Data Privacy

Data protection

Responsible body in terms of data privacy laws is:

Van Sterling Capital Ltd.
168, St. Christopher Street
MT – Valletta VLT 1467

Definitions

The privacy policy of Van Sterling Capital Ltd. is based on the terminology used by the European legislature and legislature in adopting the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain in advance the used terminology.

We can use the following terms in this privacy policy, including but not limited to.

Personal data

Personal data is any information relating to an identified or identifiable natural person. A natural person is considered to be identifiable who, directly or indirectly, in particular by association with an identifier such as a name, with an identification number, with location data, with an online identifier or with one or more special features, expresses the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person can be identified.

Affected person

Affected person is any identified or identifiable natural person, whose personal data is processed by the controller.

Processing

Processing means any process or series of operations related to personal data, such as collecting, organizing, storing, adapting or modifying, reading, querying, using, with or without the aid of automated procedures; disclosure by submission, dissemination or other form of provision, reconciliation or association, restriction, erasure or destruction.

Limitation of processing

Restriction of the processing is the marking of stored personal data with the aim to limit their future processing.

Profiling

Profiling is any type of automated processing of personal data that consists in using that personal information to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal to analyse or predict preferences, interests, reliability, behaviour, whereabouts or relocation of that natural person.

Pseudonymisation

Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.

Receiver/Subscriber

Recipient is a natural or legal person, agency or other entity to whom personal data is disclosed, whether or not it is a third party. However, authorities which may receive personal data under EU or national law in connection with a particular mission are not considered as beneficiaries.

Third

Third is a natural or legal person, public authority, body or body other than the data subject, the controller, the processor and the persons authorized under the direct responsibility of the controller or the processor to process the personal data.

Responsible or data controller

The controller is the natural or legal person, public authority, body or body that, alone or in concert with others, decides on the purposes and means of processing personal data. Where the purposes and means of such processing are determined by EU law or the law of the member states, the controller or the specific criteria for his designation may be provided for under EU or national law.

Processors

The processor is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.

Consent

Consent, any information given voluntarily by the data subject in an informed and unequivocal manner in the form of a statement or other unambiguous affirmative act by the data subject to indicate to the data subject that they consent to the processing of the personal data concerning them is.

Collecting general information

When you access our website, information of general nature is automatically recorded. This information (server log files) includes, for example, the type of web browser, the operating system used, the domain name of your Internet service provider and the like. This is only information that does not allow conclusions concerning your person. This information is technically necessary to correctly deliver the content of web pages requested by you and is mandatory when using the internet. Anonymous information of this kind is statistically evaluated by us to optimize our internet presence and the underlying technology.

Registration on our website

When registering for the use of our personalised services, some personal information will be collected, such as name, address, contact and communication information such as telephone number and email address. If you are registered with us, you can access content and services that we offer only to registered users. Registered users also have the option to changing or deleting the data specified during the registration at any time. Of course, we also provide you with information about the personal data we store about you at any time. We are happy to rectify or delete this at your request, as far as no statutory storage requirements preclude. To contact us in this context, please use the contact details given at the end of this Privacy Policy.

Processing of data (customer and contract data)

We collect, process and use personal data only insofar as they are necessary for the establishment, fulfilment or modification of the legal relationship (inventory data). This is done on the basis of Art. 6 para. 1 lit. b GDPR, which allows the processing of data to fulfil a contract or pre-contractual measures. We collect, process and use personal data about the use of our website (usage data) only insofar as this is necessary to enable or charge the user for the use of the service.

The collected customer data will be deleted after completion of the order or termination of the business relationship. Legal retention periods remain unaffected.

Data transfer at the conclusion of the contract

We only transfer personal data to third parties if this is necessary within the scope of the contract, for example to the bank responsible for processing the payment.

A further transmission of the data does not take place or only if you have expressly consented to the transmission. A transfer of your data to third parties without explicit consent, such as for advertising purposes, does not occur.

The basis for data processing is Art. 6 para. 1 lit. b GDPR, which allows the processing of data to fulfil a contract or pre-contractual measures.

Provision of paid services

To provide paid services we ask for additional data, such as payment details.

To protect the security of your data during transmission, we use state-of-the-art encryption techniques (such as SSL) over HTTPS.

Newsletter

When you sign up to receive our newsletter, the data provided by you will be used exclusively for this purpose. Subscribers may also be notified by email about circumstances relevant to the service or registration (such as changes to the newsletter offer or technical conditions).

For an effective registration we need a valid email address. To verify that an application is actually made by the owner of the email address, we use the “double-opt-in” procedure. For this purpose, we record the order of the newsletter, the dispatch of a confirmation mail and the receipt of the requested answer. No further data is collected. The data will be used exclusively for the newsletter distribution and will not be passed on to third parties.

The consent to the storage of your personal data and its use for the newsletter can be revoked at any time. Each newsletter has a respective unsubscribe link. You can also send us your request to unsubscribe via the contact details provided at the end of this document.

Contact form

If you contact us by email or contact form, the information you provide will be stored for the purpose of processing the request and for possible follow-up questions.

Deletion or blocking of data

We adhere to the principles of data avoidance and data sparingness. Therefore, we only store your personal data for as long as is necessary to achieve the purposes mentioned here or as provided for by the various storage periods provided for by law. After discontinuation of the respective purpose or expiration of these deadlines, the corresponding data will be blocked or deleted routinely and in accordance with the statutory provisions.

Use of Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, due to the activation of IP anonymization on these websites, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data. You can prevent the storage of cookies by a corresponding setting of your browser software; however, we point out that in this case you may not be able to use all functions of this website in full.

You can prevent tracking by Google Analytics on our pages by clicking this link (https://tools.google.com/dlpage/gaoptout?hl=en).

