Privacy Policy

 

INTRODUCTION

SAGEConsult (“we” or “our”) is committed to respecting your privacy. We acknowledge the importance of your personal information and preserving your right to privacy.

 

SAGECONSULT

SAGEConsult is the trading name of SAGEConsult Ltd and SRVS FZE. SAGEConsult Ltd is the data controller for SAGEConsult Ltd (“SAGEConsult”). This means that SAGEConsult determines what personal information is collected by SAGEConsult, how this personal information is going to be used and how this personal information is protected.

The website “sageconsult.com” is within the scope of this Privacy Policy. This website is considered to be a UK based website.

 

SCOPE OF OUR PRIVACY POLICY

This Privacy Policy applies to anyone who interacts with us about our services in any way (for example, by email, through our website, by telephone). We may provide you with further privacy information or notices if necessary for specific services we carry out.

 

This Privacy Policy describes how we collect, use and disclose your personal information, and your rights in relation to the personal information we hold, in accordance with relevant data protection laws and regulations applicable to your jurisdiction, such as the retained EU law version of the General Data Protection Regulation ((EU) 2016/679). (“UK GDPR”). Please read this Privacy Policy carefully.

 

This Privacy Policy was last updated on 17 June 2021 (“the Effective Date”). This Privacy Notice supersedes any previous Privacy Notice or equivalent which you may have been provided with or seen prior to the Effective Date stated above.

To the extent that we are a data controller, each of our entities is a joint data controller of your personal information.

 

YOUR LEGAL RIGHTS

If you are based within the UK, you have the following rights which you can exercise under certain circumstances in relation to your personal information that we hold:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Please note that the above rights are non-exhaustive.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

LAWFUL BASIS FOR COLLECTION AND USE OF PERSONAL INFORMATION

By law, we must have a lawful reason for processing your personal information. We process standard personal information about you if this is for a Legitimate Interest, Performance of Contract or to Comply with a legal obligation, in each case as defined below:

 

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

 

SHARING YOUR PERSONAL INFORMATION

We may share your personal information with or transfer it to the following:

  • Third parties whom we engage to assist in delivering the services to you, including our clients with whom you have an agreement to receive services from;
  • Your agents, advisers and other intermediaries;
  • Our professional advisers where it is necessary for us to obtain their advice or assistance, including solicitors, accountants or other advisers;
  • Other third parties such as intermediaries who we may introduce to you; and
  • Our data storage providers.

 

TRANSFERRING INFORMATION OUTSIDE THE UNITED KINGDOM (“UK”)

We may transfer your personal information to countries outside the UK for the purposes set out in this Privacy Policy. Not all countries outside the UK have data protection laws that are similar to those in the UK and may not have the same level of data protection.

We take steps to make sure that, when we transfer your personal information to another country, appropriate protection is in place, in line with UK laws and other applicable laws and regulations on data protection.

 

HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information from you and from third parties (anyone acting on your behalf) any in a number of ways. Please see below for more information.

Where you provide us with information about other individuals, you must make sure that they have seen a copy of this Privacy Policy and are comfortable with you giving us their information.

We collect personal information from you:

  • through your contact with us, including by telephone, by email, through our website, by post, by filling in forms (such as client on-boarding, due diligence or other forms), through social media or face-to-face; and
  • we also collect information from other people and organisations, for example our clients, solicitors, translators, regulators, your agents, your advisers, publicly available sources or third parties (where we conduct background screening checks), company service providers and/or other intermediaries.

 

CATEGORIES OF PERSONAL INFORMATION

SAGEConsult collects and processes the following categories of personal information about you as part of performing its services:

  • name, gender, date of birth and contact details of your home and business (telephone, email address, mobile telephone number, fax number, address);
  • tax identification number, passport number or national identity card details, country of domicile and/or nationality;
  • financial circumstances, e.g. income, expenditure, assets and liabilities, sources of wealth, as well as your bank account details;
  • your knowledge and experience in financial services and investments; and
  • occupation/employment, education, family or personal circumstances.

This personal information includes, among others, data on clients, employees, suppliers and other individuals on whom we are asked to provide our services.

 

RETENTION OF PERSONAL INFORMATION

We will only retain your personal information for the length of time required for the specific purpose or purposes for which it was collected. In particular:

We may be obliged to store some personal information for a longer time, taking into account factors including:

  • legal obligation(s) under applicable law to retain information for a certain period of time;
  • statute of limitations under applicable law(s);
  • (potential) disputes; and
  • guidelines issued by relevant data protection authorities.

 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

 

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

COOKIES

Our website uses cookies, which is a small data file that is downloaded to your device when you access our website. Cookies are used to help to make your experience of using a website better.

 

Almost all websites use cookies. Cookies do not carry viruses and cannot install malware and do not store any personal information about you.

 

Our website uses Google Analytics which gathers cookies to help improve the performance and to gather website analytics. We sometimes use cookies in our emails to track performance indicators so that we can continually improve our services to you.

If you do not wish to accept cookies, you can change your browser settings so that cookies are not accepted. Should you decide to block all cookies from our website then you may not be able to use the website to its full functionality.

 

DATA PROTECTION CONTACT

If you have any questions about how we use your personal information, or you wish to exercise any of the rights set out above, please contact:

 

The Data Protection Officer
SAGEConsult Ltd
71-75 Shelton Street,
Covent Garden, London,
WC2H 9JQ
United Kingdom
+44 (0) 7933 267872
admin@sageconsult.com