Privacy Policy

PRIVACY STATEMENT
Last updated 24 May 2018

Article 1. Introduction

INTERTRUST CONSULTING is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, INTERTRUST CONSULTING is committed to the appropriate protection and use of personal information (hereinafter referred to as “personal data”,) that has been collected both online and offline.

We hereby inform you about the processing of your personal data, and your rights according to the provisions of Regulation (EU) 2016/679 – the General Data Protection Regulation (“GDPR”), the national law for the enforcement of the provisions of GDPR, as well as according to any other decision that may be adopted by the National Authority for Personal Data Processing Surveillance with respect to the protection of personal data.

Generally, we collect only the personal data that is voluntarily provided by clients or potential clients, business partners, employees, potential employees, collaborators or online visitors of our web site so that we can offer information, provide services, carry out contractual relationships, promote our services, and offer information about employment opportunities. In addition, we need to receive certain personal data in order to be able to render the services agreed upon with clients or to comply with different legal obligations.

Please review this privacy statement (“Privacy Statement”) to learn more about how we collect, use, share and protect the personal data that we have obtained.

Article 2. The legal grounds we have to use your personal information

INTERTRUST CONSULTING generally collects only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection.
The law allows us to process personal information, as long as we have a legal ground to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:

Entering into a contract: this is when the processing of your personal information is necessary for us to take steps at your request in order to enter into a contract;
Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;
Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
Legitimate interests: we will process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, as long as it doesn’t outweigh your interests; or
Your consent: in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting INTERTRUST CONSULTING at office@intertrust-consulting.com
Examples of the ‘legitimate interests’ referred to above are:

To offer information and/or services to individuals who visit our website to the extent allowed by the law or offer information about employment opportunities.
To prevent fraud or criminal activity and to safeguard our IT systems.
To customize the individual’s online experience and improve the performance usability and effectiveness of INTERTRUST CONSULTING’s online presence.
To meet our corporate and social responsibility obligations.
To exercise our fundamental rights in the EU under Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and right to property;
To maintain the security of premises and staff of INTERTRUST CONSULTING;
To conduct compulsory risk management procedures.
Article 3. Personal Data Processing Within Professional Services, Business Activities and Employment Relations

3.1. Categories of processed personal data

The categories of personal data that may be processed by INTERTRUST CONSULTING are the following:

Identification or contact personal data such as name, date of birth, nationality, series and number of the identity card, personal identification number (CNP or other), place of birth, photo, domicile, residence or correspondence address, email address, telephone number etc.;
Personal data regarding professional qualifications such as certificates/attestations/study diplomas and/or professional development diplomas;
Data localization such as remote desktop location data, GPS data;
Financial data, bank account and other payment details, salary, benefits, shares, etc.;
Civil status or family data such as number of children or other persons in care;
Electronic identification details such as IP address, cookies, web beacons, as detailed under Article 4 below;
Video or other data in connection with visitors to INTERTRUST CONSULTING’s premises.
In some cases, the personal data that we collect will also include special categories of data, such as diversity related information (including data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership and data about sexual life and sexual orientation), or health data and data about alleged or proven criminal offences in each case where permitted by law.
With respect to the special categories of data that we may process, we inform you that the legal ground on which we may rely on is (i) your consent, (ii) the legal obligation that we have to process such categories of data, or (iii) the processing is necessary for the establishment, exercise or defense of legal claims.

3.2. Categories of data subjects and purposes for the processing of personal data

Web site visitors – As detailed under Article 4 below.

Business Contacts
INTERTRUST CONSULTING collects and processes the personal data of potential, current and past business partners and contacts from such data subjects directly or from third parties, for the purpose of continuing, establishing and renewing communication with those business partners and contacts under the legal grounds of either (i) consent (ii) legitimate interest.

