Privacy Policy (the “Policy”)

Date : 01/07/2023

1. Definitions

We/Us/Our/SFM means www.sfm.com, owned and operated by SFM Corporate Services Group.

You/Your/Yourself means the user of the website www.sfm.com (the “Website”)

"Personal Data" means any information through which we can identify you, as further described below under paragraph 3.

This Policy sets out how We use your Personal Data in connection with:

• services provided to or by you ("Services”);
• other (pre) contractual relationship between You and Us, except for employment or similar relationship (“Relations”);
• Services provided to or by an entity that You represent or work for (“your entity”) or Relations that your entity has with Us.

2. Introduction

The Policy outlines how We deal with Your personal data. We respect Your privacy and We also seek to protect Your personal data.

This Policy only applies to the usage of Personal Data of (prospective) clients, vendors or other business partners (individuals) for which We are responsible and qualify as a controller in the meaning of the General Data Protection Regulation (2016/679/EU) ("GDPR") or similar qualification under other data protection laws, whereby We determine the purpose and the means of the processing of such Personal Data.

3. What kind of Personal Data is collected?

The Personal Data We handle in connection with the provision of our Services or Relations include the following:

• Contact information: This includes Your name, address, phone number, email address, and any other contact details You provide to us.
• Personal characteristics: This refers to information such as Your gender, profession, job title, the name of Your organization, marital status (if indicated on national identification cards), or any other personal and technical characteristics or patterns necessary to identify You as a (prospective) client, vendor, business partner, or representative/employee of such entities. This may also include information disclosed in commercial registers if it is considered Personal Data according to local laws.
• Video footage recording: When you enter our premises, our video surveillance systems (CCTV) may record you. Additionally, you may be recorded on video footage during events, such as seminars, hosted by us. We also conduct introductory video calls for KYC onboarding purposes, and these calls are recorded with additional consent.
• Communication data: This includes your requests, complaints, or any other data exchanged between us via email, telephone, in-person interactions, or any other means of communication.
• KYC information: As required by law, we are obligated to conduct "know your client" identification procedures. To fulfill this legal obligation, we collect specific information from Ultimate Beneficial Owners (UBOs) or executives (e.g., managing directors, board members) of our clients. This information includes their first and family names, nationalities, Personal Data provided in a copy of their ID (including ID number, issuance and expiry dates, issuing authority, and photo), tax residence, private/residential address, phone number, email address, date and place of birth, marital status, profession and actual function, range of annual income, range of estimated wealth, proof of source of wealth/funds, and, where applicable, a U.S. or other Taxpayer Identification Number.

If you are a party to a contract with us, providing Personal Data that allows us to identify you is a prerequisite for concluding the contract. Without such Personal Data, the contract cannot be finalized.

Providing Personal Data for the KYC process is necessary for us to comply with legal requirements related to anti-money laundering. Failure to provide this Personal Data may significantly hinder the verification process, and as a result, we may be unable to enter into a contract with you or your company, or an already concluded contract may be terminated.

Providing Personal Data for the purpose of contact or communication is voluntary. However, the absence of such Personal Data may impede our ability to provide Services, maintain Relations, or respond to your requests or complaints effectively.

Providing Personal Data solely for marketing purposes is voluntary. Not providing this Personal Data will have no consequences.

4. What is the purpose for which We use Your Personal Data?

We collect, utilize, or otherwise process Your Personal Data for the following purposes and on a lawful basis. If we already have information about you, we may use that information for the same purposes.

1. Performance of our agreement with You: We use Your Personal Data to fulfill Our obligations under any agreements between You and Us. This includes providing you with requested information or Services, managing and addressing your inquiries, requests, or complaints.
2. Consent-based use of information: If you are a prospective client, we use your Personal Data to send you marketing communications (such as newsletters, promotions, news, or service updates) via email, electronic means, or telephone. However, We will only do so after obtaining Your consent, unless otherwise permitted by applicable laws. You can withdraw Your consent at any time and exercise Your rights as described in paragraph 11 (Your rights) below.
3. Compliance with legal obligations: The Personal Data mentioned in paragraph 3 (Personal Data we process) may be used to comply with legal obligations imposed on Us. This includes maintaining appropriate business records, conducting Know Your Client identification procedures, responding to lawful requests from governmental agencies and public authorities, and complying with applicable laws, regulations, or legal requirements.
4. Legitimate commercial interests:
   • If You are an existing client, vendor, business partner, representative, or employee, We use Your Personal Data (both in aggregated and individual forms) for the purpose of advertising our Services that may be of interest to You, based on the Services You or Your entity previously used. We may also contact You for marketing or other commercial purposes.
   • Your Personal Data is used for client administration purposes, including the administration of Services agreements or other relevant agreements, as well as for internal administration related to work performed under such agreements.
   • We use Your Personal Data to analyze and enhance the quality of Our Services, understand You or Your entity as a (prospective) customer (customer optimization), assess Your interests, measure the effectiveness of advertising, and deliver personalized marketing materials based on Your preferences and experiences.
   • Additionally, we utilize your Personal Data for other legitimate commercial interests, such as operating and expanding our business activities, developing, improving, or modifying our Services, generating aggregated statistics about Service users, assisting in security and fraud prevention, website administration, troubleshooting, data analysis, testing, research, and statistical purposes.
   • Your Personal Data is also used for system integrity purposes (e.g., prevention of hacking, spamming), facilitating business operations, implementing company policies and procedures, enabling corporate transactions (e.g., mergers, sales, acquisitions, bankruptcies), or for other legitimate business purposes as permitted by applicable law.

