HubSpot Privacy Notice

This Privacy Notice sets out how Suntera Group Limited (and its global subsidiaries) (hereinafter to be referred to as "Suntera", “we”, “us” or “our”) uses and protects any information customers, event attendees, employment candidates or website enquiries give to us relating to our products and services.

The data controller is Suntera Group Limited and depending on who and where you gave your information to, the data controller could also be:

Suntera Group Limited
Suntera (IOM) Limited
Suntera Fund Services (IOM) Limited
Suntera Accounting & Tax Limited
Suntera Training Limited
Suntera Digital Limited 
Suntera Forensics Limited

Peveril Buildings, Peveril Square, Douglas, Isle of Man, IM99 1RZ

Amber (Isle of Man) Limited
Advennt Limited

3rd Floor, Peveril Buildings, Peveril Square, Douglas, Isle of Man, IM99 1RZ 

Suntera (Bahamas) Limited

#9 Pineapple House, Western Road, Lyford Cay, P.O. Box SP64274, New Providence, Bahamas

Suntera (Cayman) Limited

Suite 3204, Unit 2A, Block 3, Building D, P.O. Box 1586, Gardenia Court, 49 Market Street, Camana Bay, KY1 – 1100, Cayman Islands

Carey Commercial Limited

Elizabeth House 1st and 2nd Floors, Elizabeth House, Les Ruettes Brayes, GY1 4LX, Guernsey, Channel Islands

Suntera Private Wealth (Guernsey) Limited

Fairbairn House, PO Box 192, Rohais, St Peter Port, Guernsey, GY1 3LT 

Suntera (Hong Kong) Limited

18th Floor, On Building, 162 Queens Road Central, Central, Hong Kong

Suntera Trust & Corporate (Jersey) Limited
Suntera Fund Services (Jersey) Limited

13 Castle Street, St. Helier, Jersey JE2 3BT, Channel Islands

Suntera (Luxembourg) Holding S.à.r.l

12, rue Guillaume Schneider, L-2522 Luxembourg

Suntera (UK) Limited

Suntera Services (UK) Limited

Suite 121, Viglen House, Alperton Lane, Wembley, United Kingdom, HA0 1HD

Socium, LLC

830 Morris Turnpike Suite 309 Short Hills, NJ 07078

• We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified during your dealings with us you can be assured that it will only be used in accordance with this Privacy Notice.
• We may change this Privacy Notice from time to time. You should check this document regularly to ensure that you are happy with any changes.

• Personal Data means any information that can identify, directly or indirectly, a living individual.
• Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data. For the purpose of this Privacy Notice, Suntera is the Controller.
• Processing means any operation or set of operations which is performed on Personal Data or on sets of Personal Data.

We may collect and process any of the following information:

• Your name, title and/or date of birth;
• Your contact information including your email address, home address, delivery address telephone number and/or mobile number;
• Your demographic information such as postcode and/or country;
• Your job title, job function, industry, company name;
• Your company contact information including office address, work email address and/or office phone number;
• Images, Audio and video recordings;
• Your marketing and communication preferences and/or interests relating to our products and service offering this includes: your services/ solutions of interest, industry sector/ sectors of interest, your interest in attending an event hosted by us, interest in receiving newsletter communications from us.
• Your other information relevant to customer surveys and/or offers;
• Your information that you provide to us when you use the Website including how you heard about us.
• Your employment history including whether you have the right to work in the advertised role location and information contained within your CV (such as education and referees information) if you use our website to apply for a Job with us.
• Your dietary requirements when attending an event hosted by us.
• We may ask for your sporting handicap when we host a sporting event such as your golf handicap.
• Your IP address used at the time of access.

If you have provided us with the Personal Data of another person (including any employer or a referee), by continuing to engage with us you hereby warrant that they consent to the processing of their Personal Data and that you have informed them of our identity as a Controller and provided them with a copy of this Privacy Notice.

If you are applying for a job with us, we might ask you to participate in aptitude tests and/or to attend an interview – or a combination of both. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information will be held by Suntera Group Limited, or whichever of our subsidiaries to which you directly applied.

We collect your Personal Data using some or all of the methods listed below:

• Individual themselves (either in person, over the phone, or through our website).
• Third party individual

Other sources – For example:

• Internet/social media
  • LinkedIn
  • Facebook
  • Twitter
  • Instagram
• Service and/ or platform providers such as:
  • Eventbrite
• Government departments/agencies

Where we are engaged in a media or industry partnership, we may be contracted to receive contact information of leads generated or attendees from an event the partner is hosting or marketing promotion we have featured and/or we are a named sponsor or partner.

We require this Personal Data to understand your needs and provide you with a better service, and in particular for the following purposes:

Record keeping:

• Our internal record keeping of our dealings with you.

To deliver our products and services:

• To provide you with access to our online client portal (if available) if you become a client of ours
• To deliver of content, you may have signed up for including a training course, workshop, demo or webinar
• We may track engagement activity through HubSpot for communications via Outlook and/or Microsoft Teams relating to a provision of service.

To improve our products and services:

• For quality assurance purposes, market research may be conducted via surveys and data research projects to help improve the quality of our product and service offering.

Marketing:

• To periodically send promotional emails about new products, special offers or other information which we think you may be interested (and seasonal pleasantries) in using the email address which you have provided and/ or on the basis you have consented to receive such communications from us.
• To showcase our latest product and service updates through emails such as newsletters and event invitations.

Events:

Registration details are required to confirm your place at an event we are hosting. These details may also be used to invite you to future events which we think that you may be interested in attending.

Customer Engagement:

• Marketing community and engagement tools that require the collection of data may be used to engage with you such as HubSpot Chatbot and LinkedIn or Facebook Events.