Clients and data subjects associated with clients
INTERTRUST CONSULTING collects and processes the client’s personal data, or personal data of the client’s representatives, contact persons, client’s personnel, including collaborators for, among others, the following purposes: (i) providing professional services – in order to establish, carry out and terminate the contractual relationship; (ii) conducting compulsory risk management formalities – in order to implement an effective global/regional risk assessment process that monitors and identifies mitigation solutions for key risk areas, to build an ethics and compliance culture consistent with INTERTRUST CONSULTING’s core values, protect the brand and reputation of INTERTRUST CONSULTING, and act in accordance with the ethical and other professional standards expected of a professional service provider; (iii) providing, on the basis of consent, clients with newsletters and/or other marketing materials – to this extent, INTERTRUST CONSULTING provides business contacts with periodical newsletters, information relating to INTERTRUST CONSULTING’s professional services and products, events and activities, etc.; (iv) for INTERTRUST CONSULTING’s compliance with the obligations imposed by the law and by the regulatory bodies to which INTERTRUST CONSULTING is subject, such as anti-money laundering and anti-terrorism financing obligations, the obligation to report to the tax authorities; (v) analysing and improving our services and communication to you, including conducting surveys on clients’ satisfaction regarding the services rendered by INTERTRUST CONSULTING; (vi) exercising or defending our legal rights, or to comply with court orders. INTERTRUST CONSULTING collects personal data directly from clients or from third parties which are acting on behalf of clients.

The processing for these purposes is concluded, as appropriate, under one or more of the following legal grounds: (i) your consent, (ii) for the purpose of entry into or performance of a contract; (iii) the legal obligation that we have to process such categories of data, or (iv) our legitimate interest (v) the processing is necessary for the establishment, exercise or defense of legal claims.

Suppliers and subcontractors
INTERTRUST CONSULTING collects and processes personal data relating to its suppliers, including subcontractors, and the personal data of their representatives, and contact persons, strictly for the performance of the contractual relationship.

INTERTRUST CONSULTING collects and processes the suppliers/subcontractors’ personal data for the following purposes: (i) providing professional services to clients through subcontractors, (ii) for the performance of the contract concluded by INTERTRUST CONSULTING with suppliers, (iii) conducting compulsory risk management formalities (iv) providing suppliers/subcontractors with newsletters and/or other marketing materials (v) to exercise or defend our legal rights, or to comply with court orders; (vi) to comply with the obligations imposed by the law and by the regulatory bodies which we are subject to. The processing for these purposes is concluded, as appropriate, under one or more of the following legal grounds: (i) your consent, (ii) for the purpose of entry into or performance of a contract; (iii) the legal obligation that we have to process such categories of data, or (iv) our legitimate interest (v) the processing is necessary for the establishment, exercise or defense of legal claims.

Employment Candidates
INTERTRUST CONSULTING collects and processes candidates’ personal data as included in the CV and cover letters submitted to us, as well as any other potential information provided to us.
To this extent, INTERTRUST CONSULTING processes such personal data strictly for the purpose of conducting the selection, recruitment and hiring process or for the organization of internships, based on consent.

Visitors to INTERTRUST CONSULTING’s premises
INTERTRUST CONSULTING has in place security measures, including registration at the reception, CCTV and, if necessary, identification of the visitors by our security personnel. INTERTRUST CONSULTING collects and processes visitors’ personal data for the purpose of ensuring the security of INTERTRUST CONSULTING’s premises, assets and personnel. The processing for these purposes is concluded, as appropriate, under one or more of the following legal grounds: (i) the legal obligation that we have to process such categories of data, or (ii) our legitimate interest.

Article 4. Personal Data Processing within the usage of this website

4.1. The protection of personal data on our website
The protection of your privacy while using our website is extremely important for us. Accordingly, we wish to provide you with detailed information regarding the processing of personal data.

4.2. Data security and integrity
INTERTRUST CONSULTING has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite INTERTRUST CONSULTING’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.
In order to protect your data, we have adopted technical and organizational measures, especially against loss, tampering or unauthorized access. The measures adopted are regularly verified and are adapted constantly in accordance with the latest applicable technical standards.

4.3. The collection and processing of personal data

Data provided by you
We obtain personal data about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you will have previously provided your personal information to INTERTRUST CONSULTING (if, for example, you are a former employee). If you choose to register or login to a INTERTRUST CONSULTING web site using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, or Twitter) with INTERTRUST CONSULTING, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect will depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.

