Alsec Nominees Limited (“Alsec”) takes its responsibilities with regard to the management of personal data very seriously and we do not take lightly the trust you have reposed in us, in providing us with your personal information. This Policy describes how Alsec processes your personal data, but it may not address all possible data processing scenarios. This Privacy Policy is a guide to help you understand:
(1) The Information We Collect
(2) How We Collect and Use Your Data
(3) Consent and Access Rights
(4) Personal Data Protection Principles
(5) User Responsibility
(6) Data Security
(7) Third Party Access
(8) Violation of Privacy
(9) How to Contact Us
1. The Information We Collect
We collect the following information: name, data of birth, residential and contact
address, telephone number, email address, marital status, nationality, gender,
tax identity number, bank details, posts on social networking information on
family members, medical information, educational background, genetic data,
biometric data, identity number, location, photograph, IP address, MAC address,
IMEI number, IMSI number and other information relevant.
2. How We Collect and Use Your Data
2.1 Alsec collects the above-mentioned information using forms, email and physical
requests, cookies, JWT, web tokens.
2.2 When you send email or other communications to Alsec, we may retain those
communications in order to process your inquiries, respond to your requests and
improve our services. When you access Alsec’s services, our servers
automatically record information that your browser sends whenever you visit a
website.
2.3 We use the above-mentioned information for due diligence, transaction advisory,
legal advisory, litigation, regulatory compliance, marketing, business
development, listing on legal directories, publicity, human resources
management, recruitment, events planning and hosting, in-house security,
research, analysis and vendor registration.
3. Consent and Access Rights
3.1 We require your consent for the processing of your data and shall obtain your
consent to individual matters, where any document deals with other matters. If
we use this information in a manner different than the purpose for which it was
collected, then we will ask for your consent prior to such use.
3.2 No Consent shall be sought, given or accepted in any circumstance that may
engender direct or indirect propagation of atrocities, hate, child rights violation,
criminal acts and anti-social conducts.
3.3 You may withdraw your consent at any time and may request access to your
personal information in our possession. We can, however, deny you access to
the information where we determine that your request is unreasonable.
3.4 You reserve the right to request the modification or amendment of your personal
data in our possession.
3.5 In all cases of access or modification / amendment of personal information, we
shall request sufficient identification to enable us confirm that you are the owner
of the data sought to be accessed or modified / amended.
4. Personal Data Protection Principles
When we process your personal data, we are guided by the following principles,
which require personal data to be:
a) processed lawfully, fairly, in a transparent manner and with respect for the
dignity of the human person.
b) collected only for specified, explicit and legitimate purposes and not further
processed in a manner incompatible with those purposes.
c) adequate, relevant and limited to what is necessary in relation to the
purposes for which it is Processed.
d) accurate and where necessary kept up to date.
e) removed or not kept in a form which permits identification of data subject for
longer than is necessary for the purposes for which the personal data is
processed.
f) processed in a manner that ensures its security, using appropriate technical
and organisational measures to protect against unauthorised or unlawful
Processing and against accidental loss, destruction or damage.
5. User Responsibility
You are required to familiarise yourself with this policy and to ensure that the
information you provide to us is complete, accurate and up to date.
6. Data Security
6.1 Alsec implements and maintains appropriate safeguards to protect personal data,
taking into account in particular the risks to you, presented by unauthorised or
unlawful processing or accidental loss, destruction of, or damage to their
personal data.
6.2 Safeguarding will include the use of encryption and pseudonymisation where
appropriate. It also includes protecting the confidentiality (i.e. that only those who
need to know and are authorised to use personal data have access to it),
integrity and availability of the personal data. we regularly evaluate and test the
effectiveness of those safeguards to ensure security of our processing of
personal data.
7. Third Party Access
7.1 Alsec only shares personal information with other companies or individuals in the
following limited circumstances:
a) We have your consent.
b) We provide such information to other professional advisers or other trusted
businesses or persons for the purpose of processing personal information on
our behalf. We require that these parties agree to process such information
based on our instructions and in compliance with this Privacy Policy and any
other appropriate confidentiality and security measures.
c) We have a good faith belief that access, use, preservation or disclosure of
such information is reasonably necessary to (a) satisfy any applicable law,
regulation, legal process or enforceable governmental request, (b) enforce
applicable terms of service, including investigation of potential violations
thereof, (c) detect, prevent, or otherwise address fraud, security or technical
issues, or (d) protect against imminent harm to the rights, property or safety
of Alsec, its users or the public as required or permitted by law.
7.2 Alsec is at all times, responsible for the security and appropriate use of that data
as long as it remains with Alsec.
8. Violation of Privacy
8.1 We have put in place procedures to deal with any suspected personal data
breach and will notify you of any personal data breach and let you know the
steps we have taken to remedy the breach and the security measures we have
applied to render your personal data unintelligible.
8.2 All suspected breach of personal data will be remedied with 1 (one) month from
the date of the report of the breach.
8.3 If you know or suspect that a personal data breach has occurred, you should
immediately contact the Alsec team at dp@uubo.org.
8.4 Alsec will not be responsible for any personal data breach which occurs as a
result of:
a) an event which is beyond the control of Alsec;
b) an act or threats of terrorism;
c) an act of God (such as, but not limited to fires, explosions, earthquakes,
drought, tidal waves and floods) which compromises Alsec’s data protection
measures;
d) war, hostilities (whether war be declared or not), invasion, act of foreign
enemies, mobilisation, requisition, or embargo;
e) rebellion, revolution, insurrection, or military or usurped power, or civil war
which compromises Alsec’s data protection measures;
f) the transfer of your personal data to a third party on your instructions; and
g) the use of your personal data by a third party designated by you.
9. How to Contact Us
For any enquiries you have in relation to this Privacy Policy, please feel free to
contact our Data Protection Officer at dp@uubo.org