PRIVACY POLICY
1. PRIVACY STATEMENT
This Privacy Statement has been created in order to inform you that your personal data (hereinafter «Data»), will be processed in accordance with the previsions of Regulation (EU) n. 2016/679, also referred to General Data Protection Regulation (hereinafter the «GDPR») and any other national complementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK.
2. OWNER AND DATA CONTROLLER
The owner and data controller is OMNIA ADVISORS LTD, c/o Fidlaw Ltd Portman House, 2 Portman Street, London W1H 6DU (UK) Y and registered in the Company House of England and Wales under no. 12194629. (hereinafter also “Omnia Advisors”).
The person appointed as Data Protection Manager is Pietro Rocca and he is our Data Protection Point of Contact and responsible for assisting with enquires in relation to this privacy notice of our treatment of your personal data. To contact our Data Protection Manager you can use the following contact details:
• by mail – OMNIA ADVISORS LTD, c/o Fidlaw Ltd Portman House, 2 Portman Street, London W1H 6DU (UK)
• By email: contact@omniaadvisors.com
3. TYPES OF DATA COLLECTED
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
• Personal data (such as your name and/or address);
• Details of contact (such as phone number and email);
• Details of services you have received from us;
• Information about complaints and enquiries you make to us;
• Our corrispondence and communications between you and our firm;
• Information we received from other sources (such as public entity or information by third parties).
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact our Data Protection Manager.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.
4. HOW WE COLLECT THE DATA
We collect your data when:
• You send us contact form
• You engage us to provide services and also during the provision of these services;
• You contact us by email, telephone or post
5. MODE AND PLACE OF PROCESSING DATA
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
• users have given their consent for one or more specific purposes.
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
6. DATA SHARING
We will share you personal data with third parties where:
• we are required by law;
• it is necessary to administer the relationship between us;
• we have another legitimate interest in doing it.
Third parties includes thirdy-parts providers and other entity of our firm’s network. All of our third-parties are required to take commercially reasonable and appropriate security measures to protect your personal data and we only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
Data transfer outside UE
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.
Data transfer to countries that guarantee European standards (this Application)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission’s website.
Data transfer abroad based on consent (this Application)
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.
Data transfer abroad based on standard contractual clauses (this Application)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (this Application)
If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU – U.S. and Swiss – U.S. Privacy Shield.
In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.
7. DATA SECURITY
We recognise the importance of keeping your personal information secure from unauthorized access. Any information or contents that you enter or which are related to access to your account will be handled securely. Moreover, we shall at all times take all the technical and organizational measures necessary to guarantee the protection of personal data and avoid its alteration, loss, unauthorized access or treatment by, based at all times on the technical possibilities at that time, the nature of the data stored and the risks to which they are exposed. All the above shall be done in accordance with the provisions of the Personal Data Protection Law.
8. RIGHT OF USERS
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
If you have any queries about this Privacy Statement, please contact our Data Manager by sending an email to: contact@omniaadvisors.com.
You may exercise your right to access, rectify, cancel or oppose the use of your data by using the following contact details:
• by mail – OMNIA ADVISORS LTD, c/o Fidlaw Ltd Portman House, 2 Portman Street, London W1H 6DU (UK)
• by email: contact@omniaadvisors.com
The cancellation of the Data means they will be blocked and cannot be viewed or processed by anyone, although they may be stored in their blocked form in order toc omply with the legal, fiscal or tax obligations of Omnia Advisors.
9. CHANGES TO THE PRIVACY POLICY
Omnia Advisors reserves the right to modify or amend this Privacy Statement at any time and for any reason. Users shall be notified of changes to the Privacy Statement via the website www.omniaadvisors.com, or any equivalent system via the applications of our firm.