Privacy

CLS Group Privacy Notice

1. Introduction

CLS Group Holdings A.G, its subsidiaries and its affiliates (collectively referred to as “CLS Group”, “we” and “us”) respect your privacy and is committed to protecting your personal data. This notice (Privacy Notice) applies to personal data held by members of the CLS Group as data controllers or join data controllers, as described below. This Privacy Notice explains how we collect, use and share personal data 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 at https://www.cls-group.com/ or other applications and CLS employees or applicants for employment.

2. Changes to the Privacy Notice and informing us of changes to your personal data

This version was last updated on 11 June 2026.

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. Nothing in this Privacy Notice should be interpreted to establish rights or obligations that go beyond what is mandated by the respectively applicable data protection laws.

3. The data we collect about you

Personal data (also sometimes referred to as personal information), means any information about an individual from which that person can, either directly or indirectly, be identified. It does not include data where individuals can no longer be identified (anonymous data).

We may process or otherwise be a controller of different kinds of personal data about you which we have grouped together as 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, and account authentication details.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, device type, 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 CLS Group websites and applications. It also includes details of the part of our websites and applications that you are viewing, such as full web page URLs; location data, including the geographic location of a device derived from IP address; diagnostic data (including crash logs, launch time, hang rate and energy use, and any other data collected for technical diagnostics purposes); and any relevant unique identifiers assigned to a device or browser (including cookie identifiers).
Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our websites, applications, products or services, including data observed or collected in relation to your browsing activity on our websites and applications and interaction with our emails. This may include information about pageviews and events on our websites and applications; information about the webpage or other source that you were previously on before reaching our websites and applications; information about when a browsing session started and ended; and information about views of and clicks on our advertisements, together with advertising or other identifiers associated with you or your device (for example, a device's IDFA (iOS) or AAID (Android) or advertising cookie identifiers).
Social Media Data includes information that is logged by third-party providers of social media platforms in relation to events that users take in relation to our social media pages or content. Events can include views, clicks, following or unfollowing, and any other types of interaction with our page or content, and the data that is recorded by the third-party providers of social media platforms may include information about the person taking the action and the device they are using, such as social media handles, the date and time of the event, the country/city (derived from IP address or social media profiles) of the user, age/gender information and the type of device used. Unless specified otherwise in this Privacy Notice, this personal data is not shared with us, but third-party social media providers may use it to provide us with anonymous and aggregate statistics about our social media pages and content.
Advertising Partner Data includes information obtained independently by our advertising partners, including unique identifiers and a profile of your possible interests and characteristics, which may have been built by observing your activity on websites, apps and other digital properties, including those operated by third parties, that use our advertising partners’ services. Unless specified otherwise in this Privacy Notice, this personal data is not shared with us, but it may be used for our benefit for the online advertising activities described in this Privacy Notice.
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, including your location of work in CLS offices.
Public Data includes information you have made publicly available, including via social media sites such as (but not limited to) LinkedIn.
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, tax identifiers, and conflicts of interest.
Special Categories of Data and Data Related to Criminal Convictions includes categories of personal data relating to health, religious beliefs, ethnicity, biometrics, political opinions, criminal convictions and offences or other categories. Where necessary we may request special category data from employees, applicants for employment or individuals wishing to provide services to us. The law and other regulations afford additional protections to special categories of personal data and CLS Group will only collect and use this information where the law allows us to do so.

4. 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.
Automatically through the use of cookies and other similar technologies
From third parties that are authorised to share your information with us, such as clients, service providers or intermediaries.
From publicly available sources of information.
From other CLS Group entities.

5. Purposes for which we will 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.

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.

