about team services trusts offshore companies news contact pay online PRIVACY POLICY PURPOSE OF THIS PRIVACY POLICY This privacy policy aims to give you information on how Aston International Limited (“Aston”) collects and processes your personal data through your use of this website, including any data you may provide through this website and when you purchase a product or service or communicate with us generally. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them WHAT DATA DO WE COLLECT? Aston collects the following data: Identity Data includes names, date of birth, gender, nationality, passport/identity number, tax identification number Contact Data includes address, email address, telephone numbers Financial Data includes bank account, payment card details. Transaction Data includes details of payments between us Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. Usage Data includes information about how you use our website, products and services. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. HOW DO WE COLLECT YOUR DATA? You directly provide Aston with most of the data we collect. We collect data and process data when you: Register online or apply for any of our products or services. Pay for any of our products or services. Voluntarily complete a customer survey or provide feedback via our website or by email. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Data obtained from third parties: Not all the personal data we hold about you will always come directly from you. We may also collect data from third parties such as service providers and publicly available websites to identify and know our customers to comply with our legal and regulatory obligations. HOW WILL WE USE YOUR DATA? We will only use your personal data when the law allows us to and where it is necessary for our legitimate interests, and your interests and fundamental rights do not override those interests. Most commonly, we will use your personal data in the following circumstances: Where we need to perform the contract or services we are about to enter into or have entered into with you. Where it is necessary for our legitimate interests (or those of a third party) and it is not disproportionate to your interests and fundamental rights. Where we need to comply with a legal or regulatory obligation. We have set out below a description of the ways we use your personal data, and which of the legal bases we rely on to do so. Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To register you as a customer – Identity – Contact – Performance of a contract with you To provide services, including: – Manage payments, fees and charges – Collect and recover money owed to us – Identity – Contact – Financial – Transaction – Marketing and Communications – Performance of a contract with you – Necessary for our legitimate interests (to recover debts owed to us) To manage our relationship with you which will include: – Notifying you about changes to our terms or privacy policy – Identity – Contact – Marketing and Communications – Performance of a contract with you – Necessary to comply with a legal obligation – Necessary for our legitimate interests (to keep our records updated) To administer our business and to protect this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) – Identity – Contact – Technical – Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud) – Necessary to comply with a legal obligation To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you – Identity – Contact – Profile – Usage – Marketing and Communications – Technical – Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) To use data analytics to improve our website, products/services, marketing, customer relationships and experiences – Technical – Usage – Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy) Please note that Aston does not undertake automated individual decision-making or profiling. DISCLOSURES OF YOUR PERSONAL DATA We may share your personal data with the parties set out below for the purposes set out in the table above. External Third Parties: Service providers acting as processors based in the Isle of Man, United Kingdom or EEA who provide IT and system administration services. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the Isle of Man, United Kingdom or EEA who provide consultancy, banking, legal, insurance and accounting services. Regulators and other authorities acting as processors or joint controllers based in the Isle of Man who require reporting of processing activities in certain circumstances. DATA SECURITY Aston recognises that online security and data protection is an area of vital importance for all of our clients, it is important to us that you have confidence in the security of your personal data when doing business with us. Aston are committed to employing security measures to protect your data from access by unauthorised persons and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration and damage. Our technological security solutions are robust and are governed by a mature framework. Our approach is focused on preventing risks. Please note that communication via the internet is not completely secure. We cannot guarantee the security of any data that you transmit using your internet connection. You accept the inherent security implications of using the internet and we will accept no liability for any direct, consequential, incidental, indirect, or punitive losses or damages arising out of such an occurrence. Aston 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. DATA RETENTION Aston will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, Aston considers 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. MARKETING Aston would like to send you information about products and services of ours that we think you might like. If you have agreed to receive marketing, you may always opt out at a later date. You have the right at any time to stop Aston from contacting you for marketing purposes or giving your data to other members of the Aston Group. If you no longer wish to be contacted for marketing purposes, please email us at: newbusiness@aston.co.im WHAT ARE YOUR DATA PROTECTION RIGHTS? Aston would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following: The right to access – You have the right to request a copy of the personal data we hold on you. The right to rectification – You have the right to request that Aston correct any information you believe is inaccurate. You also have the right to request Aston to complete the information you believe is incomplete. The right to erasure – You have the right to request that Aston erase your personal data, under certain conditions. The right to restrict processing – You have the right to request that Aston restrict the processing of your personal data, under certain conditions. The right to data portability – You have the right to request that Aston transfer the data that we have collected to another organization, or directly to you, under certain conditions. The right to object to processing – You have the right to object to Aston’s processing of your personal data, under certain conditions. If you make a request we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We have one month to respond to a request under normal circumstances. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In such a case we will notify you and keep you updated. COOKIES Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our website, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org. How do we use cookies? Aston uses cookies in a range of ways to improve your experience on our website, including: Keeping you signed in Understanding how you use our website Payment processing What types of cookies do we use? There many different types of cookies, however our website uses the following: Functionality – Aston uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used. Advertising – Aston uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Aston sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website. Google Analytics – To understand how people use our site, and to discover areas on our site with issues, we use Google Analytics. Most websites use some sort of analytics program like this. The data it collects helps us understand how many people visit our site, which country they are from, how many pages they visited, how fast our site loaded etc. All data collected is completely anonymous, it does not identify you as an individual in any way. WordPress – WordPress is the Content Management System (CMS) that runs this website. It uses a cookie when logging in and out and is essential for proper website function. It is only set if you are a registered user, so for most people, it is not set at all. User data is all anonymous. Worldpay – Passes the information entered in our online payment form to Worldpay’s website for secure processing. Social Media – When you share items from our website using social media, for example to Facebook, the social media company will drop cookies and identifiers to track this. Cookie Footer – In the footer of each web page on this site, you will see a message alerting you of our privacy and cookie policy. If you’ve seen this message once, you probably won’t want to see it again. We use a cookie to remember this setting. User data is all anonymous. How to manage cookies You can set your browser not to accept cookies, and the website allaboutcookies.org tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result. PRIVACY POLICIES OF OTHER WEBSITES The Aston website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy. CHANGES TO OUR PRIVACY POLICY Aston keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 6 January 2020. HOW TO CONTACT US Aston has appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about Aston’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact the Data Protection Officer using the details set out below. Email: datacontroller@aston.co.im Post: Data Controller, Aston International Limited, Aston House, 36 Hope Street, Douglas, Isle of Man, IM1 1AR HOW TO CONTACT THE APPROPRIATE AUTHORITY Should you wish to report a complaint in relation to how we are processing your data or if you believe Aston has not addressed your concern in a satisfactory manner, you may contact the Isle of Man’s Information Commissioner. Website: www.inforights.im Address: First Floor, Prospect House, Prospect Hill, Douglas, Isle of Man, IM1 1ET Phone: +44 (0)1624 693260 Aston International Limited, Isle of Man Company No. 005183V, is licensed by the Isle of Man Financial Services Authority. 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