Privacy Policy

Data protection and privacy

Your privacy is very important to us, and we are committed to protecting your personal data. Our role towards certain personal data may be that we collect certain personal data or process certain personal data that iscontrolled by our clients. Our commitments in both cases can be found in respectively the Privacy Policy.

Therefore, we respect and protect your right to privacy and will process your personal data in accordance with the provisions of the European General Data Protection Regulation (GDPR) and other applicable privacy laws. The GDPR and any other applicable privacy laws apply to this Privacy Policy and anything not specifically mentioned in this notice shall be governed by the GDPR and any other applicable privacy laws.

This Privacy Policy explains how we may use, process and store your personal data.

What kind of personal data do we collect?

Personal data means any information relating to an identified or identifiable natural person. CBFO processes thefollowing types of personal data:

• name, address, email address, telephone number and other contact information
  
• date and place of birth
  
• nationality
• gender
  
• employment details
  
• marital statusa
  
• copies of identity documents (passport, national ID card, driver’s license, employee identification numbers)
  
• source of wealth
  
• utility bill, bank statement
  
• tax residency
  

Please note that the list is not exhaustive and that Carte Blanche Family Office (CBFO) may also collect and processpersonal data to extent this is useful or necessary for the provision of our services.

How does CBFO collect personal data?

CBFO obtains and processes personal data in different ways.

• Personal data provided to CBFO directly
  
  We collect personal data directly from (prospective) clients, business partners and intermediaries for the purposes of entering into a contract or a service agreement and/or to meet certain legal requirements.
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• Personal data obtained from third parties
  
  We also collect and process personal data from publicly accessible sources such as internet, social networks, World-Check or commercial registers. Furthermore we may receive personal data from third parties as part of the service we provide to you or in connection with legal requirements that are applicable to us.
  

How does CBFO use personal data?

The majority of the personal data processed by CBFO is necessary for the performance of a contract to which thedata subject is a party or to comply with the request of the data subject prior to entering into a contract. CBFO alsoprocesses personal data in order to comply with our legal and regulatory obligations.We may furthermore process personal data for the purposes of the legitimate business interests pursued by CBFO. Such legitimate interests include general research and development (including statistical research or as a basis to analyze our current security measures) or to develop and improve our services or to strengthen our relationship with you.

We may provide you with communications or information regarding our service offering which we think will be interesting for you. When we process your personal data for our legitimate business interests, we will consider and balance any potential impact on you and your rights under the relevant data protection and anyother relevant law. Whenever we process personal data for these purposes you have the right to object to this way of processing.

To whom does CBFO provide personal data?

CBFO may disclose or transfer personal data collected by CBFO to our group companies in sofar as reasonably necessary for the purposes of our service offering or for bona fide compliance purposes as well as on the legalbasis as set out in this Privacy Policy.

Except as described in this paragraph, CBFO will not disclose, transfer or sell your personal data to any third party unless you have consented to this.

CBFO may disclose or transfer personal data to subcontractors for the purpose of the proper performance of the services we provide to our clients. It may, for example, disclose or transfer such personal data to third party serviceproviders who provide administrative, computer, payment, data processing, debt collecting or other services. Weenter into data processing agreements with such subcontractors to ensure that they process your data, on ourbehalf, with the same level of security and confidentiality as applied by CBFO. CBFO may furthermore disclose ortransfer personal data when we received your consent to do so.

In addition CBFO may disclose or transfer personal data to protect our rights or those of our clients and/or to prevent fraud. CBFO can also be obliged to disclose or transfer personal data to competent authorities in order tocomply with our legal and/or regulatory obligations.

International transfers and data storage

CBFO may disclose or transfer personal data to other companies of the CBFO group that are located in countries that are outside the European Economic Area in connection with the above purposes.

The personal data CBFO processes is stored by CBFO on our servers, and/or on the servers of the cloud-based database management services CBFO engages.

If disclosure or transfer of personal data is being done in a country that does not ensure an adequate level of protection of your personal data, CBFO will make sure additional safeguards will be put in place.

Retention

CBFO will process and store the relevant personal data for the duration of our services or for the duration of thebusiness relationship. CBFO may also store the data for as long as it is necessary or required in order to fulfill legal,contractual or statutory obligations and, or for the establishment, exercise or defense of legal claims, and ingeneral where it has a legitimate interest for doing so.

Your rights

You have the following rights:

• Access to your information
  You have the right to access the personal information that CBFO holds about you at any time.
  
• Data portability
  You may ask CBFO to provide you with a copy of the personal information that CBFO holds about you.
  
• Correction of your personal information
  You have the right to ask CBFO to update and correct any out-of-date or incorrect personal information thatwe would hold about you.
  
• Deletion of your personal information (the right to be forgotten)
  You have the right to ask CBFO to delete your personal information, to the extent that CBFO has no legaland/or regulatory obligations to keep such personal information.
  
• Restriction of processing of your personal information
  You have the right to ask CBFO to restrict the processing of your personal information in case
  i) You contested the accuracy of the personal information held by CBFO
  ii) The processing is unlawful but you objected to the deletion of the personal data and request the restriction of the use instead
  iii) CBFO no longer needs the personal data for the purposes of the processing, but you require them forlegal reasons
  iv) You objected to processing and CBFO is investigating whether there are legitimate grounds tooverride your objection
  
• Automatic decision making
  CBFO generally does not make decisions by purely automatic means, but if we do, you have the right to object.
  
• Object
  You have the right to object at any time to the processing of your personal data for any direct marketing (andrelated profiling) by CBFO.
  
  If you wish to exercise any of the above rights, you can contact CBFO using the below contact details. In addition you have the right to make a complaint with the local supervisory authority with respect to the way CBFO is processing your personal data or the way CBFO is handling your rights.
  

How we protect personal data?

CBFO is committed to ensuring the security of your personal data. CBFO takes appropriate commercially reasonable technical, physical and organisational measures to prevent unauthorised or unlawful processing of your personal data or accidental loss or destruction of your personal data. CBFO will ensure a level of security suitable to the identified risks and pursuant to applicable Data Protection Laws and, where the Processing concerns personal data of EU residents, shall take measures required pursuant to article 32 GDPR.

Employees of CBFO are trained to handle personal data securely and with utmost respect and they will treat your personal data strictly confidential. Staff members shall be authorized to access personal data only to the extent necessary to serve the applicable legitimate purposes for which the data are processed by CBFO and to perform their job.

CBFO will not divulge client information to a third party unless we have received explicit client authorisation or weare required to do so by law.

Changes to this notice

CBFO may update this Privacy Policy from time to time. We advise you to periodically review this Privacy Policy to be informed of how CBFO is protecting your privacy.