Last modified: February 2020
We are committed to protecting and respecting your privacy.
Our privacy practices may vary among the different countries in which we operate, to reflect local practices and legal requirements (“Applicable Data Protection Laws”). In most cases this will be the law of the country in which you are located.
Please note that the Services may contain links to other websites, digital platforms or internet resources which may collect personal data voluntarily or through cookies or other technologies. We have no responsibility, liability for, or control over those other websites or Internet resources or their collection, use and disclosure of your personal data and thus recommend you to review the privacy policies of those other websites and internet resources to understand how they collect and use personal data.
According to Applicable Data Protection Laws, you may be entitled to know the identity of your “Data Controller” i.e., the legal entity which determines why and how your personal data is processed.
Your relevant Data Controller may vary, depending on how you are receiving Services from us. For example:
- As Expatriate spouse and companion
- As Expatriate spouse and companion
- If you are engaging us directly
to provide services for you, then your relevant Data Controller is likely to be that particular entity which is providing those services to you and processing your personal data and named in any relevant correspondence with you.
- If you are providing consultancy services to us, then your relevant Data Controller is likely to be that entity with whom you have concluded your agreement.
We process three categories of personal data in using our Services or communicating with us:
3.1 Given information.
Information you give us by filling in forms on our website or other digital assets or by corresponding with us by phone, email or otherwise. It may include without limitation your personal contact details, nationality, country of residence, marital status, age, occupation, employment history, and/ or your business information such as business
plan, concept description and other relevant or related details. Unless explicitly authorised by you, we commit not to share any sensitive data, as further defined.
3.2 Collected information. We may collect certain information by using automated means, such as cookies, when you visit our website. This information may include your IP address, browser type, operating system, the full URLs, referring URLs and information on actions taken or interaction with our digital assets. We may use third-party web analytics services on our websites and other digital assets, to help us analyse how visitors use our website and other digital assets.
A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.
IP addresses are used by your computer every time you are connected to the Internet.
Your IP address is a number that is used by computers on the network to identify your computer. IP addresses are automatically collected by our web server as part of demographic and profile data known as “traffic data” so that data (such as the Web pages you request) can be sent to you.
We use Google Analytics to collect data about demographics of the people who access this website. If you do not want your information collected, Google provides you with a browser add on, which you can download here: https://tools.google.com/dlpage/gaoptout.
3.3 Information received from third parties.
We are working closely with third parties (including for example, your employer, business partners and consultants and may receive information about you from them).
The processing of personal data under points 3.1 & 3.3 are necessary for the performance of the Services we are providing to either its corporate or private client. The processing of personal data identified under point 3.2 is necessary for our legitimate interests in order to deliver and improve its Services.
Purpose of the Processing
When acting as Data Controller, we will process these data for the following purposes:
- to provide its corporate or private clients with the Services (as applicable);
- to administer, operate, facilitate and manage its clients’ relationship and/ or account;
- to provide you, or permit selected third parties to provide you with information, recommendations or advice concerning our offers, promotions, products and services;
- to notify you about changes to the Services;
- to operate, evaluate and improve our business (including developing new products and services, troubleshooting, data analysis, testing and research and statistical and survey purposes); managing our communications; determining the effectiveness of and optimising our advertising; analysing our products, services, websites, mobile applications and any other digital assets; facilitating the functionality of our websites, mobile applications and any other digital assets; to ensure the content of our website is presented in the most effective manner for you and for your computer; and performing
accounting, auditing and billing activities;
- as may be required by applicable laws and regulations or requested by any relevant judicial process or governmental agency; and
- to comply with industry standards and our policies.
Under Applicable Data Protection Law, you may have certain rights regarding the personal data we maintain about you. We also offer you certain choices about what personal data we collect from you, how we use that data, and how we communicate with you.
You can choose not to provide personal data to us. You may also refrain from submitting data directly to us. However, if you do not provide your personal data when requested, or if you exercise your rights, you may not be able to benefit from the Services (as applicable), and we may not be able to provide you with information about Services.
To the extent provided by Applicable Data Protection Law, you may withdraw any consent you previously provided to us, or object at any time to the processing of your personal data. We will apply your preferences going forward. In some circumstances, withdrawing your consent to our use or disclosure of your personal data will mean that you cannot take advantage of certain Services. In addition, you may have the right to: request access to and receive information about the personal data we maintain about you, receive copies of the personal data we maintain about you, update and correct inaccuracies in your personal data, object to the processing of your personal data, and have the information blocked, anonymised or deleted, as appropriate. You may also have a right to data portability, which implies that We can supply (at your request) your data to you and/ or to a third party in a structured and machine-readable form.
To exercise these rights, please contact us at email@example.com
The rights above are likely to apply to you if you are based in the European Economic Area and may be limited in some circumstances by local law requirements including Applicable Data Protection Law. The rights can be exercised free of charge unless the requests are manifestly unfounded or excessive. In the latter cases, we can either charge a reasonable fee or refuse the requested action.
We will ensure that for its marketing activities it will comply with the applicable legislation (including the Applicable Data Protection Laws) and that it will obtain, where required, the necessary consents before the User receives any emails or other electronic communication from us. You can demand at any time to stop the sending of such information by clicking
on the unsubscribe button in the received electronic communication.
Disclosure of Personal Data
Although we may transfer personal data to so-called business partners and consultants for the performance of the Services (as applicable) or any other contract we enter into with them or you, we will not share data with third parties for secondary or unrelated purposes unless otherwise stated when collecting these data.
If we get involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes.
Where appropriate or required, we will be entitled to transmit personal data to law enforcement authorities, regulatory or other government agencies, or third parties where necessary or desirable to comply with legal or regulatory obligations or in the context of the above mentioned purposes.
One or more of the above may be located outside of the EEA. Where applicable, your personal information will be processed in compliance with section 7.
We do not store the data longer than legally admissible and in any case not longer than required for the purposes for which it was collected.
International Data Transfers
Security of Data
The security of personal data is important to us. We shall take all reasonable and appropriate technical and organisational measures to protect the security, confidentiality and integrity of personal data.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or other digital assets, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not without any risks. The User consequently acknowledges that we cannot guarantee the security of her/ his personal data to our website or other digital assets (such as our applications, tools); any transmission is at your own risk. We will however do our best to protect your personal data once we have received it and will use strict procedures and security features to try to prevent any unauthorised access.