Privacy notice

Ganado Management Limited privacy notice

Ganado Advocates (Malta) privacy notice

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. 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 Data Protection Act (Chapter 586 of the Laws of Malta) (the “Act”), as may be amended or replaced from time to time, and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “Regulation” or the “GDPR”).

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.

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”).

We (Ganado Advocates) are the controller and responsible for the Website.

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. For instance, GSL regularly assists Ganado in providing corporate services for clients who initially engaged Ganado, which may give rise to certain autonomous data processing activities by GSL. These associated corporate entities have their own separate data protection notices which will be made available to you if and when they process your personal data.

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 Advocates.

Email address: dp@ganado.com

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

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 Malta, this is the Office of the Information and Data Protection Commissioner (the “IDPC”) (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.

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

This version was last updated on May, 2018.

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 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 both the Act and the GDPR. 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

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 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.

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 strictly 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 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 by the Prevention of Money Laundering Act (Chapter 373 of the Laws of Malta) (“PMLA”), the Prevention of Money Laundering and Funding of Terrorism Regulations (“PMLFTR”), the Financial Intelligence Analysis Unit (“FIAU”) and/or any other competent authority or related legislation.

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).

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 occasionally need to collect and process certain special categories of personal data, including potentially information relating to your criminal convictions and offences. When this data concerns you, by engaging us you will be providing us with your unambiguous consent to process the data in order to provide you with the requested services. We may also process third party special categories of data where authorised by, and in accordance with our obligations at law.

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 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 legal and professional 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 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

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 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 PMLA, PMLFTR 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 MFSA, 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: dp@ganado.com.

“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

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 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

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 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 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 Commissioner for Revenue, regulators and other authorities, including the Courts of Malta, the Financial Intelligence Analysis Unit, the Police Authorities and the Malta Financial Services Authority.
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 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 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

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.

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 six (6) 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 period of up to eleven (11) years in order to comply with applicable accounting and tax laws (this will primarily consist of your Transaction and Payment Data). 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.

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 the rights set out above, please contact us at dp@ganado.com.

No fee is usually charged

You will not have to pay a fee to access your personal data (or to exercise any of the other 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 take 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 Marketing in Clause ‎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 however affect the lawfulness of any processing which we 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. Conclusion

We reserve the right to make changes to this Notice in the future, which will be duly notified to you. If you have any questions regarding this Notice, or if you would like to send us your comments, please contact us today or alternatively write to our dedicated data protection team, using the contact details indicated earlier on this web page.

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.

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’.

Controller

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

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

2. Some key definitions

Set out below are key definitions of certain data protection terms which appear 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).

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

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;

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.

If you fail to provide personal data

Special categories 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)

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.

“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 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.

7. International transfers

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.

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

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 the rights set out above, please contact us at nhernandez@ganado.com.

No fee is usually charged

What we may need from you

Time limit to respond

You have the right to:

You may send an email to nhernandez@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.

(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.

11. Conclusion

Ganado Services Limited privacy notice

Introduction

Welcome to Ganado Services Limited’s privacy statement (the “Statement”).

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, ranging from registered office services to full company secretarial services, including organisation of Board Meeting and Annual General Meetings in Malta (the “Services”).

Accordingly, 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 Services, including where relating to the company or other legal entity (herein an “entity”) 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.

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

Kindly note that, by engaging our services as a CSP, you and/or your respective entity enter into a contractual (service) relationship with GSL, as subject to and governed by our Service Agreement. This 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.

Although GSL primarily services companies and other legal entities, this Notice is also addressed to their respective beneficial owners, shareholders, founders, directors, representatives, company officers, registered owners or registered charterers, administrators and any other individual responsible or otherwise involved in their management and administration (as applicable). This Notice should therefore be circulated accordingly.

1. Important information and who we are

This Notice aims to ensure that you are fully informed on how GSL 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 unless and except where it is necessary to provide you with the Services that you may request from us.

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 at all times.

Controller

GSL is associated with various corporate entities and is also the service company for Ganado Advocates of 171, Old Bakery Street, Valletta, VLT 1455, Malta, a leading commercial law firm based in Malta (“Ganado Advocates”).

We (Ganado Services Limited) are the controller and responsible for the Website.

