PRIVACY STATEMENT

Effective Date: from 25 May 2018

Geoswift Limited and its subsidiaries and affiliates (“Geoswift”, “we”, “us”, “our”, and similar terms) respects your privacy and values the confidence of its clients, partners, and employees.

This Privacy Statement explains how particular companies in the Geoswift Group collect, process and disclose your personal data, and your rights in relation to the personal data it holds.

Geoswift complies with the data protection principles and all relevant provisions of the Hong Kong Personal Data (Privacy) Ordinance and the EU General Data Protection Regulation 2016/679 (the “GDPR”).  Geoswift acts both as data controller and data processors under the GDPR.

 This Privacy Statement supersedes any previous Privacy Policy or equivalent which you may have been provided with or seen prior to the Effective Date stated above.

Your rights

 Under the regulation you have the following rights:

  • To obtain access to, and copies of, the personal data that we hold about you;
  • To require that we cease processing your personal data if the processing is causing you damage or distress;
  • To require us not to send you marketing communications;
  • To require us to erase your personal data;
  • To require us to restrict our data processing activities;
  • To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
  • To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. You can find out more about your rights at https://www.eugdpr.org. and https://www.pcpd.org.hk/

If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please fill up the Subject Access Request (“SAR”) form and contact us using the following:

  • By post – Attention: Data Protection Officer, Geoswift UK Limited,1925 Portland House, Bressenden Place, London, SW1E 5RS United Kingdom
  • By email – [email protected]

How we collect your data

 We collect your personal data in a number of ways, for example:

  • From information about you provided to us by your company or an intermediary;
  • When you communicate with us by website (http://www.geoswift.com/ and https://www.paytuitionnow.com/), telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
  • When you complete the client on-boarding or application or other forms;
  • From other companies in the Geoswift Group;
  • From publicly available sources or from third parties, most commonly where we need to conduct background checks about you.

The categories of personal data we collect

 We collect the following categories of personal data about you:

  • Your name and contact information such as your home or business address, email address and telephone number;
  • Biographical information which may confirm your identity including your date of birth, tax identification number and your passport number or national identity card details, country of domicile and/or your nationality, country of tax residency; and
  • Information to assess whether you may represent a politically exposed person or money laundering risk. This might include details on source of wealth.

The basis for processing your personal data (other than with your consent), how we use that personal data and whom we share it with

 (i) Performance of a contract with your company

 We process your personal data because it is necessary for the performance of a contract to which you your company is a party or in order to take steps at its request prior to entering into a contract.

In this respect, we use your personal data for the following:

  • To prepare a proposal regarding the services we offer;
  • To provide your company with the services;
  • To deal with any complaints or feedback you may have;
  • For any other purpose for which you provide us with your personal data.

In this respect, we may share your personal data with or transfer it to the following:

  • Other companies in the Geoswift Group;
  • Third parties whom we engage to deliver the services to you;
  • Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
  • Other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you;
  • Our data storage providers.

(ii) Legitimate interests

 We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person.

In this respect, we use your personal data for the following:

  • For marketing to you. In this respect, see the separate section on Marketing below;
  • Training our staff or monitoring their performance;
  • For the administration and management of our business, and archiving or statistical analysis;
  • Seeking advice on our rights and obligations, such as where we require our own legal advice.

In this respect, we will share your personal data with the following:

  • Our advisers or agents where it is necessary for us to obtain their advice or assistance;
  • With third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.

(iii) Legal obligations

 We also process your personal data for our compliance with a legal obligation which we are under. In this respect, we will use your personal data for the following:

  • To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws;
  • As required by tax authorities or any competent court or legal authority.

In this respect, we will share your personal data with the following:

  • Our advisers where it is necessary for us to obtain their advice or assistance;
  • Our auditors where it is necessary as part of their auditing functions;
  • With third parties who assist us in conducting background checks;
  • With relevant regulators or law enforcement agencies where we are required to do so.

Marketing

 We also process your personal data for our marketing purposes.

We will send you marketing about similar services we provide, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you.

We will communicate this to you in a number of ways including by post, telephone, email, SMS or other digital channels.

If you object to receiving marketing from us at any time, you can contact us by email [email protected].

Cookies and tracking technologies

 A “cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate our websites and the internet and helps us provide better services to you and tailor certain content.

Cookies may collect personal information about you. Cookies help us remember information about your visit to our website, like your country, language and other settings and searches. The Cookies will be used in following aspects:

  • Essential cookies.These are cookies that are set throughout our website. They include, for example, cookies that enable you retain information between pages on the website, so you don’t have to re-enter the information.
  • Analytical/performance cookies.They allow us to recognize 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.
  • Targeting/Advertising cookies.These cookies record your visit to our website, the pages you have visited and the links you have followed. This information enables us to remember your preference and provide the personalized content.

For more information on how we use cookies please read our Cookie Policy, where you can also find information so you can delete cookies or block certain types of cookie. You should note that this may have an impact on our ability to provide the services to you.

 

Retention of your data

 We will only retain your personal data for as long as we have a lawful reason to do so. In particular:

  • where we have collected your personal data as required by anti-money laundering legislation, including for identification, screening and reporting, we will retain that personal data for seven years after the termination of our relationship, unless we are required to retain this information by another law or for the purposes of court proceedings; or
  • otherwise, we will in most cases retain your personal data for a period of five years after the termination of our contractual or other relationship with you in case any claims arise out of the provision of our services to you.

Our Privacy and Data Compliance Officer is contactable by email at [email protected]