you.

(b) To determine whether GML can provide you with the requested Services and, as applicable, perform them on an ongoing basis.

(a) Identity;

(b) Contact;

(d) Service; and

(e) Financial.

(a) Performance of a contract with you.

(b) Necessary for our legitimate interests (to determine whether we can or want to enter into a service relationship with you, to determine whether we can provide the Services that you have requested, to carry out internal conflict clearance searches and verify your ability to meet financial commitments that may result from the Service provision).

Service Provision

(a) To provide you or your organisation with the requested Services.

(b) To improve the provision of those Services to you or your organisation.

(a) Identity;

(b) Contact;

(a) Performance of a contract with you.

(b) Legitimate business interests (quality control, business reputation, to keep track of the Services provided and their status or outcome, to be able to revisit them should issues arise).

(a) For billing and invoice purposes.

(b) To collect and recover money which is owed to us (debt recovery).

(a) Identity;

(b) Contact;

(d) Financial; and

(e) Transaction.

(a) Performance of a contract with you.

(b) Necessary to comply with a legal obligation (accounting and other record-keeping requirements).

Relationship Management

To manage our professional relationship with you (as a client or where the client is your organisation), which may include the following:

(a) notify you about changes to our terms of business or privacy notices;

(b) deal with your enquiries, requests, complaints or reported issues;

(d) ask you to participate in a survey;

(e) request feedback from you;

(f) advise you of industry and legislative updates;

(g) inform you about our events and seminars (including webinars);

(h) provide you with information about our Services; and

(i) provide you with any other information or materials that you have requested to receive from us.

(a) Identity;

(b) Contact;

(d) Marketing and Communications.

(a) Performance of a contract with you.

Business and Financial Management

(a) To run our business in an efficient and proper manner;

(b) To enable third parties to provide us with services necessary for the client;

(d) To investigate and respond to client complaints.

(a) Identity;

(b) Contact;

(d) Marketing and Communications.

(b) Necessary to comply with a legal obligation.

(a) To detect, investigate and prevent and/or report:

– breaches of internal and regulatory policies; and/or

– fraudulent activity and/or any other criminal activity.

(b) To assist and cooperate in any criminal or regulatory investigations against you, as may be required of us.

(a) Identity;

(b) Contact;

(d) Service;

(e) Financial; and

(f) Transaction.

(a) Necessary to comply with a legal obligation.

(b) Necessary for our legitimate interests (regulator relations, business reputation).

Marketing and Business Growth

(a) To carry out market research campaigns.

(b) To market our Services to you by email or other means if you have subscribed to one of our mailing lists (where you are not a client).

(c) To deliver relevant Website content and advertisements to you, and measure or understand the effectiveness of the advertising we serve to you.

(a) Identity;

(b) Contact;

(d) Marketing and Communications.

(a) Necessary for our legitimate interests (to develop our lines of Services and grow our business, to define our clients and their industries or sectors, to keep our Services and the Site updated and relevant, and to inform our marketing strategy).

(b) On the basis of your consent, in the absence of a client relationship.

To permit us to pursue available remedies or limit any damages that we may sustain.

(a) Identity;

(b) Contact;

(d) Financial;

(e) Transaction; and

(f) Marketing and Communications.

(a) Performance of a contract with you.

(b) Necessary for our legitimate interests.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around advertising and marketing. Through your Identity, Contact, Service and Profile Data, we are able to form a view on what we think you or your organisation may want or need as to legal and advisory services. This is how we decide which of our Services may be of most relevance or interest for you and/or your organisation.

you have entered into a relationship with GML (be it as a client or as an individual connected to a business), regardless of whether there is a formal agreement; and
provided you have not opted out of receiving marketing from us (see Your right to objectbelow).

Where the above does not apply to you, we will only send you our marketing communications where you have expressly consented to receive them from us.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third parties (including our associated corporate entities) for marketing purposes.

Opting out

You can ask us to stop sending you marketing communications (unsubscribe) at any time by following the opt-out (unsubscribe) links on any marketing communication sent to you.

Change of purpose

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at dp@ganado.com.

6. Disclosures of your personal data

We may transfer your personal data to Ganado Advocates or any affiliated or associated entities, such as Ganado Services Limited (C 10785) for the following purposes:

to facilitate and administer your business relationship with us;
as part of our regular reporting activities on company performances;
to consolidate our reporting and accounting procedures;
to ensure business efficiency (all above being part of our legitimate interests), and/or
where necessary to achieve or further any of the purposes in Section ‎5 above.

Law firms or other professional advisors involved in the provision of the Services to you (including instructing law firms, business partners or your professional advisors);
Suppliers and external agencies that we engage to process information on our or your behalf, including to provide you with the Services you may have requested;
To any relevant party in connection with our anti-money laundering, anti-bribery, anti-fraud or ‘KYC’ requirements or policies (including third party service providers which carry out sanctions checks on our behalf);
Third-party payment processors, such as payment services providers and banks;
Our professional advisers (including our auditors, accountants, financial advisers, and legal counsel);
To regulators, government bodies and tax authorities (local and overseas) when required by applicable laws and/or regulations);
To any relevant party, claimant, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims in accordance with applicable law and regulation;
To any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences in accordance with applicable law;
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets (successors in title). Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We may also disclose your data if we are under a duty to disclose or share your personal data to comply with any legal obligation, judgment or under an order from a court, tribunal or authority. This includes exchanging information with the Police or regulatory bodies in Malta or if applicable, overseas, and other organisations and may undertake credit or fraud searches with relevant agencies for the purposes of fraud detection and prevention.