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 and/or Ganado Advocates may also be data controllers of your personal data in their own right, whether jointly with GSL or as entirely separate data 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 the relevant legal and advisory services; and
GSL, on the other hand, is responsible for providing the relevant shipping and corporate administrative services,

as may be requested by the client in question. This may, therefore, give rise to certain autonomous data processing activities on the part of Ganado Advocates with respect to your personal data.

Ganado Advocates and our associated corporate 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 is governed by a joint controller agreement.

GSL and Ganado Advocates have a joint dedicated 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 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 Services Limited (C 10785)

Email address: dp@ganado.com

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

In the case of Malta, this is the Office of the Information and Data Protection Commissioner (the “IDPC”) (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.

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

This version was last updated on June 2018.

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 professional (service) relationship with you.

Third-party links

Some key definitions

Set out below are key definitions of certain data protection terms which appear 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).

Note that personal data does not include information relating to a legal person (such as, 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 both the Act and the GDPR. Consequently, 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 client practices and obligations at law.

3. The data we collect about you

In the course of its professional (service) relationship with you and/or your respective entity, GSL 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 which we offer and provide (be it at your own request or on behalf of your respective entity). Given the broad spectrum of our potential Services to you and your respective entity, it is both impractical and almost impossible to exhaustively list all of the items of personal data which we may need to collect, use or disclose about you.

However, to ensure transparency, we have made an attempt to group and categorise below the different kinds of personal data about (i) our clients (including, where applicable, their respective owners, beneficiaries, representatives, officers and/or administrators) and/or (ii) mere users of the Website, which we (GSL) may generally need to collect, process, use, share and store. For the reasons explained above, these data categories are strictly indicative and not exhaustive.

As mentioned in the ‘Introduction’, 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. Furthermore, we (GSL) 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, corporate involvements, occupation and (in the context of the Site) username or similar identifier.
Contact Data includes billing address, mailing address, email address and contact numbers.

As mentioned, in the context of our corporate clients, we collect Identity and Contact Data about the following persons:

directors;
• legal and judicial representatives;
• company officers (including, for example, MLROs);
• external advisors (including auditors, accountants and tax advisors)
• shareholders (direct and indirect), ultimate beneficial owners (UBOs) and any individual who otherwise exercises control;
• registered owner and/or registered charterer in the case of a Vessel (if a natural person);
• founders and board of administrators in the case of Foundation; and
• 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 their respective beneficial owners, shareholders, founders, directors, representatives, company officers, registered owners or registered charterers, and/or administrators (as applicable) in the case of corporate clients: (i) copy of an identity document, (ii) copy of a recently issued utility bill, (iii) professional references, (iv) tax domicile status, (v) financial status information (bank statements, source of wealth and other related documents), (vi) KYC’ (database) checks and (vii) any other documentation or information which may be mandated from time to time by the Prevention of Money Laundering Act (Chapter 373 of the Laws of Malta) (“PMLA”), the Prevention of Money Laundering and Funding of Terrorism Regulations (“PMLFTR”), the Register of Beneficial Owners Regulations (the “RBO Regulations), the Financial Intelligence Analysis Unit (“FIAU”), the Malta Business Registry (“MBR”), the MFSA and/or any other competent authority or related legislation.
Service Data includes the following information about our clients:
the client’s professional requirements, needs, 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).

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 and/or its respective owners, beneficiaries, representatives, officers and/or administrators (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 professional 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, our associated or affiliated entities or our third parties 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, seminars or webinars, or accepted any of our invitations.

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 about you by law, or pursuant to the terms of our professional (service) relationship with you and/or your respective entity, and you fail to provide that data when requested, we may not be able to service you or your respective entity.

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

We may occasionally need to collect and process certain special categories of personal data, including potentially information relating to your criminal convictions and offences. When this data concerns you, by engaging GSL (whether on your own behalf or on behalf of your respective entity), you will be providing us with your unambiguous consent to process the data in order to provide you with the requested Services. We may also process third party special categories of data where authorised by, and in accordance with our obligations at law.

