March 1, 2019
This document outlines our data protection obligations and your data protection rights under the EU data protection regime introduced by the General Data Protection Regulation (Regulation 2016/679), the (“GDPR”). In this document, “we”, “us” and “our” refer to Vibe Advisors Limited and its potential affiliates and delegates.
Your personal data
You understand that by providing us with personal information you will provide us with certain personal information which constitutes personal data within the meaning of the GDPR (This includes, but is not restricted to, data such as your first name, last name, email, company, location, phone).
Why we may use your personal data
You understand that we may collect, store and use this data for lawful purposes including, in particular direct marketing purposes (that is, providing you with information on products and services that may be of interest) and this may be regarded as being for the purposes of a legitimate interest. We do not analyse personal data nor sell personal data. Accordingly, you understand and agree that we may keep your personal data for such purposes as described above, provided that we are acting in a fair, transparent and accountable manner and have taken appropriate steps to prevent any unwarranted impact on you and also noting your right to object to retaining this data. Should we wish to use your personal data for other specific purposes that require your consent, we will contact you to request your consent for such usage.
Why we may transmit your personal data
You understand that in certain circumstances we may share your data (this includes, but is not restricted to, data such as your first name, last name, email, company, location, phone) to our third-party managers for client servicing and marketing purposes only and this may include certain entities located outside the EEA.
The data protection measures we take
Any transmission of your personal data by us or our duly authorised affiliates and/or delegates outside the EEA shall be in accordance with the conditions in the GDPR. We shall apply appropriate information security measures designed to protect data in our/our affiliates and/or delegates’ possession from unauthorised access by third parties or any form of computer corruption. We shall notify you of any personal data breach affecting you that is likely to result in a high risk to your interests, fundamental rights or freedoms.
Your data protection rights
You understand that you have certain rights regarding our use of this personal data such as (but not limited to):
– the right to access your personal data;
– the right to examine and correct your personal data;
– the right to restrict the use of your personal data;
– the right to withdraw any consent given to the processing of your personal data (where applicable);
– the right to receive information regarding any entities we disclose your personal data to;
– the right to lodge a complaint
Personal data retention
We may retain your personal data for a period of up to three years following our last communication.
Enquiries and Complaints
We do not process personal data on a large scale and are therefore not required to designate a data protection officer. However, should you have any queries or wish to discuss your data protection rights with us, please contact us via email to firstname.lastname@example.org.