Purpose/Activity	Lawful Basis
Delivering products and services To manage our relationship with you or your business and deliver our products and services. To exercise our rights set out in agreements or contracts. To communicate with you about our products and services. To measure, detect and prevent the likelihood of financial, reputational, legal, compliance or customer risk. This includes credit risk. For business continuity management. To manage complaints or feedback received by third parties.	Contractual Obligation Legal Duty Legitimate Interests Consent
Registering you as a vendor and receiving your services To measure, detect and prevent the likelihood of financial, reputational, legal, compliance or customer risk. This includes credit risk. To communicate with you about the service including end to end management review.	Legitimate Interests Contractual Obligation
Recruitment, employment and receipt of certain services To confirm your references, educational background or other information and to consider your suitability for any current or future recruitment requirements. To carry out the employment relationship, to fulfil our duties as an employer and to make use of our rights as employer. For internal training. For business continuity management. To provide CLS approved benefits for employees.	Legitimate Interests Contractual Obligation Legal Duty Consent Vital Interests For special category personal data: Article 9(2)(b) – rights of Controller in the field of Employment Article 9(2)(c) – to protect the vital interests of the data subject or of another natural person
Protecting our legal rights To protect our legal rights, e.g. in the case of defending or the protection of legal rights and interests (e.g. collecting money owed, enforcing or protecting our security or defending rights of intellectual property), court action, managing complaints or disputes, in the event of a restructuring of companies or other mergers or acquisition.	Legitimate Interest Contractual Obligation For special category personal data: Article 9(2)(f) – processing is necessary for the establishment, exercise or defence of legal claims
Website, web portals, applications and systems To allow us to provide you with access to our website, web portals, applications and systems, including to set up and manage user accounts and to verify users when logging into accounts and secure areas of our website, web portals, applications and systems. To allow you to directly or indirectly communicate with us through our website, web portals, applications and systems. To administer and protect our website, web portals, applications and systems and users (including troubleshooting, fixing errors, analysis, testing, system maintenance, support, and security, including for fraud monitoring and prevention). We use essential Cookies for this purpose. See the Cookies and other similar technologies section of this Privacy Notice for further information.	Legitimate Interests Contractual Obligation Compliance with a legal obligation
To meet our legal or regulatory obligations To prevent and detect crime or non-compliance with laws or regulatory requirements including, e.g. insider trading, fraud, terrorist financing and money laundering, including monitoring, mitigation and risk management, carrying out client due diligence, name screening, transaction screening and client risk identification. For reporting to, and audits by, national and international regulatory or enforcement bodies and complying with court orders associated with us.	Legitimate Interests Legal Duty Public Interest
Analytics and insights To carry out insight and analytics in relation to our website, web portals, applications and systems, including counting user visits, combining this with general insights about our users’ interests and browsing habits so that we can understand the type of user that our website, web portals, applications and systems appeals to, and learning what content and features of our website, web portals, applications and systems are most popular – these insights and analytics are used for the purposes described in the Website, web portals, applications and systems improvement section below. To count the open rate and measure the effectiveness of our marketing emails. To measure the effectiveness of our online advertising, including to generate aggregate statistics that do not identify individuals (for example, counting how many people viewed or clicked on our ads and were redirected to our website, web portals, applications and systems through one of our ads). To gain general insights about users and customers and their purchase or use of our products and services, so that we can develop future product and service lines. To analyse the success of our events, including assessing sign-up rates, monitoring social media, online forums, and other online content, and collecting and analysing event feedback. We may use non-essential Cookies for this purpose. See the Cookies and other similar technologies section of this Privacy Notice for further information.	Legitimate interests. Consent (where non-essential Cookies are used)
Website, web portals, applications and systems improvement To develop and improve our website, web portals, applications and systems, including content that we make available, through insight and analysis that we carry out as described in the Analytics and insights section above. We may use non-use essential Cookies for this purpose. See the Cookies and other similar technologies section of this Privacy Notice for further information.	Legitimate Interests Consent (where non-essential Cookies are used)
Social media pages and insights To publish pages on social media (including LinkedIn, X, and YouTube) relating to our website, web portals, applications and systems, products and services, and business. These pages help social media users discover and engage with us, and help us promote, and keep social media users updated about, our business. To gain insight into our social media pages, we may receive insights from the third-party provider of the social media platform about how users interact with our pages. We receive this information so that we can understand how many people saw our social media content, which content people are engaging with the most, actions users are taking on our pages (such as whether they are visiting our website, web portals, applications and systems after visiting our pages, clicking on any content), and the demographics (such as age, gender and location) of those that view our social media pages. These insights are derived from personal data that the third-party provider of the social media platform processes and are only provided to us in the form of anonymous and aggregate statistics – we do not receive your personal data or any information that we can use to identify you when we receive these insights. To see who has ‘liked’ or shared content that we post on social media (including when you interact with any ‘like’ or similar embedded feature on our website, web portals, applications and systems.) For more information, please see the Advertising and Social Media Partners section.	Legitimate Interests
Monitoring activity To access, review, disclose, intercept, monitor and/or record verbal and electronic messaging and communications including for the purposes of: detecting non-compliance with laws, regulatory obligations or CLS Group’s internal policies monitoring quality of service establishing facts preventing fraud, money laundering or other crimes ensuring effectiveness of systems assisting investigations managing cybersecurity risks To record and review CCTV footage or other information for the purposes of managing and protecting CLS premises and assets, as well as health and safety requirements in relation to our employees, contractors and visitors To record and review office attendance data via door entry and HR systems for the purposes of monitoring compliance with CLS Group's hybrid working policy. For users of CLS systems with privileged access accounts, to record and review keystroke logs or screen recordings for the purpose of investigating security incidents and/or the protection of our systems.	Legitimate Interests Legal Duty Public Interest Consent For special category personal data: Article 9(2)(g) – reasons of substantial public interest.
Online advertising To display ads for our products and services or our website, web portals, applications and systems, or that otherwise promote our business, when you visit websites, apps, and other digital platforms, including social media, that are operated by third parties (“Third-Party Sites), including to: recognise you as a user of our website, web portals, applications and systems and to display ads for products and services that you have viewed on our website, web portals, applications and systems reach users of Third-party Sites who meet certain criteria determined by us or our advertising partners using selection tools made available by our advertising partners (for example, individuals who are aged between 20-25). To measure our advertising and to determine how successful our advertising campaigns are, including to generate insight and analysis about our advertising activities, as described in the Analytics and insights section above To carry out these activities we may use non-essential Cookies and we also work with third-party advertising partners. Please see the Cookies and other similar technologies and Advertising and social media partners sections for more information. Please also note that our advertising partners may use non-essential Cookies on third-party sites, as well as Advertising Partner Data that they have independently collected, for this purpose. We are not responsible for these technologies and you should separately review the information provided to you on the third-party site about these technologies.	Legitimate Interests Consent (where non-essential Cookies are used)
Marketing To make suggestions and recommendations to you about products or services that may be of interest to you or your company. To capture and publish photographs, videos, and audio recordings at CLS organised events for the purposes of providing information about and promoting CLS products, services or activities via internal and external media channels	Consent Legitimate Interest