The officers and employees that form part of GSL are bound by strict duties of confidentiality. In addition, 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, Service and Marketing and Communications Data by entering into our Service Agreement, filling in our forms (such as our ‘Contact Form’ accessible at: https://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 service offerings;
- discuss with us the particular Services which you and/or your respective entity may require (whether via meetings, telcos or email correspondence);
- or your respective entity, 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 to your respective entity. This may encompass all of the data categories listed in Clause 3 (namely, Identity, Contact, Compliance, Service, Transaction and Assistance Data).
During the course of our dealings with you. 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:
  - 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 MBR, the Malta Ship Registry, company houses, company registers and shipping registers of other jurisdictions, and from electronic data searches, online KYC 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 and/or your respective entity wish to enter into a professional (service) relationship with us.
Where we are providing you and/or your respective entity with the 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 obligations and duties to regulators and in the context of mandatory external reporting obligations).

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 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 including basis of legitimate interest

(a) To determine whether GSL will enter into a professional relationship with you and/or your respective entity;

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

(a) Identity;

(b) Contact;

(d) Service; 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 (or other individuals involved in the respective entity), to determine whether we can provide and perform the requested Services, to carry out internal conflict clearance searches. Further, in the case of beneficial owners and shareholders, to verify ability to meet financial commitments that may result from the scope of the requested Services).

(a) To establish and verify your identity (This is primarily applicable to those individuals who own, exercise control or are otherwise responsible for or involved in the management and administration of the corporate client).(b) To fulfil our other internal compliance policies and requirements;

(c) To fulfil any licensing requirements which may be imposed on us, whether now or in the future (as a duly licensed corporate service provider operating from Malta);

(d) To comply with our obligations under the PMLA, PMLFTR and others laws or regulations that may be applicable to us in terms of client due diligence and AML requirements; and

(e) To fulfil any external mandatory reporting obligations that we may have to the FIAU, the MFSA, the MBR, the Police and any other (including overseas) public, regulatory, law enforcement or tax authority

(a) Identity;(b) Contact;

(d) Service**

**provided that we are exempted from confidentiality and any applicable 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 (including beneficial owners and involved individuals for corporate clients), even where the requested assistance does not amount to a ‘relevant activity’ – namely, for internal risk assessment and management).

(a) To provide you and/or your respective entity with the requested Services (which may include assistance in terms of RBO record keeping and notification requirements); and

(b) To improve the provision of those Services to you and/or your respective entity.

(a) Identity;

(b) Contact;

(a) Performance of a contract with you.

(b) Necessary to comply with our professional obligations and 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;

(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 respective entity), 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

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

(a) Identity;(b) Contact;

(d) Usage;

(e) Profile;

(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;

(d) Service;

(e) Financial; and

(f) Transaction.

Necessary to comply with a legal obligation.

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

(a) Identity;(b) Contact;

(d) Usage.

(a) Necessary for our legitimate interests (for running and administering our 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 subscribed to one of our mailing lists (where you and/or your respective entity are not a client);

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

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

(a) Identity;

(b) Contact;

(d) Financial;

(e)Transaction;

(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 our standing as a leading corporate service provider, 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: dp@ganado.com.

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

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 respective entity may want or need in terms of shipping and corporate administrative services. This is how we decide which of our Services may be of most relevance or interest for you and/or your respective entity.

you have entered into a relationship with GSL (be it as a client, the owner or representative of the corporate client or as a business partner), regardless of whether a formal service agreement 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 dp@ganado.com.

6. Disclosure 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:

Ganado Advocates of 171, Old Bakery Street, Valletta, VLT 1455, Malta;
Our other associated or affiliated entities;
Other entities or professional advisors involved in the provision of the Services to you (including, amongst others, instructing law firms, business partners or your internal or external advisors).
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 which you may have requested.
Service providers, including those that provide IT support and system administration services for GSL.
Professional advisers such as consultants, bankers, professional indemnity insurers, brokers and auditors.
Regulators and authorities (local and overseas), including the Courts of Malta, the Commissioner for Revenue, the FIAU, the MFSA, the MBR and the Police Authorities.
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.

