Privacy Policy - Intokia

Privacy Notice

This is the privacy statement for Van Sterling Capital Ltd. (or We). Van Sterling Capital Ltd. is a registered and licensed Investment Firm, regulated by the Malta Financial Service Authority with the licence number VANS-IF-9616 with its address at 168, St. Christopher Street, Valletta VLT 1467, Malta.

Van Sterling Capital Ltd. is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data We collect from you or that you provide to us, directly or indirectly, will be processed by us. Please read the following carefully to understand our views and practices regarding personal data and how We treat it.

Van Sterling Capital Ltd. can be contacted at the above address, [email protected] and on +356 (27) 289 615.

The General Data Protection Regulation (EU) 2016/679

In this statement we have used certain terms which are set out in the EU´s General Data Protection Regulation (GDPR or the Regulation):

personal data means: any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

controller means: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

processor means: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

processing means: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

What we do?

Van Sterling Capital Ltd is a regulated asset manager for private and institutional clients.

Our Status under GDPR

Depending on the nature of the interaction, We may act as a processor in that We are acting upon instructions from controllers when We provide our services to them; and when We control the purposes and means of the processing of personal data, We act as a controller, as defined under GDPR.

What lawful reasons do we use to process personal data?

The lawful reasons Van Sterling Capital Ltd. uses to process personal data are set out in Article 6 of the regulation and with respect to the business model undertaken by Van Sterling Capital Ltd., our processing is lawful given that at least one of the following applies:

The data subject has given consent to the processing of his or her personal data for one or more specific purposes (Consent).
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Contract Performance).
Processing is necessary for compliance with a legal obligation which We are subject to (Legal Obligations).
Processing is necessary for the purposes of the legitimate interests pursued by Van Sterling Capital Ltd., except where our interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child (Legitimate Interest).

Sensitive personal data

Where We process sensitive personal data, We do so on the basis that We have established a lawful exception to the prohibition on processing sensitive personal data under Article 9 of the Regulation; and where Van Sterling Capital Ltd. is processing sensitive personal data of employees, it does so pursuant to its employment relationship with its personnel and so uses the exception set out in paragraph 2(b) of Article 9 of the Regulation.

What personal information do we collect?

We collect and process your personal information in a number of ways.

Information you give us directly

You give us information about yourself when you register for an agreement with us. Information includes contact details, identity data such as your passport or national identification card, utility bills, age, gender, address details, employment details, financial details, tax information, details of your trading experience and knowledge and payment details such as credit and debit card information. We also collect personal data about you from publicly available sources.
You choose to provide additional information to us when you contact us or otherwise interact with us, including via e-mail, letter, phone or chat function and through your use of our services.
We keep records of communications when you contact us or otherwise interact with us, including e-mail, letter, online, telephone or live chat function on our platforms. This may include credentials such as passwords, password hints and other security information used for authentication and account access.

Information we collect automatically
When you interact with our services, our servers keep an activity log unique to you which collects certain administrative and traffic information including source IP address, time of access, date of access, language use, software crash reports and type of browser used.

How does Van Sterling Capital Ltd. use my personal information?

We use your information for the following purposes:

To provide a requested service or carry out a contract with you.
To collect payment, deliver our services to you and to process your transactions.
To provide you with support and service messages, including messages requesting your feedback on our services and notifying you about changes to our platform, services or changes to our terms, conditions and policies.
To enforce any contract entered into between you and us for the provision of our services.
To conduct security and anti-money laundering reviews and to validate your identity, age, the registration information provided by you and to verify your use of our services and your financial transactions.
To develop and improve our platforms to enhance your experience and personalise our platforms and services for you.
To improve the quality of the services we provide.
To monitor accounts to prevent the use of unfair or unlawful practices.
To ensure effective operational management and internal administration of our business, document retention, compliance with regulatory guidance and exercise or defence of legal claims.
To protect, investigate and deter against fraudulent, unauthorised or illegal activity.
In response to requests by government or law enforcement authorities conducting an investigation.
To fulfil our legal regulatory responsibilities; and when required by our regulator.