Purpose/Activity

Lawful Basis

Delivering products and services

To manage our relationship with you or your business and deliver our products and services.
To exercise our rights set out in agreements or contracts.
To communicate with you about our products and services.

To measure, detect and prevent the likelihood of financial, reputational, legal, compliance or customer risk. This includes credit risk.
For business continuity management.
To manage complaints or feedback received by third parties.

Contractual Obligation
Legal Duty
Legitimate Interests
Consent

Registering you as a vendor and receiving your services

To measure, detect and prevent the likelihood of financial, reputational, legal, compliance or customer risk. This includes credit risk.
To communicate with you about the service including end to end management review.

Legitimate Interests
Contractual Obligation

Recruitment, employment and receipt of certain services

To confirm your references, educational background or other information and to consider your suitability for any current or future recruitment requirements.
To carry out the employment relationship, to fulfil our duties as an employer and to make use of our rights as employer.
For internal training.
For business continuity management.
To provide CLS approved benefits for employees.

Legitimate Interests
Contractual Obligation
Legal Duty
Consent
Vital Interests

For special category personal data:

Article 9(2)(b) – rights of Controller in the field of Employment
Article 9(2)(c) – to protect the vital interests of the data subject or of another natural person

Protecting our legal rights

To protect our legal rights, e.g. in the case of defending or the protection of legal rights and interests (e.g. collecting money owed, enforcing or protecting our security or defending rights of intellectual property), court action, managing complaints or disputes, in the event of a restructuring of companies or other mergers or acquisition.