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 the requested Services, (ii) fulfil our contractual obligations to you or your respective entity, (iii) exercise and enforce our contractual rights, (iv) comply with our legal or regulatory obligations or (v) 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 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 (particularly in the context of any company secretarial or corporate governance support services), we will perform any processing activity required to fulfil such instructions as your mandatories or appointed officers and not as an autonomous controller. 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 also 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

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, shareholders, founders, directors, representatives, company officers, registered owners or registered charterers, administrators and any other individual responsible or otherwise involved in their management and administration (as applicable).

By and large, our retention of your personal data shall not exceed the period of six (6) years from the termination of the professional (service) relationship with GSL. This retention period enables us to make use of your personal data for 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 or your respective entity (taking into account applicable statutes of limitation). In certain cases, we may need to retain your personal data for a period of up to eleven (11) years in order to comply with applicable accounting and tax laws (this will primarily consist of your Financial and Transaction Data). There may also be instances where the need to retain personal data for longer periods, as 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 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 the rights set out above, 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:

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 take places, we will inform you, within a reasonable and practicable timeframe, about the third party or publicly accessible source from whom 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 GSL, since this may otherwise impair our ability to provide you and/or your respective entity with the 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.

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 onto the data even if we no longer require it, as you need it to establish, exercise or defend legal claims; or
where you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it.

(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 however affect the lawfulness of any processing which we carried out before you withdrew your consent. Any processing activities that are not based on your consent will remain unaffected.

11. Conclusion

We reserve the right to make changes to this Notice in the future, which will be duly notified to you. If you have any questions regarding this Notice, or if you would like to send us your comments, please contact us today or alternatively write to our data protection team using the details indicated in this Notice.

Ganado Management Limited privacy notice

Privacy Notice: This version was last updated on 14 April 2023

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 the client (the “Services”).

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 Services, including when they relate to the company or other legal entity (generally referred to in this Notice as an “entity”) which you own, hold, control, or otherwise represent in whatever capacity; and
receive the Services that you request from us during the course of this service relationship.

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

Kindly note that, by engaging our Services, you and/or your respective entity enter into a contractual relationship with GSL, as subject to and governed by our Service Agreement. This Service Agreement stipulates that we will process your personal data in accordance with the practices set out in this Notice.

Although GML primarily services companies and other legal entities, this Notice is also addressed to their respective beneficial owners, shareholders, founders, directors, representatives, company officers, registered owners or registered charterers, administrators and any other individual responsible or otherwise involved in their management and administration (as applicable).

This Notice should therefore be circulated accordingly.

1. Important information and who we are

This Notice aims to ensure that you are fully informed on how GML will collect and process your personal data in the scenarios described in the ‘Introduction’. It informs you about the items of personal data that we may collect about you and how we will handle it, and also tells you about (i) our obligations to process your personal data responsibly, (ii) your rights as a data subject and (iii) how the law protects you.

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

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

Controller

We (Ganado Management Limited) are also the controller of any personal data which we collect or receive and which we process in connection with the Services. Our associated corporate entities and/or Ganado Advocates may also controllers of your personal data in their own right, whether jointly with GML or as entirely separate data controllers. As a particular example, GML and Ganado Advocates have an ongoing relationship and together offer a ‘packaged’ service provision to their joint clients, whereby:

Ganado Advocates is responsible for providing the relevant legal and advisory services; and
GML, on the other hand, is responsible for providing the relevant administrative services,

as may be requested by the client in question.

Ganado Advocates and our associated corporate 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, 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.

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 Management Limited (C 94704)

Email address: dp@ganado.com

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

You have the right to lodge a complaint at any time to a competent supervisory authority on data protection matters, such as the supervisory authority in the place of your habitual residence or your place of work.

Changes to the privacy notice and your 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 could impair our ability to provide you with the Services, amongst other potential issues. Please keep us informed if your personal data changes at any time during our professional relationship with you.

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 (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);
“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, holding, organising, amending, retrieving, using, disclosing, erasing or destroying personal data. 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.

Note that personal data does not include information relating to a legal person (such as, 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 both the Act and the GDPR. Consequently, 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 all and any such information in a confidential manner, in accordance with our standard client practices and obligations at law.

3. The data we collect about you

In the course of its professional (service) relationship with you or your respective entity, GML will need to collect, use, and sometimes disclose, various items of personal data about you for various purposes associated with the scope of our Services (be it at your own request or on behalf of your respective entity).

