Effective date: 14 September 2018
The International Trade Council (“we”) are committed to securely maintaining and respecting your privacy.
Content means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of this Web Site, our blogs and our social media pages.
Controller means a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing of Personal Data.
Customer means an individual, legal person (corporate, partnership or otherwise), group of people to whom we supply goods and services either ongoing or on a “once only” basis.
GDPR means the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time.
Personal Data means any information relating to an identified or identifiable natural person.
Processing means any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Services means collectively any online facilities, tools, services or information that the International Trade Council makes available through this website either nor or in the future.
System mans any online communications infrastructure that the International Trade Council makes available through this website either now or in the future. This includes, but is not limited to, email, CRM system, message boards, live chat facilities and email links.
Users means any third party that accesses this website, email, CRM system, message boards, live chat facilities and email links and is not employed by the International Trade Council and acting in the course of their employment.
Website means the website that you are currently using (https://www.formationsadvice.com) and any sub-domains of this site unless expressly excluded by their own terms and conditions.
We, us, our and ourselves refers to the International Trade Council.
2. Important Information
This privacy notice aims to give you information on how the International Trade Council collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service or sign up to our newsletter. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
The International Trade Council
Email address: firstname.lastname@example.org
Postal address: The International Trade Council. 712H Street NE. #1110. Washington DC 20002. United States of America
Telephone number: +1 202 869 0988
Fax number: +1 202 869 1121
We would appreciate the chance to deal with any of your your concerns so please contact us if you have any queries.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on the 14th of September 2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
3. How we collect your data
- Direct interactions. You may give us your Identity, Contact, Personal and Financial Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties [and public sources] as set out below
- Technical Data from analytics providers such as Google;
- Identity and Contact Data from publicly availably sources such as government registries and electoral registries contained within the EU and outside of it.
4. The Data we collect about you
Although the International Trade Council provides business services to legal entities, there are different categories of Personal Data that we may collect about 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).
Some Personal Data is collected automatically while you visit this website.
Due to the nature of company formations and related services presented on this website, you are required by law to provide certain Personal Data which is legally mandatory for receiving those Services.
When you make an enquiry or order Services, you are required to provide certain personal information, such as your name, e-mail address, telephone number, address and credit card number or other billing information, for preparing the offer and making the payment for the ordered Services.
Your credit card details are encrypted and securely stored by payment service providers. Our payment service providers are Stripe.com and Paypal.com. Please review their privacy notices for information on how they handle and store your credit card information.
Categories of data
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth. This information may include scanned copies of your passport and or other forms of government issued identification.
- Contact Data includes billing address, delivery address, email address, and telephone numbers.
- Financial Data includes bank account details, bank statement(s), and payment card details.
- Transaction Data includes details about payments from you and other details of products and services you have purchased from us.
- Technical Data includes 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 this website.
- Profile Data includes your username and password, purchases or orders made by you, your preferences.
- Usage Data includes information about how you use our website, products, and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Aggregate Data includes statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Information we may collect from you
To provide services and information you request, you consent, and we will collect the following information from you:
- When you require a service from us: Information that you enter in the application forms on our site or provide to us by verbal or written communication. We will use this information to process your orders or respond to your enquiries. Our Email, Chatbox, Efiling ,Sharefile and ordering systems all store the information you give us. You have the right to withdraw consent at any time by asking us to delete the information stored in our Email, Chatbox, Efiling ,Sharefile and ordering systems.
- To comply with Anti Money Laundering regulations: We may ask for various documents to verify your ID and address. This specific regulation means that we must hold and retain records for seven years after ceasing to provide the service. This data is GDPR Compliant and secured on our server located outside the EU. It is never shared or sold however we may be required to provide these documents to various government agencies, mail service providers, notaries, attorneys, accountants, law firms, registered agents, financial service providers and banks to fulfill your service requests.
- When you carry out transactions on our site: Details of those transactions will be stored in the portal and our CRM and email system. You have the right to withdraw consent at any time. Deleting your account will leave the order in place but your contact details will be deleted with the exception of those which we are required to maintain in order to comply with Anti Money Laundering regulations.
- When you contact us by email: We will keep a record of that correspondence. This will be stored on our email system and in our CRM. You have the right to withdraw consent at any time by asking us to delete these mails.
- When you visit our website: Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access. This will be stored: on our Google Analytics account.
We may collect information about your computer including, where available, your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
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. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the International Trade Council for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase.
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.
Legal basis for processing the data
Your data is used for the following purposes:
Providing the Services
Your Personal Data (e.g. your name, contact details, personal identification documents etc) is processed to be able to provide you the Services. Since some of the Services provided by the International Trade Council are regulated services, clients are also obligated by law to provide the service provider with certain Personal Data.
Failure to provide Personal Data by clients as required by law shall result in not being able to fulfill the contract or even in refusing the Services.
Legal basis: performance of a contract; compliance with a legal obligation.
Improving the Services
Legal basis: consent; legitimate interests.