Legitimate Interest
Contractual Obligation

For special category personal data:

Article 9(2)(f) – processing is necessary for the establishment, exercise or defence of legal claims

Website, web portals, applications and systems

To allow us to provide you with access to our website, web portals, applications and systems, including to set up and manage user accounts and to verify users when logging into accounts and secure areas of our website, web portals, applications and systems.
To allow you to directly or indirectly communicate with us through our website, web portals, applications and systems.
To administer and protect our website, web portals, applications and systems and users (including troubleshooting, fixing errors, analysis, testing, system maintenance, support, and security, including for fraud monitoring and prevention).

We use essential Cookies for this purpose. See the Cookies and other similar technologies section of this Privacy Notice for further information.

Legitimate Interests
Contractual Obligation
Compliance with a legal obligation

To meet our legal or regulatory obligations

To prevent and detect crime or non-compliance with laws or regulatory requirements including, e.g. insider trading, fraud, terrorist financing and money laundering, including monitoring, mitigation and risk management, carrying out client due diligence, name screening, transaction screening and client risk identification.
For reporting to, and audits by, national and international regulatory or enforcement bodies and complying with court orders associated with us.

Legitimate Interests
Legal Duty
Public Interest

Analytics and insights

To carry out insight and analytics in relation to our website, web portals, applications and systems, including counting user visits, combining this with general insights about our users’ interests and browsing habits so that we can understand the type of user that our website, web portals, applications and systems appeals to, and learning what content and features of our website, web portals, applications and systems are most popular – these insights and analytics are used for the purposes described in the Website, web portals, applications and systems improvement section below.
To count the open rate and measure the effectiveness of our marketing emails.
To measure the effectiveness of our online advertising, including to generate aggregate statistics that do not identify individuals (for example, counting how many people viewed or clicked on our ads and were redirected to our website, web portals, applications and systems through one of our ads).
To gain general insights about users and customers and their purchase or use of our products and services, so that we can develop future product and service lines.
To analyse the success of our events, including assessing sign-up rates, monitoring social media, online forums, and other online content, and collecting and analysing event feedback.

We may use non-essential Cookies for this purpose. See the Cookies and other similar technologies section of this Privacy Notice for further information.

Legitimate interests.
Consent (where non-essential Cookies are used)

Website, web portals, applications and systems improvement

To develop and improve our website, web portals, applications and systems, including content that we make available, through insight and analysis that we carry out as described in the Analytics and insights section above.

We may use non-use essential Cookies for this purpose. See the Cookies and other similar technologies section of this Privacy Notice for further information.

Legitimate Interests
Consent (where non-essential Cookies are used)

Social media pages and insights

To publish pages on social media (including LinkedIn, X, and YouTube) relating to our website, web portals, applications and systems, products and services, and business. These pages help social media users discover and engage with us, and help us promote, and keep social media users updated about, our business.
To gain insight into our social media pages, we may receive insights from the third-party provider of the social media platform about how users interact with our pages. We receive this information so that we can understand how many people saw our social media content, which content people are engaging with the most, actions users are taking on our pages (such as whether they are visiting our website, web portals, applications and systems after visiting our pages, clicking on any content), and the demographics (such as age, gender and location) of those that view our social media pages. These insights are derived from personal data that the third-party provider of the social media platform processes and are only provided to us in the form of anonymous and aggregate statistics – we do not receive your personal data or any information that we can use to identify you when we receive these insights.
To see who has ‘liked’ or shared content that we post on social media (including when you interact with any ‘like’ or similar embedded feature on our website, web portals, applications and systems.)

For more information, please see the Advertising and Social Media Partners section.

Legitimate Interests

Monitoring activity

To access, review, disclose, intercept, monitor and/or record verbal and electronic messaging and communications including for the purposes of:
- detecting non-compliance with laws, regulatory obligations or CLS Group’s internal policies
- monitoring quality of service
- establishing facts
- preventing fraud, money laundering or other crimes
- ensuring effectiveness of systems
- assisting investigations
- managing cybersecurity risks
To record and review CCTV footage or other information for the purposes of managing and protecting CLS premises and assets, as well as health and safety requirements in relation to our employees, contractors and visitors
To record and review office attendance data via door entry and HR systems for the purposes of monitoring compliance with CLS Group's hybrid working policy.
For users of CLS systems with privileged access accounts, to record and review keystroke logs or screen recordings for the purpose of investigating security incidents and/or the protection of our systems.