Due to the broad spectrum of potential Services which you or your respective entity may request from us, it is both impractical and almost impossible to exhaustively list all the items of personal data which we may need to collect or otherwise process. However, to ensure transparency, we have made an attempt to group and categorise below the different kinds of personal data held concerning our clients (including, where applicable, their respective owners, beneficiaries, representatives, officers and/or administrators). For the reasons explained above, these data categories are strictly indicative and not exhaustive.

As mentioned in the ‘Introduction’, GML primarily services companies and other legal entities (that is, ‘corporate clients’ and not natural persons per se). Nonetheless, please note 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. Furthermore, we (GML) also require personal information about such individuals in order to enable us to provide and perform the requested Services.

The data categories we collect include:

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

In the context of our corporate clients, we collect Identity and Contact Data about the following persons:

directors;
legal and judicial representatives;
company officers;
external advisors (including auditors, accountants, and tax advisors)
shareholders (direct and indirect), ultimate beneficial owners (UBOs) and any individual who otherwise exercises control;
registered owner and/or registered charterer in the case of a Vessel (if a natural person);
founders and board of administrators in the case of Foundation; and
settlors, beneficiaries, protectors, and trustees in the case of a Trust.
Compliance Data includes the following due diligence information and documentation relating to our clients, and/or their beneficial owners, shareholders, founders, directors, representatives, company officers, registered owners or charterers and/or administrators (as applicable) in the case of corporate clients: (i) copy of an identity document and recently issued utility bill, (ii) professional references, (iii) KYC’ (database) checks and (iv) any other such documentation or information which 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 requirements, needs, 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).

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 and/or its respective owners, beneficiaries, representatives, officers and/or administrators (as needed 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 and means of settlement), (ii) payments made to and from the client and (iii) any outstanding invoices.
Profile Data includes information about the professional areas that may be of interest or relevance to you (based on the Services that you request from us), your feedback and survey responses.
Marketing and Communications Data includes your preferences in receiving marketing from us, our associated or affiliated entities or our third parties 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, seminars or webinars, or accepted any of 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 occasionally need to collect and process certain special categories of personal data, including, potentially, information relating to your criminal convictions and offences. We will only do so to the extent allowed by law and, in most cases, as necessary to determine whether to accept you or your entity as a client or, in the case of an existing relationship, whether to maintain that relationship and continue providing the Services We may also process third party special categories of data where authorised by, and in accordance with our obligations at law.

The officers and employees that form part of GML are bound by strict duties of confidentiality. In addition, 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, Service and Marketing and Communications Data by entering into our Service Agreement, filling in our forms (such as our Contact Form accessible at: https://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 service offerings;
- discuss with us the specific services which you and/or your respective entity may require (whether via meetings, telcos or email correspondence);
- you or your respective entity enter into a formal service relationship with GMl;
- request further assistance or other services from us;
- 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, events or webinars;
- subscribe to our newsletters and updates;
- provide us with feedback.
Through our provision of the Services to you or to your respective entity. This may cover all the data categories set out in section 3.
During the course of our dealings with you. This may encompass most of the data categories set out 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 Data from our banks.
- Identity, Contact, Compliance and Service Data from publicly available sources such as public court documents, the MBR, the Malta Ship Registry, company houses, company registers and shipping registers of other jurisdictions, and from electronic data searches, online KYC 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 and/or your respective entity wish to enter into a client relationship with us.
Where we are providing you and/or your respective entity with the 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 any mandatory external reporting obligations which we may have).

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 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 including basis of legitimate interest

(a) To determine whether GML will enter into a professional relationship with you and/or your respective entity;

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

(a) Identity;

(b) Contact;

(d) Service; and

(e) Financial.

(a) Performance of a contract with you or 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 (or other individuals involved in the respective entity), to determine whether we can provide and perform the requested Services, to carry out internal conflict clearance searches. Further, in the case of beneficial owners and shareholders, to verify ability to meet financial commitments that may result from the scope of the requested Services.

To provide you and/or your respective entity with the requested Services, and to improve their provision (including from the feedback received from your).

(a) Identity;

(b) Contact;

(a) Performance of a contract with you.

(b) Legitimate interests (business reputation).

(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;

(e) Transaction.