Providing client support
Your Personal Data (e.g. your name and e-mail address or phone number) is processed to contact you for administrative purposes such as customer service, billing matters and responding to your enquiries.
Legal basis: performance of a contract.
Marketing and keeping you informed about the Services and news
If you are interested in receiving offers, information and news regarding the Services, you may subscribe to the International Trade Council newsletter by providing us with your e-mail address.
The International Trade Council uses your e-mail address provided upon subscription only for sending you the newsletter. You can unsubscribe from receiving the newsletter anytime or ask the International Trade Council to delete your e-mail address from the list of recipients anytime.
Legal basis: legitimate interests; consent.
The International Trade Council generally does not process Personal Data based on consent. However, occasionally your consent may be required (e.g. for processing information through certain cookies placed on the Website).
Your Personal Data may also be processed as may be described in a separate privacy notice provided to you at the time the information is collected, or in other manner to which you consent.
The International Trade Council can rely on legitimate interests for processing of your Personal Data, provided those interests are not outweighed by your rights and interests. Legitimate interests pursued by the International Trade Council are identified above under the purposes of processing.
5. How we use your Personal 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:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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.
- Where we need to comply with a legal or regulatory obligation.
Because the types of services provided by us on this website we generally do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Categories of recipients of personal data
The International Trade Council is not able to provide you with the quality Services without using third party service providers. Therefore, your personal information will be disclosed to the third-party service providers used by the International Trade Council. The International Trade Council uses third party service providers of the following services:
- Website hosting
- Payment gateways
- IT support
- CRM software
- Sales and marketing software
- Accounting software
- Company registration services
- Registered agent services
- Virtual office / virtual mail services
- Telephone and fax number services
- Banking and financial services
- Accounting services
- Mail forwarding / package reception / package forwarding services
- Social media, advertising and analytics
- Other third-party service providers required to fulfill the provision of a service that you have ordered
Third party service providers are provided only with such information that is reasonably necessary for performing their services and selected service providers guarantee their compliance with the applicable data protection legislation. Third party service providers are independent from the International Trade Council and have their own privacy notices. Please contact us for further information by e-mail email@example.com
The International Trade Council may disclose your personal information to the state authorities if so required by applicable law.
6. Data storage
All information you provide to us is stored on our servers (see above: Information we may collect from you). Any payment transactions will be encrypted using SSL technology, and processed by an external payment processor(s). Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Data storage periods
Where the International Trade Council processes Personal Data for being in compliance with a legal obligation, the data shall be kept for the period of 5-10 years from the end of the contract for Services. The exact mandatory period for keeping the client data depends on the location of the provider of the Services and the various Anti-Money-Laundering and applicable Tax law(s).
We retain all information you submit to us within a reasonable period of time for backups, archiving, prevention of fraud, protecting our legal interest or otherwise where we have a legitimate reason for retention. All data other than required by law shall be deleted after 6 months from providing it to the International Trade Council.
Security of personal data
To protect your Personal Data the International Trade Council take reasonable precautions and follow industry’s best practices to make sure your data is not lost, misused, accessed, disclosed, altered or destroyed.
The International Trade Council have implemented several security features for keeping your data secure, including:
using SSL technology and the encryption of personal data,
using pseudonymisation where appropriate,
using secure servers, firewalls and passwords,
using trusted third-party service providers,
instructing natural person who has access to Personal Data to process the data on instructions from the Controller, unless such processing is regulated by law.
We have limited the number of persons who have access to the Personal Data to those directly involved in providing the Services.
In case of suspicion of unauthorised use, disclosure, alteration or transfer of your data, please report immediately to us by e-mail firstname.lastname@example.org.
Where a Personal Data breach occurs, the Controller shall notify the breach to the supervisory authority and clients within 72 hours after having become aware of the breach, unless the Personal Data breach is unlikely to result in a risk to the rights and freedoms of natural persons.
7. Your legal rights
Right of access to your data: you have the right to obtain information if your Personal Data is processed and if so then to have access to it.
Right to amend your data: you have the right to require your incorrect Personal Data to be corrected.
Right to object: you have right to object to processing of your Personal Data if the use of your Personal Data is based on legitimate interests, including profiling for direct marketing purposes.
Right to transfer of your data: in certain cases, you have the right to receive your data in a structured, commonly used format and have the right to transmit those data directly to another service provider.
Right to erasure of your data: in certain cases, you have the right to have your Personal Data deleted.
Right to restrict processing of your data: in certain cases, you have the right to restrict the processing of our Personal Data.
Right to withdraw consent: you have the right to withdraw consent for processing of your Personal Data.
Automated processing: you have the right not to be subject to a decision based solely on automated processing, including profiling if such decision-making has legal effects or similarly significantly affects you.
Right to lodge a complaint: If you wish to exercise your rights or if you believe your right to privacy granted by applicable data protection laws has been breached, please contact us via e-mail email@example.com You also have the right to lodge a complaint with data protection authority if you think that our processing of your Personal Data infringes your rights.