CLS Group Privacy Notice
CLS Group Holdings A.G, its subsidiaries and its affiliates (collectively referred to as “CLS Group”, “we”, “us” and “our”) respect your privacy and is committed to protecting your personal data. This notice (Privacy Notice) applies to personal information held by members of the CLS Group as data controllers or joint data controllers, as described below. This Privacy Notice explains how we collect, use and share personal information in the course of our business activities.
This Privacy Notice is directed at any individual whose personal data is processed by CLS Group, including but not limited to clients or their representatives (including their employees or agents), vendors, suppliers or other parties with whom CLS Group have a contractual relationship (including individuals employed by, or agents of, such vendors, suppliers or other parties), users of CLS Group’s website or other applications and CLS employees or applicants for employment.
Changes to the Privacy Notice and your duty to inform us of changes
This version was last updated on 2 November 2018. CLS Group’s Privacy Notice can be found on www.cls-group.com. We may change or update portions of this Privacy Notice to reflect changes in our practices and or applicable law and regulation. Please check this Privacy Notice from time to time so you are aware of any changes or updates to the Privacy Notice, which may be indicated by a change in the effective date noted in this section. Where required under applicable data protection and privacy laws, we will notify you of any change or update portions of this Privacy Notice by individual message or by disclosing the changes to the data processing on a publicly available medium.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity and Contact Data includes your contact information and information about you, including in some cases your signature, identification documents and other identifiers.
- Communications Data includes information we capture through your communications with us e.g. telephone conversations, emails, letters and instant messaging.
- Contractual Data includes information about the nature of the products or services we provide to each other.
- Imagery Data includes CCTV footage and photographs.
- Financial Data includes financial information about you, transactional information and credit information, account authentication details.
- Technical Data includes internet protocol (IP) address, your login data, 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 through CLS Group websites and applications.
- Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website or other applications, products or services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Location Data includes data we receive about where you are.
- Public Data includes information you have made publically available, including via social media.
- Recruitment and Employment Data includes your resumé or CV, data required for background checks, information required to carry out employment relationship such as, but not limited to, passport number, bank account details and tax identifiers.The law and other regulations afford additional protections to certain categories of personal data relating to health, religious beliefs, political opinions or criminal convictions and offences and other categories. We may request sensitive personal data from employees, applicants for employment or certain individuals wishing to provide services to us. CLS Group will only collect and use this information where the law allows us to do so.
- Special Categories of Data and Data Related to Criminal Convictions The law and other regulations afford additional protections to certain categories of personal data relating to health, religious beliefs, political opinions or criminal convictions and offences and other categories. We may request sensitive personal data from employees, applicants for employment or certain individuals wishing to provide services to us. CLS Group will only collect and use this information where the law allows us to do so.
How is your personal data collected?
We will collect your personal data from one or more of the below sources:
- Directly from you throughout our relationship.
- From third parties that are authorised to share your information with us, such as clients, service providers or intermediaries.
- From publically available sources of information.
- From other CLS Group entities
We also collect personal data when we monitor or record our communications with you or through use of certain technology.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we have entered into.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where you have provided your consent. Note that you have the right to withdraw your consent at any time.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the main ways we plan to use your personal data, and which of the legal bases we may rely on to do so.
Delivering products and services
Registering you as a vendor and receiving your services
Recruitment, employment and receipt of certain services
Protecting our legal rights
Website, web portals, applications and systems
See CLS Group’s Cookie Notice for further information.
To meet our legal or regulatory obligations
We may use your personal information to let you know about products and services we believe may be relevant for you. We may contact you by email, post or telephone or through other appropriate communication channels. We strive to ensure that direct marketing is reasonable and proportionate and that we believe is of relevance or interest to you.
You can ask us to stop sending you direct marketing messages at any time by contacting CLS Group’s Data Protection Officer at any time.
Disclosure of your personal data
We share your information in the manner and for the purposes described below:
- Within CLS Group, where such disclosure is necessary to provide you with our services or to manage our business.
- With third parties and vendors who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us, including IT service providers.
- With agencies and organizations working to prevent fraud in financial services.
- To our clients, to facilitate ongoing communications and receipt or provision of services.
- To comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies.
- We may share in aggregate, statistical form, non-personal information regarding the visitors to our website or applications, traffic patterns, and website usage with our business partners, affiliates or advertisers.
- Where required in connection with potential or actual corporate restructuring, merger, acquisition or takeover, including any transfer or potential transfer of any of our rights or duties under an agreement. Your personal information, technical information about your device or browser and/or other anonymous information we obtain from you via the websites may be disclosed to any potential or actual third party purchasers of such assets and/or may be among those assets transferred.
- To any third party to whom you authorise us to disclose your personal data.
We share your personal data within the CLS Group. This will involve transferring your data outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented (unless a derogation applies):
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
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 will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
Your legal rights
You have the right to:
- access information we hold about you and to obtain information about how we process it (often referred to as a “Subject Access Request”);
- in certain circumstances, the right to withdraw your consent to our processing of your information. We may continue to process your information if we have another legitimate reason for doing so;
- in some circumstances, the right to receive certain information you have provided to us in an electronic format and/or request that we transmit it to a third party;
- the right to request that we rectify your information if it’s inaccurate or incomplete;
- in some circumstances, the right to request that we erase your information. We may continue to retain your information if we’re entitled or required to retain it;
- the right to object to, and to request that we restrict, our processing of your information in some circumstances. Again, there may be situations where you object to, or ask us to restrict, our processing of your information but we’re entitled to continue processing your information and/or to refuse that request; and
- you have the right to lodge a complaint with your local data protection supervisory authority if you have concerns about how we are processing your personal information. We would ask that you attempt to resolve any concerns with CLS Group before lodging a complaint with your local supervisory authority.
If you have any questions, concerns or complaints or if you wish to exercise any of your rights, please contact CLS Group’s Data Protection Officer:
Data Protection Officer, CLS Group, Exchange Tower,1 Harbour Exchange Square, London. E14 9GE