DATA PROTECTION NOTICE
We, at Centaur, respect your right to privacy and we seek to comply with our obligations under all applicable data protection laws and regulations, including Regulation (EU) 2016/679 (the General Data Protection Regulation) (the “Regulations”). There are no policy waivers or exceptions.
In this data protection notice, we explain how Centaur collects personal data about you, how we use it and how you can communicate with us regarding your personal data.
2. Centaur Group
In this notice, “we”, “us”, “our” “Centaur” or “Centaur Group” refers to the Centaur Group of companies which includes Centaur Fund Services Limited, Centaur Fund Services (Luxembourg) S.A., Centaur Fund Services (Bermuda) Limited, Centaur Fund Services (Cayman) Limited, Centaur Fund Services US, Inc., Centaur Fund Services (Canada) Limited, Centaur FS Limited, Centaur Financial Limited, and any other affiliates and their respective parent and subsidiary companies which may be incorporated from time to time. For more information about the Centaur Group, please visit: www.Centaurfs.com.
3. Data Controllers and Processors
4. Data Protection Officer and How to Contact Us
Our Data Protection Officer is based in Ireland. The Data Protection Officer oversees how we collect, use, share and
protect your personal data to ensure your rights are fulfilled and that Centaur complies with the Regulations. You
can contact our Data Protection Officer by:
- Email: DPO@centaurfs.com
- Post or In Person: Data Protection Officer, Centaur Fund Services Limited, 2nd Floor, 2 Custom House Plaza, Harbourmaster Place, IFSC, Dublin, D01 V9V4, Ireland.
- Telephone: 00353 1 899 2400
Centaur Fund Services Limited is the EU Representative for all non‐EU entities within the Centaur Group, where required.
5. How we collect information
We may collect personal data from you, for example, if you or your business has engaged our services or if you or an organisation with which you are connected, invest in a product for which we have been engaged to provide services.
We may collect personal data from you in connection with an application or offer of employment and where relevant, as an employee at Centaur. We may also collect personal data through our marketing and social media channels. We may record phone/online conversations but, where this is the case, we will always make you aware of this before doing so.
We may collect personal data from you if we engage you or your business as a service provider or in instances where we need to work in partnership with you or your business to provide our services.
As part of our due diligence on customers, potential customers, contractors, service providers, employees and job applicants, we may carry out information searches and may take steps to verify your identity in accordance with applicable legislation. We do this by requesting the relevant information from you and where necessary, by checking your details against due diligence and risk profile databases provided to us by third parties.
6. Types of data we collect and how we use it
We will process any personal information you provide to us for the following purposes:
- to provide you with the services you have requested;
- to contact you in connection with a service request;
- to respond to any communications, you might send to us;
- to perform our duties under a service contract to which you are a party, or to which you are a connected party;
- to comply with applicable laws and regulations;
- to communicate with you about Centaur activities or services;
- to perform our duties as an employer;
- to communicate with you as a prospective or former employee; and
- to monitor the provision of services and/or business relationship between Centaur and you/your organisation.
7. Information safeguarding
We have security measures in place to protect your personal data, in accordance with applicable laws and regulations and industry standards. We also keep our IT platform, files and buildings secure.
If you choose to contact us to ask about your personal data, we will need to establish and where necessary, verify your identity before it can be provided. This is to help protect your data.
Your personal data is held in secure locations, for example on secure servers or secure office storage facilities. We cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your personal data once we have received it.
8. Information retention
9. Compliance with our legal and regulatory obligations
For Centaur to use your information lawfully, we may rely on one or more of the following legal bases:
- performance of a contract
- legal obligation
- legitimate interest
Our legitimate interests may include the below;
- the establishment, exercise or defence of legal claims;
- to manage and administer the Centaur Group’s business, to improve and manage relationships with employees and other stakeholders and for marketing and business development activities and analysis;
- to communicate with you in respect of your relationship with the Centaur Group;
- for risk assessment and risk management purposes, for statistical and trend analysis, for system administration, operation, testing and support and to operate control systems and management information systems;
- to help detect, prevent, investigate, and prosecute fraud or other criminal activity;
- to manage the Centaur Group’s information technology platforms and to ensure the security of the Centaur Group’s systems;
- to disclose information to a governmental, tax or regulatory body, financial market, broker or other intermediaries, counterparties, court, auditors or other third parties, and;
- to investigate and respond to any complaints about the Centaur Group, to help maintain quality and to deal
with such complaints and disputes.
In order to fulfil our legal and regulatory obligations, we may need to collect your personal data, verify it and keep it up to date by performing ongoing reviews. We may also gather information/ personal data about you from publicly available sources, and from third parties to help us fulfil our legal and regulatory obligations.
11. Providing your information to third parties
Centaur does not share your personal data routinely with third parties, however it may be necessary to do so, in certain circumstances, to assist with the performance of a contract, for example when administering payroll, or when complying with audit or regulatory requests from authorised third parties. We will always ensure that your data is transferred securely in these situations.
We may provide non‐personal data to third parties, where such information is combined with similar information about other users of our web site.
Centaur may need to share personal data with third parties to comply with applicable laws, regulations or lawful requests. When we believe we have been given false, fraudulent or misleading information, or if we suspect criminal activity, we may have a duty to inform the relevant law enforcement agencies, which may be either in or outside the European Economic Area (EEA).
12. Transferring data internationally
13. Your rights regarding your personal data.
You have various rights under the regulations in respect of your personal data. These include:
- the right to request access to your personal data;
- the right to have your personal data rectified;
- the right to have your personal data erased;
- the right to request that your personal data is only used for specific purposes;
- the right to object to your personal data being processed (if the lawful basis for processing your personal information is the legitimate interest of the Centaur Group), for example, for marketing;
- the right to object to any automated decision making, where applicable;
- the right to require certain aspects of your personal data to be transferred to you or a third party (in certain circumstances).
- the right to lodge a complaint with the relevant data regulator in your jurisdiction and;
- in certain circumstances the right to compensation because of a breach of data protection.
Your rights can be exercised by contacting our Data Protection Officer using the contact details given above.
14. Sale of business
15. Making a complaint
If you have a complaint about Centaur’s use of your personal data, please contact Centaur’s Data Protection Officer using the contact details given above.
All complaints received will be fully investigated. Please supply as much information as possible to assist us to resolve your complaint in a prompt and efficient manner.
You can contact the Office of the Data Protection Commissioner in Ireland, at email@example.com or as directed on their website https://www.dataprotection.ie/en/contact/how‐contact‐us.
If you need assistance or information on how to contact the relevant data protection authorities in any other countries where Centaur operates, please contact our Data Protection Officer with the details provided above.