RAMPARTS PRIVACY AND COOKIES POLICY
Ramparts is committed to protecting and respecting your privacy. This policy, together with any agreement we enter into with you, sets out how your personal data will be collected and processed, your privacy rights and how the law protects you.
Ramparts (our, us, we, data controller) provides a range of business services, including legal services, accountancy services and fiduciary services, and is responsible for your personal data. Details about the Ramparts group of companies are included below. If you have any questions about this policy or wish to exercise any of your rights under it you can email us at info@ramparts.eu.
The Ramparts Group (Ramparts) of companies includes:
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Rampart Corporate Support (UK) Limited (a law firm based in England and Wales) (RUK) with registered address 2nd Floor, 3 Hardman Square, Manchester, England, M3 3EB;
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Rampart Corporate Services Limited (a fiduciary business based in Gibraltar) (RFID) with registered address Office 6.20 World Trade Center, 6, Bayside Road, Gibraltar GX11 1AA, PO Box 1324; and
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Rampart Corporate Advisors Limited (a law firm based in Gibraltar) (RGIB) with registered address Office 6.20 World Trade Center, 6, Bayside Road, Gibraltar GX11 1AA, PO Box 1324.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By providing consent you are accepting and consenting to the practices described in this policy.
This website is not intended for children and we do not knowingly collect data relating to children.
INFORMATION WE COLLECT FROM YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
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Financial Data includes information about your financial position, status and history, and payment account details (can include bank, credit, payment and electronic money accounts).
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Technical Data includes details about the devices and technology you use including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or services.
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Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
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Special Types of Data include racial or ethnic origin, racial or ethnic origin, religious or philosophical beliefs, trade union membership, genetic and bio-metric and health data. We will only process such data if the law allows us to do so.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and if you fail to provide that data when requested, we may not be able to meet our regulatory obligations or perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). If you do not provide the requested information we may have to decline your application or cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW YOUR PERSONAL DATA IS COLLECTED
We use different methods to collect data about you (and your business) including through:
Information you give us:
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when you apply for, or use, our products or services;
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when you communicate with us whether by phone, post, email, online or by other means;
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when you use our websites or device applications;
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in emails, letters and other correspondence ; when you request marketing to be sent to you by us or selected third parties;
Your use of our services- The data we collect when you use our services (such as making transactions, viewing your account details or using any part of our website) includes:
Third parties. We may receive personal data about you from various third parties and public sources as set out below:
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Companies that introduce you to us;
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Public information sources such as Companies House and the Electoral Register;
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Government and law enforcement agencies; and
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Agents working on our behalf including fraud prevention agencies, analytics providers, advertisers.
HOW WE USE YOUR DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
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Where you consent to it;
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Where we need to perform the contract we are about to enter into or have entered into with you;
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Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
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Where we need to comply with a legal or regulatory obligation.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We have also included which data controllers will use, and be responsible for, your data in the manner specified.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
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Purpose/Activity
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Type of data
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Lawful basis for processing including basis of legitimate interest
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To register you as a new client, to verify your identity, to provide services to you and manage our relationship with you (e.g. inform you of changes and correspond with you including billing).
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Identity
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Contact
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Financial
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Transaction
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Marketing and Communications
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Performance of a contract with you.
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Necessary to comply with a legal obligation.
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Necessary for our legitimate interests (e.g. risk management and fraud prevention).
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Consent.
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To administer and protect our business, your information and our website, to improve our website and products/services (including troubleshooting, data analysis, testing, system maintenance, support, security, reporting, complying with our regulatory obligations and hosting of data).
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Identity
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Contact
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Technical
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Transaction
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Usage
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Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
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Necessary to comply with a legal obligation
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To collect information for recruitment purposes.
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Identity
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Contact
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Financial
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Profile
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Usage
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Necessary for our legitimate interests (e.g. recruitment).
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Consent.
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To give you, or allow selected third parties to give you, information about goods and services we think you may be interested in.
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Identity
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Contact
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Profile
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Usage
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Marketing and Communications
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Technical
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Consent.
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Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business,to inform our marketing strategy to develop new products/services and grow our business).
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MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you or your business. This is how we decide which products, services and offers may be relevant for you or your business (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.