When you register or submit personal data to INTERTRUST CONSULTING we will use this information in the manner outlined in this Privacy Statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register on a INTERTRUST CONSULTING web site and provide information about your preferences we will use this information to personalize your user experience. Where you register or login using a third party single user sign-in we may also recognize you as the same user across any different devices you use and personalize your user experience across other INTERTRUST CONSULTING sites you visit. If you send us a resume or curriculum vitae (CV) to apply online for a position with INTERTRUST CONSULTING, we will use the information that you provide to match you with available INTERTRUST CONSULTING job opportunities.

In some cases where you have registered for certain services we will store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).

Automatic collection of personal information
In some instances, INTERTRUST CONSULTING and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of INTERTRUST CONSULTING’s online presence, and to measure the effectiveness of our marketing activities.

IP addresses
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses from which visitors appear to originate will be recorded for IT security and system diagnostic purposes. This information will also typically be used in aggregate form to conduct web site trend and performance analysis.

Cookies
Cookies will typically be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.

On some of our web sites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as “user-input” cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser’s cookies.

Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites’ features.

Further information about managing cookies can be found in your browser’s help file or through sites such as www.allaboutcookies.org.

Below is a list of the types of cookies used on our web sites:

Purpose Description Type & Expiry
Performance (i.e. User’s Browser) Our web sites are built using common internet platforms. These have built-in cookies which help compatibility issues (e.g., to identify your browser type) and improve performance (e.g., quicker loading of content). Session
Deleted upon closing the browser
Security (e.g. Asp .NET) Cookies If you register for access to a restricted area, our cookies ensure that your device is logged for the duration of your visit. You will need your username and password to access the restricted areas. Session
Deleted upon closing the browser
Site Preferences Our cookies may also remember your site preferences (e.g., language) or seek to enhance your experience (e.g., by personalizing a greeting or content). This will apply to areas where you have registered specifically for access or create an account. Session
Deleted upon closing the browser
Analytical We use several third party analytics tools to help us understand how site visitors use our web site. This allows us to improve the quality and content on intertrust-consulting.com for our visitors. The aggregated statistical data covers items such as total visits or page views, and referrers to our web sites. For further details on our use of Google Analytics, see below. Persistent, but will delete automatically after two years if you no longer visit intertrust-consulting.com
Site visitor feedback We use a third party survey tool to invite a percentage of visitors to provide their feedback. Cookies are used to prevent visitors from being invited multiple times.
The first cookie (1) is set if the visitor is not invited to participate in the survey, and is used to ensure visitors are not invited after their first page view.
The second cookie (2) is set if the visitor is invited to participate in the survey, and is used to ensure the visitor is not invited again to participate for a period of 90 days. 1. Session
Deleted upon closing the browser2. Persistent
Deleted automatically after 90 days or presenting survey invite.
Social sharing We use third party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed on our webpages (e.g. the social share count cache is updated) and log information about your activities across the Internet and on our web sites. We encourage you to review each provider’s privacy information before using any such service. For further details on our use of social media widgets and applications, see below. Persistent, but will be deleted automatically after two years if you no longer visit intertrust-consulting.com

Other third party tools and widgets will be used on our individual web pages from time to time to provide additional functionality. Use of these tools or widgets will typically place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.

Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we will obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.

BY NAVIGATING ON OUR WEB SITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.

Google Analytics
INTERTRUST CONSULTING uses Google Analytics. More information about how Google Analytics is used by INTERTRUST CONSULTING can be found here: http://www.google.com/analytics/learn/privacy.html

To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

Web beacons
A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. INTERTRUST CONSULTING only uses web beacons in accordance with applicable laws.
INTERTRUST CONSULTING or its service providers will use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.

In some of our newsletters and other communications, we will monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

Location-based tools
INTERTRUST CONSULTING will collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

Social media widgets and applications
INTERTRUST CONSULTING web sites will typically include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications will collect and use information regarding your use of INTERTRUST CONSULTING web sites (see details on ‘Social Sharing’ cookies above). Any personal information that you provide via such social media applications will often be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, INTERTRUST CONSULTING web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any INTERTRUST CONSULTING social media feature will typically be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we often have limited or no control.

Children
INTERTRUST CONSULTING understands the importance of protecting children’s privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.