Does Van Sterling Capital Ltd. share my personal data?

We take steps to ensure that our arrangements with third-party suppliers (including online vendors) protect your privacy. We share your personal information in the following circumstances:

With suppliers and sub-contractors for the performance of a contract including where we engage the services of third-party suppliers to provide technical support and maintain your account with us.
With analytics and search engine providers that assist us in the improvement and optimisation of our site.
If Van Sterling Capital Ltd. or substantially all of its assets are acquired by a third party, in which case personal data held by Van Sterling Capital Ltd. may be one of the transferred assets.
If We are under a duty to disclose or share personal data to comply with any legal obligation, or in order to enforce or apply our terms and other agreements.
With third-party electronic payment processors and/or financial institutions to process financial transactions.
With trusted third-party suppliers of information verification services for validating your information.
With banks, brokers, or agencies in cases of fraud or suspected fraud.
Anyone authorised by you.
To courts, tribunals, law enforcement or government agencies, or other competent authorities as required by law.
Microsoft: Office 365 and OneDrive (data may transfer to the USA under Privacy Shield).
Salesforce: CRM services (data may transfer to the USA under Privacy Shield).

How long does Van Sterling Capital Ltd. keep my personal information?

Information that we collect will be retained only for as long as is necessary to fulfil the purposes outlined above or to comply with legal obligations. Retention considerations include:

Our contractual obligations and rights in relation to the information involved.
Legal obligations under applicable law.
Statute of limitations.
Potential disputes.
Guidelines issued by relevant data protection authorities.
We securely erase your information once it is no longer needed, in compliance with GDPR.

Does Van Sterling Capital Ltd. transfer my personal information abroad?

We store your personal information on our servers which may be based outside of the European Economic Area. Where personal data is transferred to countries not subject to an EU adequacy decision, we ensure adequate safeguards such as Binding Corporate Rules, Intra-group agreements, EU Commission-approved standard contractual clauses or certified mechanisms. We use encryption and password protection to maintain data security.

What forms of ID will I need to provide in order to access the above?

Van Sterling Capital Ltd accepts the following forms of ID when information on your personal data is requested: passport, identity card, driving license, utility bill or bank statement from the previous 3 months. We reserve the right to request further information where your identification is not clear.

Your rights to complain

Where you want to address a complaint to the authority, we would be happy if you contact us beforehand under [email protected]
.
Nevertheless, you have the right to contact the Commissioner for Data Protection regarding your complaint about the way we process your personal data. You can register your concern by contacting the Commissioner at [email protected]
.

Contacting you

The personal data We process is subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure. We will get in touch with the supervisory authority (which in Van Sterling Capital Ltd.’s case is the Commissioner for Personal Data Protection located at Floor 2, Airways House, High Street, Sliema, SLM 1549, Malta — www.idpc.org.mt
) and with affected data subjects, where this is required under the Regulation.

Changes to this privacy statement

If We change this privacy statement, We will let you know about the changes by publishing the updated version on our site.

Your rights

At the request of the data subject We will confirm the information We hold about the data subject and how it is processed. As set out in the Regulation a data subject can request the following information:

Identity and contact details of the controller.
Contact details of the data protection officer, where applicable.
Purpose and legal basis for processing.
Information about legitimate interests.
Categories of personal data collected.
Recipients or categories of recipients.
Details on transfers to third countries and safeguards used.
Data retention period.
Rights to correct, erase, restrict or object.
Right to withdraw consent.
How to lodge a complaint.
Whether provision of personal data is statutory or contractual.
Source of data if not collected directly.
Details of automated decision making, profiling, and related logic.

Contact details

Van Sterling Capital Ltd.
Contact name: Sven Büchel
168, St. Christopher Street, Valletta VLT 1467, Malta
E-Mail: [email protected]