(a) Performance of a contract with you.

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

To manage our professional/service relationship with you (whether as a client or if the client is your respective entity), which may include to:

– notify you about changes to our terms of business or privacy notices;

– deal with your enquiries, requests, complaints or reported issues;

– contact you in the course of providing your requested Services;

– ask you to participate in a survey;

– request feedback from you;

– advise you of industry and legislative updates,

– provide you with information about our Services, and

– 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.

(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;

(d) Service;

(e) Financial; and

(f) Transaction.

Necessary to comply with a legal obligation.

(a) To carry out marketing campaigns;

(b) To market our Services to you by email or other means if you have subscribed to one of our mailing lists.

(a) Identity;

(b) Contact; and

(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 updated, and inform our marketing strategy).

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

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

(a) Identity;

(b) Contact;

(d)Transaction;

(e) Marketing and Communications.

(a) Performance of a contract with you.

(b) Necessary for our legitimate interests.

(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;

(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.

Marketing

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

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

you have entered into a relationship with GML (be it as a client, the owner or representative of the corporate client or as a business partner), regardless of whether a formal service agreement 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.

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.

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.

6. Disclosure 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 section 5 above:

Ganado Advocates or Ganado Services Limited of 171, Old Bakery Street, Valletta, Malta;
Our other associated or affiliated entities;
Other entities or professional advisors involved in the provision of the Services to you (including, amongst others, instructing law firms, business partners or your internal or external advisors);
Suppliers and external agencies that we engage to process information on our or your behalf, including to provide you with the information or materials which you may have requested;
Service providers, including IT and system administration support;
Professional advisers such as consultants, bankers, professional indemnity insurers, brokers and auditors.
Regulators and authorities (local and overseas), including the Courts of Malta, the Commissioner for Revenue, the MBR and the Police Authorities.
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.

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 the requested Services, (ii) fulfil our contractual obligations to you or your respective entity, (iii) exercise and enforce our contractual rights, (iv) comply with our legal or regulatory obligations or (v) 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 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.

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 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, shareholders, founders, directors, representatives, company officers, registered owners or registered charterers, administrators and any other individual responsible or otherwise involved in their management and administration (as applicable).

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it (i.e. to provide the Services and for the ongoing performance of our professional relationship with you) and, thereafter, for the purpose of satisfying any legal, accounting, tax and other 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.

By and large, our retention of your personal data shall not exceed the period of six (6) years from the termination of the professional (service) relationship with GML. This retention period enables us to make use of your personal data for potential reporting obligations and/or for the assertion, filing or defence of possible legal claims by or against you or your respective entity (taking into account applicable statutes of limitation). In certain cases, we may need to retain your personal data for a period of up to eleven (11) years in order to comply with applicable accounting and tax laws (this will primarily consist of your Financial and Transaction Data). There may however also be instances where the need to retain personal data for longer periods, as 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 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 the rights set out above, please contact us at dp@ganado.com.

No fee is usually charged

Alternatively, we may simply refuse to comply with your request in such circumstances.

What we may need from you

Time limit to respond

You have the right to:

Request access to your personal data (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 information when collecting and processing personal data about you, including from publicly accessible or third-party sources. When this take places, we will inform you, within a reasonable and practicable timeframe, including as to the third party or publicly accessible source from whom 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 GML, since this may otherwise impair our ability to provide you and/or your respective entity with the 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 Marketing in section ‎5above).

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 onto the data even if we no longer require it, as you need it to establish, exercise or defend legal claims; or
    - where 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 however affect the lawfulness of any processing which we carried out before you withdrew your consent. Any processing activities that are not based on your consent will remain unaffected.

11. Conclusion

We reserve the right to make changes to this Notice in the future, which will be duly notified to you. If you have any questions regarding this Notice, or if you would like to send us your comments, please contact us today or alternatively write to our data protection team using the details indicated in this Notice.

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Privacy notice

Ganado Advocates (Malta) 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

No fee is usually charged

What we may need from you

Time limit to respond

11. Conclusion

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

No fee is usually charged

What we may need from you

Time limit to respond

11. Conclusion

Ganado Services Limited privacy notice

Introduction

1. Important information and who we are

Controller

Contact details

Third-party links

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