DATA PROTECTION PRIVACY NOTICE
Thank you for choosing to be part of our community at Sapphire Studios (“Company”, ” we”, ” us”, or” our”). This notice is provided to enable you to better understand our processing of your personal data and we are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice or our practices with regard to your personal information, please contact us at the following URL address: www.sapphirestudios.co
Confidentiality is intrinsic to the Company’s business and we take data protection very seriously. This privacy notice is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately. The Company is acting as a data controller with respect to your personal data. The Company is responsible for ensuring that your personal data is processed in compliance with any and all applicable laws, rules and regulations and to provide you with this notice.
This privacy notice describes how we might use your information if you:
- Visit our website at ___www.sapphirestudios.co ___________________.
- Engage with us in other related ways – including any sales, marketing, or events
In this privacy notice, if we refer to:
- “Website “, we are referring to any website of ours that links to this policy
- ” Services”, we are referring to our Website, and other related services, including any sales, marketing, or events.
Please read this privacy notice carefully, as it will help you understand what we do with the information that we collect.
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- WHO WILL YOUR INFORMATION BE SHARED WITH?
- IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- WHAT ARE YOUR PRIVACY RIGHTS?
- CONTROLS FOR DO-NOT-TRACK FEATURES
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS NOTICE?
- HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
- HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services. The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the services and features you use. The personal information we collect may include the following:
(a) identification data (eg name, surname, addresses, alias, place and date of birth, professional information, proof of identity (such as passport, photograph, identity card) and proof of address, results of fraud, criminal record checks, sanction screening, numeric data including tax identification numbers, bank details, signature, contact information, social security details and FATCA/CRS details, politically exposed persons checks and any other checks required by anti-money laundering and counter terrorist financing regulations on the investor and the relevant person(s));
(b) professional data (eg position, company);
(c) coaching, training, personnel data, personality test data in conjunction with the services we offer;
(d) administrative data (eg language, tax identification numbers, bank details, signature, contact information, social security details); or
(e) financial data (eg tax data, FATCA/CRS details, transactional data, investment preferences, investment history). The Company will also process personal data relating to business contacts, staff of the Company’s service providers and their service providers, authorized signatory lists, personnel employed by or who may become involved in a transaction/contract with the Company.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
Information Collected from Other Sources: In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion.
Sources of Personal Data. This data may be provided directly by you or, third party data sources or, through your authorized intermediaries, directors, officers, individual representatives (including, without limitation, legal representatives), trustees, settlors, signatories, shareholders, unitholders, investors, nominees or employees. The Company may also collate and hold data found from the results of internet searches and other sources in the public domain in the course of the client due diligence process and in providing the services that the Company is engaged to provide. The Company processes or may process the following documents that may also contain your personal data: employment history, references, financial information, performance reviews, coaching evaluations, personnel records and surveys. In the course of your dealings with the Company you may provide us with further information; all of this information will be kept securely by us. When the Company does not collect personal data directly from you, it must tell you the categories of personal data that it processes which have been collected from other sources. The Company processes the following categories of your personal data that are not collected directly from you:
(a) professional/career data, personality test data;
(b) identity/address and other information from sanctions screening, fraud prevention agencies or credit reference agencies. The Company will notify you should any further personal data be collected from third parties.
2. HOW DO WE USE YOUR INFORMATION?
We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive to:
(a) provide our services to you;
(b) comply with applicable anti-money laundering and counter terrorist financing rules, performing legal requirements under FATCA, the Common Reporting Standard (CRS) or similar laws and regulations;
(c) communicate with you in the general course of business, including where applicable, decision making in relation to the Company, business strategy, monitoring and management of systems and improving products and services;
(d) fulfill the Company’s contractual obligations with third-parties;
(e) conduct internal and external audits and, where necessary, investigations or establishing, exercising or defending legal claims; or
(f) To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
(g) To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
(h) the legitimate interests pursued by the Company, or by the third parties.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We may process or share your data that we hold based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Personal Data Provided to Third Parties. More specifically, the manner in which the Company operates, requires us to share, disclose or provide personal data to third parties to perform our contracts with third party service providers or at other times at your request or may be necessary for legal/regulatory reasons, such as anti- money laundering and counter terrorist financing laws and regulations. Third parties may include any third party that provides services to the Company, professional advisors or any lender to the Company, including without limitation such third parties respective service providers, and any of the foregoing respective agents, delegates, affiliates, subcontractors and/or their successors and assigns generally. A non-exhaustive list of potential disclosures includes:
(a) collecting and sending documents when making an underlying investment,
(b) collecting and sending documents for external audits;
(c) collecting and sending documents for external audits of third party service providers;
(d) publications onto the public record, such as companies registries or beneficial ownership registers;
(e) publications with regulators;
(f) FATCA/CRS filings onto approved external platforms;
(g) sending information to external parties
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
We only share and disclose your information with services providers (including but not limited to depositaries, notaries, administrators, domiciliation agents, banks, consultants, distributors, managers and other advisors (including, but not limited to, legal advisors), other financial intermediaries and professionals of the financial sector acting on behalf of the Company and providing services to the Company, and supervisory or governmental bodies. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below.
Third parties and their respective service providers, directors or management bodies and the Company may require information on you for their own due diligence assessment and to comply with relevant laws and regulations, therefore we and our processors may share the information you provide to us with them for this purpose.
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
Our servers are located in ___USA____________. If you are accessing our Website from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in and other countries. Your personal data may be transferred to and stored by persons outside the United States, and in particular may be transferred to and stored by affiliates or service providers of the Company outside the United States. Where personal data is transferred outside the United States, the Company will ensure that the transfer is subject to appropriate safeguards or is otherwise permitted under applicable law. For example, in the context of personal data transferred outside the United States, the country to which the personal data is transferred may be a European Economic Area member, a country approved by the European Commission or the recipient may have agreed to model contractual clauses approved by the European Commission that oblige them to protect the personal data. You can obtain more details of the protection given to your personal data when it is transferred outside the United States or the European Economic Area, including a copy of any standard data protection clauses entered into with recipients of your personal data, by contacting the Company using the details set out below.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:
If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
If you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
CCPA Privacy Notice. The California Code of Regulations defines a “resident” as: every individual who is in the State of California for other than a temporary or transitory purpose and every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose. All other individuals are defined as “non-residents.” If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve
We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
More information about our data collection and sharing practices can be found in this privacy notice.
You can opt out from the selling of your personal information by disabling cookies in Cookie Preference Settings.
You may contact us by visiting www.sapphirestudios.co or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.
Sapphire Studios has disclosed the following personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can also be found under “WHO WILL YOUR INFORMATION BE SHARED WITH?”.
Sapphire Studios has sold the following personal information to third parties in the preceding twelve (12) months:
Your rights with respect to your personal data
Right to request deletion of the data – Request to delete. You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.
Right to be informed – Request to know. Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell your personal information to third parties;
- the categories of personal information that we sold or disclosed for a business purpose;
- categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. We will not discriminate against you if you exercise your privacy rights.
Verification process. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you may have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights. You may object to the processing of your personal data. You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data. You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
To exercise these rights, you can contact us by referring to the contact details at the bottom of this document.
12. DO WE MAKE UPDATES TO THIS NOTICE?
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by contacting us at _____www.sapphirestudios.co ________________.