DATA PROTECTION CUSTOMER INFORMATION

FS First Solutions LTD, the data controller, cares about the protection of your personal information.

This statement is intended to inform you in details about the data we treat, when and how we collect them, the purposes for which we treat and communicate the data, how long we store them, what are your rights at this regard and how you can exercise them.

  1. WHAT PERSONAL DATA DO WE TREAT

We may collect various categories of personal data, including:

  • Contact information (e.g. email and address);
  • Identification data (e.g. name, surname, identity document and passport number, nationality, place and date of birth, sex, photo, IP address);

We never ask for personal data relating to your health, racial or ethnic origin, political opinions, religious or philosophical beliefs, membership of trade unions, genetic data or data concerning your sexual orientation.

  1. WHEN AND HOW WE COLLECT YOUR PERSONAL INFORMATION

We may collect your personal information by requesting it directly at the time of the entrance into relationship with you, to illustrate and sell you our services, or if you require us to access the services Information we provide, such as the Newsletters.

We could also indirectly collect information about you, such as when your employer gives us your information or one of our customers gives us your contact details, for example, if you are:

  • family member;
  • legal representative;
  • beneficial owner;
  • company's stakeholders;
  • legal entities representative;
  • staff of service providers or business partners;
  • staff of supervisory authorities.

If necessary, we can carry out customer profiling activities exclusively to fulfil legal obligations, in particular to comply with the financial regulations and for antimoney laundering and anti terrorism purposes.

  1. WHY AND ON WHAT LEGAL BASIS WE TREAT YOUR PERSONAL INFORMATION

To run our services

We treat your data to run our services. In particular, to:

  • Provide you with information about our products and services;
  • Provide assistance and respond to your requests.

To fulfil legal obligations, regulations and authorities’ orders

We treat your personal data to comply with various legal and regulatory obligations:

  • To fulfil financial regulations or, where appropriate, to prevent money laundering and terrorist financing;
  • To respond to an official request from a public or judicial authority in the cases provided by law;
  • To conform to the Privacy authority’s principles regarding the procession of personal data.

To satisfy a legitimate interest of the company

We treat your personal data in order to implement and develop our products or services and to defend our rights, including:

  • IT management;
  • Promote products or services, similar or complementary to those you have already purchased.

Specific treatments requiring your consent

In some cases, we must ask for your consent to treat your data, such as for the promotion of our products and services which you have not yet joined.

  1. WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

To meet the purposes mentioned above, we only communicate your personal information to:

  • Independent agents, intermediaries or brokers, banking and commercial partners with whom we have a regular relationship;
  • Financial or judicial authorities, state agencies or public bodies as required and where permitted or required by law;
  • Professionals (e.g. lawyers, notary Public, auditors, consultants) with whom we have a regular professional relationship.
  1. TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

In case of international transfers from the European Economic Area (EEA), where the European Commission has acknowledged a non-EEA country with an adequate level of data protection, personal data will be transferred according to this.

For transfers to non-EEA countries whose level of protection has not been recognised by the European Commission, we will rely on a derogation applicable to the specific situation (e.g. if the transfer is necessary to carry out our relationship with you) or if we have implemented the standard contractual clauses approved by the European Commission.

  1. HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?

Unless the law imposes specific conservation requirements, we retain your personal data for the entire duration of the relationship and for a further period of 10 years from the termination of the report, if we are referring to data for which a specific preservation is required or to carry out tasks you have arranged/requested or to satisfy our legitimate interest.

With reference to the data functional to the establishment of the relationship, where an agreement is not reached, the above data will be kept for a maximum period of 12 months, in order to allow us to be able to respond to your specific requests, if any.

We will treat your personal information for marketing purposes until we have your consent, except in the case where specific regulatory requirements intervene.

  1. YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM

In accordance with the current regulations, in relation to the processing of personal data we put in place, you have the following rights:

  • Access: You can obtain information about the processing of your personal data and its copy;
  • Rectification: If you believe that your personal information is inaccurate, outdated or incomplete, you may request that such personal data will be corrected or integrated;
  • Oblìo: You may request the deletion of your personal information, if reasons provided by law are fulfilled;
  • Limitation: You may request the limitation of the processing of your personal data;
  • Opposition: You may oppose the processing of your personal data on the basis of our legitimate interest, for reasons relating to your particular situation. You may also oppose the processing of personal data for direct marketing purposes;
  • Data portability: You have the right to receive or obtain the direct transmission of your data to another holder (if technically possible);
  • Revocation: You may revoke your consent for the processing of your personal data at any time.

For the exercise of the foregoing rights you may send a written notice to info@1solution-advisory.com.

You finally have the right to file a complaint with the guarantor.

  1. CONTACT DETAILS

You can contact us through e-mail at info@1solution-advisory.com, or via post to  FS First Solutions Ltd, 32 Ludgate Hill, EC4M 7DR London, United Kingdom