OPTING OUT
You can ask us to stop sending you marketing messages or sharing your data with third parties for marketing purposes at any time by contacting us using the details provided above.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
WHO WE MAY DISCLOSE YOUR INFORMATION TO
You agree that we may disclose your personal information to:
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Any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries as reasonably necessary for the purposes, and on the legal basis, detailed in this policy;
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Our agents, advisors and business partners who we use to help manage your accounts and services, improve services and resolve issues such as legal disputes;
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HM Revenue & Customs, regulators and other authorities;
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Fraud prevention and credit reference agencies for the purpose of verifying your identity and ensuring the security of your account;
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Any party linked with you or your business including organisations that introduce you to us;
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Organisations we introduce you to for marketing purposes;
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Analytics and search engine providers that assist us in the improvement and optimisation of our website;
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Any insurance company for the purposes of insuring risk; and
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Other entities where we are obliged to by law or to law enforcement agencies for the purposes of registration of fraud or suspected fraud or where we have your consent.
You agree that we can and will disclose your personal information to third parties:
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In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
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If substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
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If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
In addition to the disclosures detailed in this section, we may also disclose your personal information where it is necessary to do so: for compliance with a legal obligation; in order to protect the vital interests of you or another natural person; and for the establishment, exercise or defence of legal claims.
We do not use your information to make automated decisions.
WHERE WE STORE AND TRANSFER YOUR PERSONAL DATA
All information you provide to us will be transferred and stored in a jurisdiction located in the European Economic Area (EEA). However, we may transfer some or all of your data to countries outside of the EEA which may not offer the same level of protection as the GDPR with respect to the processing of your personal data.
In compliance with the GDPR, we will only transfer data outside of the EEA if:
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there is a European Commission (EC) finding that the third country, territory, or sectors within the third country, or international organization ensures an adequate level of privacy protection Article 45(1);
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the data controller or data processor provides appropriate safeguards in accordance with Article 46(2) GDPR, namely the use of standard clauses adopted or approved by the EC can can by found on the EC’s website:
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the organisation we transfer the data to is based in the US and hey are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
For further details, see the EC’s website here.
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a derogation allowing for the transfer under Article 49 of the GDPR applies (see Identify Whether a GDPR Derogation Authorizes the Transfer); or
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the data subject explicitly consents to the transfer (see Obtaining Consent to Transfer Personal Data).
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
KEEPING AND DELETING YOUR DATA
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We keep certain data for minimum periods, namely:
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we retain Transaction Data for a minimum of seven years after the date of the transaction;
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we retain certain Contact and Financial Information, for a minimum of seven years after your agreement with us has ended;
The majority of personal data we hold will be deleted seven years after the termination of any agreement you have with us unless it is needed for other necessary or legitimate purposes.
In some circumstances you can ask us to delete your data: see request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR RIGHTS
Under the GDPR you have the right to:
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Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Please note that we also have to consider our regulatory obligations and the rights of other individuals when providing you with information and that this may mean that the information we provide is redacted or partial in some instances.
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Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
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Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
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Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
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Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of these rights you will need to contact us using the contact details above. In the case of exercising your right to access, you will also need to provide appropriate evidence of your identity.
If you decide to exercise one or more of these rights please note that it may mean that we have to terminate any agreement we have with you as we may no longer be able to provide the service you requested.
CHANGES TO OUR PRIVACY POLICY
Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.
CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to us at info@ramparts.eu.
COOKIES POLICY
Our website uses cookies to distinguish you from other users of our website. A cookie is a small file of letters and numbers that we put on your computer if you agree. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
We use the following 4 main types of cookies:
Strictly necessary cookies.These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website and enter into transactions.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
If you wish you can change your cookie settings in your browser if you would like to prevent any cookies being stored on your online enabled device, but be aware that this may severely impact the functionality of the site.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
You can contact us at privacy@ramparts.eu if you would like more information about the information we may retain related to you (e.g. on our databases) or if you have any concerns or complaints.
Ramparts is a European law firm based in Gibraltar. We are qualified to provide legal advice on English, Gibraltar and European law.
Thanks for your time.
The Ramparts Team
Ramparts is the trading name of Rampart Corporate Advisors Limited, Company registration No. 107531. Registered Office: 6.20 World Trade Center, 6, Bayside Road, Gibraltar GX11 1AA, PO Box 1324 Tel: +350 200 68450.