Legitimate Interests
Legal Duty
Public Interest
Consent

For special category personal data:
Article 9(2)(g) – reasons of substantial public interest.

Online advertising

To display ads for our products and services or our website, web portals, applications and systems, or that otherwise promote our business, when you visit websites, apps, and other digital platforms, including social media, that are operated by third parties (“Third-Party Sites), including to:

recognise you as a user of our website, web portals, applications and systems and to display ads for products and services that you have viewed on our website, web portals, applications and systems reach users of Third-party Sites who meet certain criteria determined by us or our advertising partners using selection tools made available by our advertising partners (for example, individuals who are aged between 20-25).

To measure our advertising and to determine how successful our advertising campaigns are, including to generate insight and analysis about our advertising activities, as described in the Analytics and insights section above

To carry out these activities we may use non-essential Cookies and we also work with third-party advertising partners. Please see the Cookies and other similar technologies and Advertising and social media partners sections for more information.

Please also note that our advertising partners may use non-essential Cookies on third-party sites, as well as Advertising Partner Data that they have independently collected, for this purpose. We are not responsible for these technologies and you should separately review the information provided to you on the third-party site about these technologies.

Legitimate Interests
Consent (where non-essential Cookies are used)

Marketing

To make suggestions and recommendations to you about products or services that may be of interest to you or your company.
To capture and publish photographs, videos, and audio recordings at CLS organised events for the purposes of providing information about and promoting CLS products, services or activities via internal and external media channels

Consent
Legitimate Interest

6. Direct Marketing

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 by contacting CLS Group’s Data Protection Officer at any time.

7. Cookies and other similar technologies

Where indicated in this Privacy Notice, cookies, web beacons, pixel tags and other similar technologies (“Cookies”) may be used for the purposes described in this Privacy Notice. In addition to the information set out in this Privacy Notice, you can find out further information about the Cookies that we use on our websites and applications, and learn how you can manage your consent to the use of non-essential Cookies, by visiting the Cookie settings link in our website footer.

In some cases, the Cookies that we use may be provided by a third party, including the advertising partners described in the Advertising and social media partners section of this Privacy Notice. Information about you may be shared with the relevant third party and used in accordance with their privacy notice.

In addition, where we use Cookies relating to services provided by Google, Google has published information about how it uses personal data in connection with its services here. Google also provides further information about:

· How it uses personal data in connection with Google Analytics here. If you do not want your personal data to be used for the purposes of Google Analytics, you can install the Google Analytics opt-out browser add-on (but please note that this will only work on certain browsers) which is available here.

· How it uses personal data in connection with its online advertising services here. Please also see the Advertising and social media partners section of this Privacy Notice for more information. For further information about how Google uses your personal data in connection with these activities, including the legal basis Google relies on and the ways to exercise your data subject rights against Google, please see Google's Privacy Policy at https://policies.google.com/privacy. You can also use Google’s Ad Settings to manage your online advertising preferences with Google.

You may also be able to manage your Cookie preferences using functionality provided by your browser, but please be aware that to use some parts of our websites and applications you will need to allow essential Cookies. If you block essential Cookies, some parts of our websites or applications may not work properly, or you may not be able to access our websites or applications.

For more general information about Cookies and managing Cookies, including blocking or deleting cookies for a wide variety of browsers, visit All About Cookie.

8. Advertising and social media partners

Where the UK and EU GDPR apply, this section provides information about third parties that we work with in relation to the activities described in the Online advertising and Social media pages and insight sections of this Privacy Notice. To carry out these activities, we may share personal data with these third parties, including through the use of Cookies as set out in the Cookies and other similar technologies section of this Privacy Notice.

Please note that these third parties may be a controller of your personal data, meaning that they determine how and why they will use your personal data.