Recruitment:

• To process and consider any applications for employment with us.

Analytics:

• We monitor and track customer interactions through data analytics to help inform and customise our Website according to your interests and/ or to improve your user experience.

Competitions:

• We may require your information to administer competitions or prize draws that we are running and to deliver a prize if you have won via digitally or via direct mail.

Under laws which are designed to protect your Personal Data, we need to have what is a called a ‘lawful basis’ or ‘ground’ each time we use, share or otherwise process your Personal Data.

We may rely on one or both of the following legal basis’:

• If you have agreed (provided your consent) to us processing your Personal Data for the relevant purpose, we shall be relying upon that consent; and/or
• Our legitimate interests in the effective delivery of information and any future or current services to you. If you would like further information about our legitimate interests, please do not hesitate to contact us.

We are committed to ensuring that your information is secure. We protect your information by:

• Offering you a secure transmission method to send us personal or company information;
• Only share it with staff members and/or third parties who need to access it; and
• Implementing suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

You can protect your data by enabling security features on your browser if you share your personal data through electronic means.

You have certain rights in relation to your Personal Data. Pursuant to the applicable data protection laws, those rights will not necessarily apply in all cases or to all Personal Data which is processed by us. You have the right to request that we:

• Provide you with access to any Personal Data which we hold about you (please refer to ‘Request of Personal Information’ below);
• Update any of your Personal Data which is out of date or incorrect;
• Delete (in some circumstances) any Personal Data which we hold about you, subject to regulatory compliance which requires certain information to be kept for a defined period of time;
• Restrict (in some circumstances) the way that we process your Personal Data;
• For us to consider any valid objections which you have to our use of your Personal Data; and/or
• Provide some of your Personal Data to a specified third party provider of services (data portability) at your request in appropriate circumstances.

You may choose to restrict the collection or use of your Personal Data in the following ways:

• If you have been asked to fill in a form on our website, you can choose to call instead;
• If you have previously agreed to us using your Personal Data for direct marketing purposes (i.e. you provided us with your consent), you may change your mind at any time by writing to or emailing us at the below email address confirming that you wish to withdraw your consent; and/or
• If you would like access to the information held about you please write to Data Protection Officer, Suntera Group Limited, Peveril Buildings, Peveril Square, Douglas, Isle of Man, IM99 1RZ or send an email to dataprotection@suntera.com. 

Should you require an update or amendment to your Personal Data, please contact us by email using the details below and we shall endeavour to amend your records as soon as is practical and no later than 7 days of receipt of any update.

We may disclose your Personal Data to any member of our wider global Group of companies, but only to fulfill the purposes detailed above.

We may also share your Personal Data with any of the following:

• Legal and professional advisers to Suntera Group Limited and global Group companies
• Third party suppliers who are bound by Non-Disclosure Agreements such as The Beach Limited and Launchpad Creative LLC;
• Referrals or introductions internal to the Suntera Group (shared upon consent only)
• Referrals or introductions to external parties (this includes clients and intermediaries of Suntera Group Limited and intergroup companies) (shared upon consent only)

Outside of that, we may disclose your Personal Data to third parties in the following circumstances:

• If we, or substantially all of our assets are acquired by a third party, in which case Personal Data held about our contacts will be one of the transferred assets;
• If we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation;
• In order to enforce or apply the terms of this Privacy Notice or any other agreements;
• To protect the rights, property or safety of us, our customers or others; and/or
• Where we have received your permission for us to do so.

 We will not share your data with third parties for marketing purposes unless we have procured your express consent to do so.

Upon reading this Privacy Notice and consenting to receive our communications you agree for us to send you marketing and promotional material as detailed above in this Privacy Notice. This includes both online communications and other communications. If at any time you wish to opt-out and remove your consent you can do so by e-mailing the Data Protection Officer whose contact details are provided in this Privacy Notice. Opt-out and consent withdrawal can also be undertaken utilising the link provided on each promotional communication.

When sharing your Personal Data with our global Group companies or any foreign third parties we will take reasonable steps to ensure that it is treated as securely as it is within the source jurisdiction. These steps include but are not limited to the following:

• Binding corporate rules;
• Model contracts; or
• Any other method deemed appropriate by the applicable Data Protection legislation, or the European GDPR.

For the avoidance of doubt, we only transfer your Personal Data within our wider Group of companies who are subjected to the EU General Data Protection Regulation or equivalent standard legislation. Any further international transfers will be not be undertaken unless we have procured your express consent.

Our Website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Notice. You should exercise caution and look at the privacy statements applicable to the website in question.

We will retain Personal Data for as long as we reasonably require it for legal or business purposes. In determining data retention periods, we take into consideration local laws, any applicable contractual obligations, and the expectations and requirements of our contacts. When we no longer need Personal Data, we securely delete or destroy it.

If you have applied for employment with us and were unsuccessful for the position you have applied for, we may ask if you would like your details to be retained in our talent pool for a period of six months. If you say yes, we would proactively contact you should any further suitable vacancies arise. 

If you have any questions, comments or requests regarding the protection of your Personal Data please contact the Data Protection Officer by email on dataprotection@suntera.com or you can write to any of our data controllers using the addresses provided in section 1 (Introduction) of this Privacy Notice.

If you are not satisfied with the above or the way we process your Personal Data you have the right to make a complaint. We hope that you will raise any complaints or concerns with us in the first instance, but if not, or if you are not satisfied with our initial response, you can contact our supervisory authority for data protection related matters using the contact details below:

The supervisory authorities for the Suntera Global Group of companies are:

THE BAHAMAS

 

CAYMAN ISLANDS