An opt-out cookie will be installed on your device. This will prevent the collection by Google Analytics for this website and for this browser in the future, as long as the cookie remains installed in your browser.

Social plugins

Our websites use social plugins of the providers listed below. The plugins are marked with the appropriate logo.

These plug-ins may be used to send information, which may include personal information, to the service provider and may be used by the service provider. We prevent the automatic and unwanted collection and transmission of data to the service provider through a 2-click solution. To activate a desired social plugin, it must first be activated by clicking on the corresponding button. Only through this activation of the plugin the detection of information and its transmission to the service provider is triggered. We do not collect personally identifiable information by means of social plugins or their use.

We have no control over what data an enabled plugin collects and how it is used by the provider. At present, it must be assumed that a direct connection to the services of the provider will be established and at least the IP address and device-related information will be collected and used. It is also possible that the service providers try to save cookies on the computer used. Please refer to the privacy policy of the respective service provider to see which specific data is collected here and how it is used.

Note: If you are logged in to Facebook at the same time, Facebook may identify you as a visitor to a specific page. If you are logged in to YouTube at the same time, YouTube may identify you as a visitor to a specific page.

We have integrated the social media buttons of the following companies on our website:

Facebook Inc. (1601 S. California Ave – Palo Alto – CA 94304 – USA)
Twitter Inc. (795 Folsom St. – Suite 600 – San Francisco – CA 94107 – USA)
Google Plus / Google Inc. (1600 Amphitheatre Parkway – Mountain View – CA 94043 – USA)
LinkedIn Corporation (2029 Stierlin Court – Mountain View – CA 94043 – USA)
YouTube, LLC (901 Cherry Ave – San Bruno – CA 94066, USA)

Cookies

Like many other websites, we also use so-called “cookies”. Cookies are small text files that are transferred from a website server to your hard drive. This automatically gives us certain information, such as IP address, browser used, operating system of your computer and your connection to the Internet.

Cookies cannot be used to launch programs or to transfer viruses to a computer. Based on the information contained in cookies, we can facilitate navigation and enable the correct display of our websites.

In no case will the data collected by us be passed on to third parties or a link with personal data will be established without your consent.

Of course, you can also view our website without cookies. Internet browsers are regularly set to accept cookies. You can deactivate the use of cookies at any time via the settings of your browser. Please use the help features of your internet browser to find out how to change these settings. Please note that some features of our website may not work if you have disabled the use of cookies.

Google AdWords

Our website uses Google Conversion Tracking. If you have reached our website via an advertisement sent by Google, Google AdWords will set a cookie on your computer. The conversion tracking cookie is set when a user clicks on a Google-served ad. These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages on our website and the cookie has not expired, we and Google may recognize that the user clicked on the ad and was redirected to this page. Each Google AdWords customer receives a different cookie. Cookies cannot be tracked through AdWords advertisers’ websites. The information gathered using the conversion cookie is used to generate conversion statistics for AdWords advertisers who have opted for conversion tracking. Customers are told the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, they do not receive information that personally identifies users.

If you do not want to participate in the tracking, you can refuse the required setting of a cookie – for example via a browser setting that generally disables the automatic setting of cookies or sets your browser to block cookies from the domain “googleadservices.com”.

Please note that you cannot delete the opt-out cookies as long as you do not want to record performance data. If you have deleted all your cookies in the browser, you must set the respective opt-out cookie again.

Google Maps

This site uses the mapping service Google Maps via an API. Provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

To use the features of Google Maps, it is necessary to save your IP address. This information is usually transmitted to and stored on a Google server in the United States. The provider of this site has no influence on this data transfer.

The use of Google Maps is in the interest of an appealing presentation of our online offers and an easy findability of the places we specify on the Internet site. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR.

For more information on how to handle user data, please refer to Google’s Privacy Policy: https://www.google.com/intl/en/policies/privacy/.

Your rights to information, correction, suspension, cancellation and opposition

You have the right to receive information about your personal data stored by us at any time. Likewise, you have the right to correction, blocking or, apart from the prescribed data storage for business transactions, deletion of your personal data. Please contact our data protection officer. The contact details can be found at the bottom.

According to Art. 17 GDPR, the person in charge must take the claim for cancellation into account when:

• The purpose of the data processing has been achieved and the personal data is therefore no longer required
• The person concerned has revoked his consent and no other (statutory) legal basis for the processing within the meaning of Art. 6 para. 1 lit. b-f GDPR intervenes
• The person concerned has lodged an objection to the processing within the meaning of Art. 21 GDPR
• The personal data was unlawfully covered, i.e. not covered, collected, processed or used by Art. 6 GDPR
• The person concerned has given his consent as a minor in accordance with Art. 8 GDPR and requests the cancellation

A deletion may be lawfully refused despite the above reason for cancellation if the person responsible has a legitimate interest in the continued use of the data (Art. 17 para. 3 GDPR). This may be the case, in particular, if the continuing processing or storage is required to fulfil a statutory retention obligation and insofar there is a legal obligation (Art. 17 para. 3 lit. b GDPR) not to delete the data.

As far as such an obligation exists, we lock your data on request. You can make changes or revoke your consent by notifying us with effect for the future.

Change of our privacy policy

We reserve the right to change this Privacy Policy from time to time to ensure that it complies with current legal requirements or to implement changes to our services in the Privacy Policy, for example when introducing new services. Your next visit to our website after that will be subject to the new privacy policy.

Questions to the data protection officer

If you have any questions about data protection, please write us an email or contact our data protection officer directly:

Contact details

Van Sterling Capital Ltd.
168, St. Christopher Street
MT – Valletta VLT 1467
Phone: +356.27.289 615
www.vansterling.com
dataprotection@vansterling.com

Please also note our Privacy Policy.