7. International transfers

the country to which the personal data is transferred ensures an adequate level of protection for the data subject’s rights and freedoms recognised under EU data protection law;
in the absence of an adequacy decision, the data transfer is regulated by specific contracts approved by the European Commission which give personal data the same standards of protection which it has in Europe (referred to as standard contractual Sections or model Sections); or
failing the above, the transfer is necessary:

for the performance of a contract concluded in your interests between us and another person;
for important reasons of public interest;
in order to comply with a legal or regulatory obligation to which we are subject; or
for the filing, exercise or defence of legal claims.

If we have to transfer your data to outside the EEA and cannot rely on any of the mechanisms set out above, we shall request your explicit consent to do so.

Please contact us at dp@ganado.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. Data security

We also regularly review and, where practicable, improve upon these security measures.

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

9. Data retention

Please note that GML considers its professional (service) relationship with clients to be an ongoing and continuous relationship, until such time that it is terminated in accordance with our Service Agreement. This also applies to their respective beneficial owners, directors and other individuals connected to their business.

How long will you use my personal data for?

thereafter:

for the purpose of satisfying any legal, accounting, tax, record-keeping or reporting obligations to which we may be subject; and/or
to the extent that we may also need to retain your personal data to be able to assert, exercise or defend possible future legal claims against or otherwise involving you.

Generally, our retention of your personal data shall not exceed a maximum period of eleven (11) years from the termination of our Services to you. We have taken into account prescriptive periods and our statutory obligations to comply with accounting, taxation and (where arising) regulatory and anti-money laundering laws, which include mandatory record-keeping requirements for set periods. Some of your data may be deleted earlier, which (in the case of records) could be dictated by the specific record period set at law.

In some circumstances you can ask us to delete your data. See Request erasure below for further information.

Kindly contact us at dp@ganado.com for further details about the retention periods that we apply.

Data minimisation

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction (rectification) of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of those rights, please contact us at dp@ganado.com.

No fee is usually charged

What we may need from you

Time limit to respond

You have the right to:

(iv) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where:

there is no good reason for us continuing to process it;
you have successfully exercised your right to object to processing (see below);
we may have processed your information unlawfully; or
we are required to erase your personal data to comply with local law.

comply with a legal or regulatory obligation to which we are subject; or
establish, exercise or defend a legal claim.

In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal information that override your rights and freedoms.

(vi) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

if you want us to establish the data’s accuracy;
where our use of the data is unlawful but you do not want us to erase it;
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it.

(vii) Request the transfer (data portability) of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

11. Complaints

https://idpc.org.mt/en/Pages/Home.aspx

We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

12. Conclusion

This Notice may be updated from time to time.

If you have any questions regarding this Notice, or if you would like to send us your comments, please contact us using the Contact Details indicated in this Notice.

GLOSSARY

Set out below are key definitions of certain terms which appear in this Notice:

“data subjects” means living, natural persons about whom we process personal data;
“data controller” or “controller” means any entity or individual who determines the purposes for which, and the manner in which, any personal data is processed;
“data processor” or “processor” means any entity or individual that processes data on our behalf and on our instructions (we being the data controller);
“GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
“legitimate interest” means our interest to conduct and manage our business appropriately and responsibly, to protect the reputation of our business, and to provide the best possible services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests;
“personal data” means data relating to a living individual (i.e., natural person) who can be identified from the data we possess about him or her. This includes, but is not limited to, your name and surname, address, date of birth, contact details. The term “personal information”, where and when used in this Notice, shall have the same meaning as personal data;
“processing” means any activity or set of operations that involves use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including, organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties; and
“special categories of personal data” includes information about a person’s racial or ethnic origin, political opinions, religious, philosophical or similar beliefs, trade union membership, physical or mental health or condition or sexual life or his or her biometric data.

Search

Our people

Industries

Practice areas

Privacy notice

Ganado Advocates (Malta) privacy notice

2. Important information and who we are

Controller

3. The data we collect about you

4. How is your personal data collected?

5. How we use your personal data

Purposes for which we will use your personal data

Marketing

Third-party marketing

Opting out

Cookies

Change of purpose

6. Disclosures of your personal data

7. International transfers

8. Data security

9. Data retention

Data minimisation

10. Your legal rights

11. Complaints

12. Conclusion

GLOSSARY

Ganado SARL (Luxembourg) privacy notice

Introduction

1. Important information and who we are

Controller

Contact details

Changes to the privacy notice and your duty to inform us of changes

Third-party links

2. Some key definitions

3. The data we collect about you

If you fail to provide personal data

Special categories of personal data

4. How is your personal data collected?

5. How we use your personal data

Purposes for which we will use your personal data

Marketing

Third-party marketing

Opting out

Cookies

Change of purpose

6. Disclosures of your personal data

7. International transfers

8. Data security

9. Data retention

Data minimisation

10. Your legal rights

11. Complaints

12. Conclusion

Ganado Services Limited privacy notice

1. Introduction

2. Important information and who we are

Controller

Duty to inform us of changes

Third-Party Links

Minors

3. The data we collect about you

If you fail to provide personal data

Special categories of personal data

4. How is your personal data collected?

5. How we use your personal data

Purposes for which we will use your personal data

Marketing

Third-party marketing

Opting out

Cookies

Change of purpose

6. Disclosures of your personal data

7. International transfers

8. Data security

9. Data retention

Data minimisation

10. Your legal rights

No fee is usually charged

What we may need from you

Time limit to respond