5. How we share your Personal Data

We share your Personal Data with the following parties:

• Our data controllers: Your Personal Data may be shared among different entities within Our group for internal administrative purposes, management purposes, analytical purposes, and other business-related purposes. We will only use Your Personal Data for marketing purposes if you have consented or if there is a legitimate interest in doing so.
• Service Providers and Processors: We engage third-party vendors to provide services on Our behalf, and they may have access to your Personal Data. These may include:
  1. Business partners such as law firms, tax and audit firms, or finance providers, including subcontractors involved in performing Services under Services agreements.
  2. Suppliers such as IT service providers, marketing and advertising companies that carry out marketing activities on our behalf.

  3. Analytics and search engine providers that assist us in improving and optimizing our website, such as Acoustic, AWS, Acronis backup, Cloudflare, Comm100, DoubleClick, Dropbox, Facebook, Google, Google Analytics, Google Tag manager, Linkedin, Microsoft Azure, Microsoft O365, Zoom , etc (the “Subcontractors”) These Subcontractors access, receive, maintain, or process Personal Data on Our behalf and under the terms of this Policy.

  4. Social Media features
• Third parties in case of legal requirements: We may disclose Your Personal Data if it is required by law, in the context of an investigation, regulatory requirement, judicial proceeding, court order, legal process served on Us, or to protect the rights or safety of the website, Us, or Our affiliated companies.
• Corporate transactions: Information about our clients, including Personal Data, may be disclosed in the event of any merger, sale, transfer of Our assets, acquisition, bankruptcy, or similar event.
• With consent: We may disclose information about you, including Personal Data, to any other third party if you have provided consent or requested us to do so.

6. Security of Personal Data

We are taking reasonable measures to ensure the proper security of Your Personal Data. We employ appropriate technical, physical, and organizational measures to protect Your Personal Data against unauthorized or unlawful use, alteration, unauthorized access or disclosure, accidental or wrongful destruction, and loss.

We restrict access to Your Personal Data only to individuals who require access for the purposes outlined in this Policy. Furthermore, we engage with Subcontractors as defined in 5 c) above, who possess explicit and unequivocal privacy policies, which are considered integral part of this Policy.

7. Data Retention Period

We keep Your Personal Data for the duration necessary to fulfill the purpose for which it was collected and used, such as providing client Services or other purpose as mentioned in paragraph 4 above. If a longer retention period is required by law or to defend against legal claims, we will retain the data for that extended period.

Our data retention practices comply with the relevant laws of the country or countries where your data is processed. Unless specified otherwise in the policy or by applicable laws, data will be retained at Our discretion.

8. Cookies

Our Website also uses a technology called “cookies.” A “cookie” is a temporary storage created by browser and stored on Your computer .

The information so gathered through cookies may include:

• the date and time when You access our Website;
• the Website pages that You view and any download that You may make through such pages;
• whether or not such viewing or download is successful;
• IP address (Internet Protocol) of your computer or your network / domain from which You access our Website;
• the operating system of the machine running Your Web browser; and the type and version of Your Web browser.

Kindly note that You may reject all third party or selected cookies that are used by our Website and You may also modify Your Web browser preferences to do so. Nevertheless, kindly note that if You reject all cookies, then You might be unable to use some of the services available on our Website. Moreover, kindly note that You may set Your browser in a certain way in order to be notified when You receive a cookie so that You have the option to choose whether to accept the cookie or not. In this regard, You should note that if You do so, this may materially distort the quality of service and data You receive. Thus, You would be doing this at Your own risk.

Apart from cookies, other technologies that are used are beacons, tags and scripts which are used by SFM as well as Our Subcontractors. These technologies are used in analyzing trends, administering the site, tracking user’s movements around the site and also to gather demographic information about Our user base as a whole.

9. Third Party Cookies

Some features on the Website are also using Subcontractors’ cookies that are not under SFM’s control.. You need to specifically reject third party cookies through your browser cookies settings if You do not want to receive third party cookies. If you reject third party cookies, Your ability to use the related features may also be limited.

10. Testimonials

We may feature personal testimonials posted by satisfied customers on Our Website, along with other endorsements. These testimonials are sourced from a third-party service provider that may request Your personal information, such as your name and email address. However, We do not publish personally identifiable information on Our Website.

11. Data Subject Rights

Subject to the conditions outlined in the relevant legislation, you have the entitlement to exercise the following rights as a data subject:

• The right to request access to, rectification of, or erasure of Your Personal Data.
• The right to restrict or object to the processing of Your Personal Data.
• The right to data portability.

If you wish to exercise any of these rights, kindly send an email to gdpr@sfm.com , clearly stating your request. We will acknowledge and respond to your request in compliance with applicable law.

When submitting your request, please indicate the specific right you would like to exercise. Provide details regarding the Personal Data You want to be modified, whether You would like it to be erased from our database, or any specific limitations on its use. We will make every effort to fulfill your request within a reasonable timeframe.

Please be aware that certain Personal Data may need to be retained for recordkeeping purposes or to fulfill ongoing transactions that were initiated prior to Your request to exercise the mentioned rights.

12. Contact Us

Office: https://www.sfm.com/contact-us

For general information:
info@sfm.com

For data protection matters:
gdpr@sfm.com