Real Substance Fiduciary Services Ltd is committed to safeguarding the privacy of its website visitors. Therefore, this policy sets out how we treat the set of personal information and data related to the individual visitors of our website. This policy is in accordance and compliance with the requirements of the Data Protection regulation 679/2016/EU, which comes into effect as of the 25th of May 2018. The content of this policy applies to all visitors of website that are located within the member states and associated countries of the European Union (EU), regardless of their status (general visitor or customer of Real Substance Fiduciary Services Ltd).
In compliance with the requirements of the Data Protection regulation 679/2016/EU, Real Substance Fiduciary Services Ltd has appointed a Data Protection Officer (DPO). This DPO has a direct connection to the top level management of Real Substance Fiduciary Services Ltd and remains independent within the corporate structure of Real Substance Fiduciary Services Ltd. The DPO can be contacted by electronic mail services at this address [email protected]
(1) What information is collected from the website visitors?
Real Substance Fiduciary Services Ltd collects and processes personal data related to individual visitors of our group companies’ websites and fills in the role of the Data Controller for this specific set of information. Personal data collected by third parties that remain legally and economically independent from Real Substance Fiduciary Services Ltd do not fall within the scope of this definition. Please refer to point (2) on cookies for further information. During the course of your visit to our website, the following types of personal data is collected:
(b) In the course of using the contact form provided in the ”Contact us”-section, Real Substance Fiduciary Services Ltd obtains personal information relating to an individual website visitor.
(c) For the purpose of subscribing to our website services, email notifications and/or newsletters Real Substance Fiduciary Services Ltd may obtain personal information and data related to the individual website visitor.
(d) any other information that a website visitor chooses to send to us.
(f) Finally, telephone calls may be recorded for training and monitoring purposes.
The web server, which hosts the website of Real Substance Fiduciary Services Ltd may send such a cookie file to a website visitor’s computer during the visit of our website, which may be stored on by your browser on your computer’s hard drive. Real Substance Fiduciary Services Ltd may use the information obtained from the cookie file for the purpose of administration of our website and for the purpose to improve the usability of that website.
Most browsers allow website visitors to refuse the acceptance of cookie files. (For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector.) This will, however, have a negative impact upon the usability of many websites.
The Google Corporation offers tools for the commercial advertising and promotion of goods and services on websites, which are Google AdWords and Google AdSense. Both use a so-called Double-Dart-Cookie file. It is the same type of text file as described above in here. In case a website visitor deactivates the acceptance of cookies in the web browser used for the visit of a website, the advertising tools of the Google Corporation may appear disfunctional on that website. The Google Corporation fills in the role of the Data Controller for all personal data collected by the services and website tools provided by the Google Corporation during your visit of the website of Real Substance Fiduciary Services Ltd. This paragraph applies mutatis mutandis to any other external, legally and economically independent third party provider of electronic commercial advertising and promotion services.
(3) Using and processing of your personal data
We may use your personal information to:
(a) administrate the website of Real Substance Fiduciary Services Ltd and for internal statistical prupose.
(b) improve the browsing experience for the visitors of our website by personalising the website.
(c) enable the use of the services available on our website.
(d) send out general (non-marketing) commercial communications to individuals that have submitted their personal data in the course of their visit on our website.
(e) send out email notifications and / or newsletters to individuals that have submitted their personal data accordingly in the course of their visit on our website, under the condition that the person to which the submitted personal data is related had specifically requested this service and submitted a trackable explicit consent to this.
(f) process the cancellation of services and the unsubscription for newsletters or other commercial and non-commercial notifications in accordance with the written request of the individual, to which the personal data is related. A written request can be sent to the Data Protection Officer by electronic mail services to [email protected]
(g) process enquiries and complaints made by an individual to which the personal data collected and stored during the course of a visit on our website is related.
(h) OTHER USES: Real Substance Fiduciary Services Ltd does not disclose any personal information related to visitors of our website to any third parties for the purpose of direct marketing, unless the person to which this personal data is related gives his/her explicit and trackable consent to this action.
(4) Other disclosures
Notwithstanding the above, a disclosure of personal data related to individual visitors of our website to third parties is permitted only in cases where the disclosure concerns matters of national and/or international security, the prevention or investigation of criminal activities, law enforcements, where a public interest is given, a juridical proceeding against the person, to which the personal data is related is pending or had been initiated or completed before and/or the personal security of the individual to which the personal data is related.
(5) Security of your personal data
Real Substance Fiduciary Services Ltd is taking the responsibility for the use of reasonable technical and organisational precautions to prevent the loss, misuse or alteration of any personal information or data related to the individual visitors of our website.
(6) Policy amendments
(7) Rights to your individual and personal data / information
Upon submission of a written request by electronic mail services to the appointed Data Protection Officer (DPO) at Real Substance Fiduciary Services Ltd ([email protected]), you as an individual visitor of our website retain the rights to:
(a) request a review of your personal data and information which was obtained and stored during your website visit and check the accuracy of these information at any time.
(b) request a rectification and change being made to your personal data and information, which was obtained in the course of your website visit.
(c) request information on the purpose for which your personal data that was obtained during your website visit, is used.
(d) request to have your personal data, which was obtained during your website visit, deleted partly or completely.
(e) effect a restriction on the purpose for the use of your personal data, which was obtained during your website visit.
(f) withdraw at any time your previously submitted and trackable explicit consent for the collection and use of your personal data and information related to you as an individual website visitor.
(g) the transfer of your personal data to another Data Controller nominated by you.
(8) Third party websites
The website may contain links to other websites. Real Substance Fiduciary Services Ltd is not responsible in any way for the privacy policies, content or practices of third party websites.