· Google: We work with Google in connection with the activities described in the Online advertising section of this privacy notice. Please note that, Google may process personal data that it obtains in connection with these activities for its own purposes, including measuring the effectiveness of advertising, protecting against fraud and abuse, and personalising content and ads across Google's products.

For further information about how Google uses your personal information in connection with these activities, including the legal basis Google relies on and the ways to exercise your data subject rights against Google, please see Google's Privacy Policy here.

In addition, Google has published information about how it uses personal information from sites, apps and other properties that use its services here, as well as further information about how it uses personal information in connection with online advertising in its Privacy Policy and here. You can also use Google’s Ad Settings to manage your online advertising preferences.

· YouTube (a Google platform): We may receive YouTube insights from Google for the purposes described in the Social media pages and insight section above. Google processes Social Media Data to provide those insights to us. For information about how Google uses your personal data to provide insights, including the legal basis Google relies on and the ways to exercise your data subject rights in respect of Google’s processing, please see Google’s Privacy Policy at https://policies.google.com/privacy.

· X: We may receive insights from X for the purposes described in the Social media pages and insight section above. For information about how X uses your personal data to provide insights, including the legal basis X relies on and the ways to exercise your data subject rights in respect of X’s processing, please see X’s Privacy Policy at https://x.com/en/privacy.

· LinkedIn. We work with LinkedIn in connection with the activities described in the Online advertising section of this privacy notice. Please note that LinkedIn may process personal data that it obtains in connection with these activities for its own purposes, including delivering, supporting and improving LinkedIn's products and services and reporting and performance analysis.

In addition, where we receive insights from LinkedIn for the purposes described in the Social media pages and insight section above, we are joint controllers with LinkedIn in relation to LinkedIn’s processing of their Social Media Data to provide those insights to us. LinkedIn has primary responsibility for complying with the GDPR in respect of this processing, including informing data subjects about the processing and enabling data subjects to exercise their rights under the GDPR.

For further information about how LinkedIn uses your personal data in connection with these activities, including the legal basis LinkedIn relies on and the ways to exercise your data subject rights in respect of LinkedIn’s processing, please see LinkedIn’s Privacy Policy at https://www.linkedin.com/legal/privacy-policy.

In addition, LinkedIn has published information about how it uses your personal data in connection with its advertising services, including how you can opt-out of LinkedIn’s interest-based advertising, at https://www.linkedin.com/psettings/advertising-data and https://www.linkedin.com/help/linkedin/answer/a421454.

9. 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 the advertising partners described in the Advertising and social media partners section of this Privacy Notice, to provide you with and measure the effectiveness of personalised online advertising. We may use Cookies to share this information, as described in the Cookies and other similar technologies section of this Privacy Notice
With agencies and organizations working to prevent fraud in financial 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.

10. International transfers

We share your personal data within the CLS Group as well as with selected service providers. This will involve transferring your data outside the United Kingdom (UK).

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use standard contractual clauses approved by the Information Commissioners Office ("ICO").

11. 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.

12. Data retention

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.

13. Individual rights

If you are a data subject in the European Economic Area (“EEA”) or the United Kingdom (“UK”) 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, where we are relying on Consent, you have the right to withdraw your consent to our processing of your information at any time.
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;
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;
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;
complain to us if you believe that our processing of your personal data does not comply with applicable privacy laws or you otherwise have a concern about the way we have handled your personal data. Once we receive your complaint, we will acknowledge receipt within 30 days. We will then take appropriate steps to investigate the matters you have raised and will keep you informed of our progress. We will notify you of the outcome of your complaint without undue delay. All complaints should be addressed to CLS Group’s Data Protection Officer and sent to the contact details below; 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. You can find a list of contact details for EEA supervisory authorities at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm . If you are in the UK, you can complain to the ICO by visiting https://ico.org.uk/make-a-complaint/.

If you are a data subject in a territory other than the European Economic Area (“EEA”) or the United Kingdom (“UK”), you may have similar rights afforded to you under other data protection laws.

14. Contact details

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:

By email: dpo@cls-services.com

By post:
Data Protection Officer
CLS Group, Exchange Tower
1 Harbour Exchange Square
London
E14 9GE