We may collect and process any of the following information:
If you have provided us with the Personal Data of another person (including your employer or a referee), by continuing to use our Website 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 require this Personal Data to understand your needs and provide you with a better service, and in particular for the following purposes:
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 more of the following lawful basis’:
Here is a list of all the ways that we may use your Personal Data, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.
|What we use your Personal Data for||Our Grounds/Reasons||Our Legitimate Interests|
Internal record keeping
To improve our products and services
To customise the Website according to your interests
|Our legitimate interests||Developing products and services and what we charge for them
To provide you with access to your funds and corporate portfolio information
|Periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided
From time to time we may contact you for market research purposes
Our legitimate interests
|Working out which of our products and services may interest you and telling you about them
Defining types of customers for new products or services
|Progressing any employment applications from you
Complying or fulfilling our legal and/or regulatory obligations.
Our legitimate interests
|Compliance with legal and regulatory obligations in the jurisdictions and sectors in which we operate.|
We are committed to ensuring that your information is secure. We protect your information by:
You can protect your data by:
This Website creates a number of cookies, which are referred to as ‘first party cookies’ as they are specific to the host site that created them. All the first-party cookies which are created do not store any personal or sensitive information, or anything that makes you personally identifiable to us. They are used for essential functionality such as security when processing form data or for analytics which helps us use anonymous visitor data to gain a better understanding of how people use our Website.
Third party cookies are cookies created by an external service when you use a page on our Website. These cookies are specific to the third-party's domain and accordingly the data held in them can be seen and managed by the third party and not by us. We control whether or not we use the third-party service with our Website, and how it is integrated and presented on our Website. We do not have control over the cookies themselves. We carefully select third party services to use on our Website; ones that are not likely to abuse your privacy according to the terms of their privacy policies.
This Privacy Notice is governed by and construed in accordance with Isle of Man law. By accessing and using the Website you agree that disputes arising in connection with this Privacy Notice shall be subject to the exclusive jurisdiction of the Isle of Man courts.
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:
You may choose to restrict the collection or use of your Personal Data in the following ways:
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.
You are entitled to access the information held about you. Your right to access the Personal Data which we hold about you can be exercised in accordance with the Isle of Man’s Data Protection Act 2018. In order to assist us in processing your request, please can you contact email@example.com.
We may disclose your Personal Data to any member of our Group.
We may disclose your Personal Data to third parties in the following circumstances:
We will not share your data with third parties for marketing purposes unless we have procured your express consent to do so.
Upon agreeing to this Privacy Notice and opting in to our communications you agree for us to send you marketing and promotional material. This includes both online communications and other communications such as e-mail. If at any time you wish to opt-out you can do so by e-mailing the Data Protection Officer whose contact details are provided below. Opt-out can also be undertaken utilising the link provided on each promotional communication.
When we transfer any part of your Personal Data outside the Isle of Man or adequate jurisdictions (such as the EEA) we will take reasonable steps to ensure that it is treated as securely as it is within the Isle of Man or adequate jurisdictions. These steps include but are not limited to the following:
For the avoidance of doubt, we only transfer your Personal Data within our wider Group of companies who are subjected to the Isle of Man Data Protection Act 2018 (or equivalent legislation such as the EU General Data Protection Regulation). 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 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, contractual obligations, and the expectations and requirements of our customers and website visitors. 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 firstname.lastname@example.org.
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 authority for Suntera Group Limited is the Isle of Man Information Commissioner’s Officer who can be contacted via the following link: www.inforights.im