Choices
In general, you are not required to submit any personal information to INTERTRUST CONSULTING, but INTERTRUST CONSULTING will also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

As described in “Cookies” above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

Links to other sites
Please be aware that INTERTRUST CONSULTING web sites will typically contain links to other sites, including sites maintained by other INTERTRUST CONSULTING member firms that are not governed by this Privacy Statement but by other privacy statements that will often differ somewhat. We encourage users to review the privacy policy of each Web site visited before disclosing any personal information.

All processing activities as mentioned in this Article are concluded, as appropriate, under one or more of the following legal grounds: (i) your consent, (ii) for the purpose of entry into or performance of a contract; (iii) the legal obligation that we have to process such categories of data, or (iv) our legitimate interest (v) the processing is necessary for the establishment, exercise or defense of legal claims. By registering on any INTERTRUST CONSULTING web site and then navigating to another INTERTRUST CONSULTING web site while still logged in, you agree to the use of your personal information in accordance with the Privacy Statement of the INTERTRUST CONSULTING web site you are visiting.

Article 5. Sharing and transfer of personal information

5.1. Transfer within the network of INTERTRUST CONSULTING firms

We share information about you with other member firms of the INTERTRUST CONSULTING network as part of international engagements, and with INTERTRUST CONSULTING International and other member firms where required or desirable to meet our legal and regulatory obligations around the world. Other parts of the INTERTRUST CONSULTING network are also used to provide services to us and you, for example hosting and supporting IT applications, provision of certain forms of insurance for member firms and their clients, performing client conflicts checks and Anti-Money Laundering checks, assisting with client engagement services and otherwise as required in order to continue to run INTERTRUST CONSULTING’s business.

5.2. Transfers to third parties

We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. This includes:

Our service providers: we transfer your personal information to our third party service providers, such as our (IT) systems providers, our hosting providers, our payroll providers, consultants (such as legal advisers) and other suppliers and services providers. INTERTRUST CONSULTING works with such providers so they can process your personal information on our behalf. INTERTRUST CONSULTING will only transfer personal information to them when they meet our strict standards on the processing of data and security. We only share personal information that allows them to provide their services.
If we are reorganized or sold to another organization: INTERTRUST CONSULTING will typically also disclose personal information in connection with the sale, assignment, or other transfer of any element of INTERTRUST CONSULTING’s business to which the personal information relates.
Courts, tribunals, law enforcement or regulatory bodies: INTERTRUST CONSULTING will disclose personal information in order to respond to the requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government or professional regulations.
Audits: disclosures of personal information will also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.
Insurers: our professional rules and our business requirements mean that we carry significant insurance cover in respect of business activities (our ‘insurance programme’). This is required in order to assist each member firm of the INTERTRUST CONSULTING network to cover the costs associated with claims which may arise in the event that it is alleged that something has gone wrong during the course of providing services to clients. In order to make the insurance programme work effectively, the insurance programme involves a number of different participants in the insurance market (e.g. brokers, insurers and reinsurers, as well as their professional advisors and other third parties involved should there be a claim). Some of these insurance market participants will require that we disclose personal information about you to them. The information will be used by the insurance market participants in the underwriting and ongoing administration of the insurance programme, where there is a claim that relates to you, and in order to allow the insurance market participants to comply with their legal and regulatory obligations. Some of these insurance market participants will handle this information on our behalf (like our service providers described above), but others will want to process information about you independently of us.
In addition, INTERTRUST CONSULTING will transfer certain personal information outside of the EEA to outside companies working with us or on our behalf for the purposes described in this Privacy Statement. INTERTRUST CONSULTING may also store personal information outside of the EEA. If we do this your personal information will continue to be protected by means of contracts we have in place with those organizations outside the EEA, containing standard data protection clauses which are in a form approved by the European Commission.

INTERTRUST CONSULTING will not transfer the personal information you provide to any third parties for their own direct marketing use. All processing activities as mentioned in this Article are concluded, as appropriate, under one or more of the following legal grounds: (i) your consent, (ii) for the purpose of entry into or performance of a contract; (iii) the legal obligation that we have to process such categories of data, or (iv) our legitimate interest (v) the processing is necessary for the establishment, exercise or defense of legal claims.

Article 6. Your rights

If INTERTRUST CONSULTING processes personal information about you, you have the following rights:

Information: you have the right to be informed on the personal data processing operations carried out by INTERTRUST CONSULTING.
Access: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal information.
Correction: If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.
Deletion: you have the right to require INTERTRUST CONSULTING, without unjustified delays, to erase your personal data, in the following circumstances:
– your personal data is no longer required for the accomplishment of the purposes for which it has been collected or processed by INTERTRUST CONSULTING;
– you withdraw the consent based on which the personal data processing has taken place;
– you object to the personal data processing based on legitimate interests and there are no overriding legitimate grounds for the processing;
– you object to the personal data processing based on direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing;
– your personal data has been unlawfully processed;
– your personal data has to be erased for compliance with a legal obligation which binds INTERTRUST CONSULTING.

Restriction of processing: you have the right to require INTERTRUST CONSULTING to restrict processing where one of the following applies:
– the accuracy of your personal data is contested by you, for a period enabling INTERTRUST CONSULTING to verify the accuracy of the personal data;
– the processing is unlawful and you oppose the erasure of your personal data and request the restriction of its use instead;
– INTERTRUST CONSULTING no longer needs the personal data for the purposes of the processing, but the data is required by you for the establishment, exercise or defense of legal claims;
– you object to the processing based on legitimate interests, pending the verification of whether the legitimate grounds of INTERTRUST CONSULTING override your legitimate interests.

Portability: you have the right to receive your personal data provided to INTERTRUST CONSULTING, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller, if the technical means allow for such an operation. You have such a right when the personal data processing is based on your consent or when the processing is carried out by automated means.
Objection: you have the right to object, on grounds relating to your particular situation, to the processing based on the legitimate interests of INTERTRUST CONSULTING. INTERTRUST CONSULTING shall no longer process your personal data unless it demonstrates compelling legitimate interests for the processing, which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
Automated individual decision-making including profiling: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects upon you or similarly significantly affects you.
Lodge claims: you have the right lodge a complaint with the competent authority in charge of protecting personal information, the National Authority for Personal Data Processing Surveillance.
You can make a request or exercise these rights by contacting INTERTRUST CONSULTING at office@intertrust-consulting.com and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

Article 7. Retention period

INTERTRUST CONSULTING has implemented technical and organizational measures for the retention of your personal data. Thus, we shall retain your personal data in accordance with the provisions of the Retention Data Policy applicable at the level of INTERTRUST CONSULTING.

However, we will cease to process any of your personal data as long as it is not required for the purposes established or when you withdraw your consent, this being the legal basis for the processing, and (i) there are no compelling legitimate grounds for INTERTRUST CONSULTING to continue the processing which override your interests, rights and freedoms or (ii) if the personal data is no longer required for the establishment, exercise or defense of legal claims.

Article 8. Changes to this statement

INTERTRUST CONSULTING may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. Any changes to the processing of personal data as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

Article 9. Policy questions and enforcement

INTERTRUST CONSULTING is committed to protecting the privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at office@intertrust-consulting.com. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.

We will acknowledge your email within 14 days and seek to resolve your concern within one month of receipt. Where the concern is complex or we have a large volume of concerns, we will notify you that the concern will take longer than one month to resolve, and we will seek to resolve your concern within three months of the concern first being raised. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ Article above), or we may reject your concern on legitimate grounds. You may also lodge a complaint with the local Data Protection Authority at the following contact details:

The National Supervisory Authority For Personal Data Processing
Address:
28-30 G-ral Gheorghe Magheru Bld., District 1,
Post Code 010336, Bucharest, Romania
Email: anspdcp@dataprotection.ro,
Telephone number: +40.318.059.211
Website: http://www.dataprotection.ro/index.jsp?page=contact&lang=en

*1 “INTERTRUST CONSULTING,” “we,” “our,” and “us” refer to INTERTRUST CONSULTING S.R.L. and/or to any one or more of the member firms of the INTERTRUST CONSULTING network of independent firms affiliated with INTERTRUST CONSULTING. In this respect for Romania there are the following entities:

EXCELERA FINANCIAL SERVICES S.R.L.

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