This privacy notice tells you what to expect when Marbral Advisory collects and processes your personal data. We may collect your personal data if we provide services to you or if you have registered to receive our newsletter. Personal data includes information such as an individual’s name, address, email address and processing includes collecting, storing, using or disclosing personal data. Marbral is bound by data protection legislation in each jurisdiction within which it operates and is committed to protecting and respecting your privacy. This Privacy Notice (“Notice”) sets out the basis on which the personal data collected from you, or that you provide will be processed by us.
We use your information strictly in accordance with all applicable laws concerning the protection of personal information and you can be assured that any information provided will only be used in accordance with this Notice. In it we explain:
What personal information is collected from you through the website and other third-party integrations, how it is used and with whom it may be shared.
The security procedures in place to protect your information.
Your rights regarding the information you provide.
+ Our commitment to you...
The EU General Data Protection Regulation (GDPR) is the most significant piece of European privacy legislation in the last twenty years. It replaces the 1995 EU Data Protection Directive (European Directive 95/46/EC), strengthening the rights that EU individuals have over their data, and creating a uniform data protection law across Europe.
Jersey has implemented its own updated data protection that is broadly equivalent to the GDPR in the form of the Data Protection (Jersey) Law 2018 (the DP Law) and the Data Protection Authority (Jersey) Law 2018 (the Authority Law).
Marbral Advisory will comply with applicable data protection legislation when they take effect on 25th May 2018. Working in conjunction with our data processors (some of which are listed below), we will keep data protection at the forefront of our activities and ensure we continually respect the legislation whenever we use your data.
- How we collect your personal data
We have clients that are individuals and clients that are corporate bodies, including limited liability partnerships, government departments and agencies and other public bodies. Even where our clients are not themselves individuals, they will be represented by individuals and they may be owned by individuals and invested in by individuals. As a result, we will inevitably process personal data in the course of our relationships with those clients too.
If you are a client, the information we process about you will include personal and/or professional contact details (addresses, telephone numbers, email addresses), copy identity documents and proofs of address, copy professional and educational certificates, details of bank accounts and/or other payment details, details of financial standing and investment objectives. Depending on the services we provide, we may additionally process details of family wealth, names, addresses and other personal details concerning family members and/or those employed by families or family members and other information categorised as "special category data", such as information about an individual's race; politics; religion; biometrics (used for ID purposes) and health.
Marbral makes every effort to maintain the accuracy of personal data, although you must assist with this by promptly contacting Marbral if there are changes to the personal data you have previously provided or if you become aware that Marbral holds inaccurate personal data.
We may also obtain personal data about you, or another person you have provided us personal data for, under a legal basis from sources other than from you. The sources and categories of personal data, along with whether these are publicly accessible are listed below:
Due diligence screening providers.
Names, addresses, age, financial or economic information, social standing, crime or security-related matters. This is publicly available. Internet search engines and public information sources.
Names, addresses, age, financial or economic information, social standing, crime or security-related matters. This is publicly available.
Those authorised to act on behalf of a client including an advisor or attorney.
Name, address, financial information, identifier code, age, gender. This is not publicly available.
- Purpose and basis for the collection
If you are a client, Marbral Advisory collects your personal data, or that of other individuals provided by you, in order to provide you with the services you have requested under the Terms of Business you have entered into with Marbral and also to meet certain legal obligations. We do not collect more information than we need in order to provide you with the services. If you do not provide the information that we ask for, we may not be able to provide you with the services that you require.
We may also (but only with your consent), use your personal data to provide you with newsletters that will contain information about Marbral, including the latest news and other Marbral services that we think may be of interest to you. We may also seek your consent to publish any client testimonial you provide on the Marbral website. Where consent is required to process personal data of an individual who has not reached the required age to provide consent under the applicable data protection law, Marbral will obtain consent from a person with parental responsibility for that individual.
If you are a visitor to our website you may give us your information if you fill in a form on the Site or if you send us an email (name, email address, telephone number and/or postal address). We do this so that we can monitor who accesses our Site and also to correspond with you.
+ Use of your personal information...
We are the sole owners of the information collected on this site. We only have access to/collect information that you voluntarily give. We will not sell or rent this information to anyone.
We will not share your information with any third party outside of our organisation, other than those noted in this policy, for which we use solely to process your data.
We may use and disclose your personal information only as follows:
(a) To promote our service and our products. You can stop receiving our promotional emails by following the unsubscribe instructions included in the footer of every email we send.
(b) To send you informational and promotional content. For example, you may have opted-in to receive emails from us. If you would like to stop receiving such emails, you can unsubscribe by following the instructions included in the footer of every email we send.
(c) To comply with our Terms of Service and applicable law.
(d) To meet legal requirements, such as complying with court orders, valid discovery requests, valid summons, or other appropriate legal mechanisms.
(e) To provide information to our representatives and advisors, such as lawyers and accountants, to help us comply with legal, accounting, and security requirements.
(f) To prosecute and defend a court, arbitration, or criminal legal proceeding.
(g) To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation, or acquisition. In such an event, we will notify you of the change by posting a notice on this website and any acquirer will be subject to our obligations under this Privacy Statement.
+ How we process your information...
If you chat with us on our website, to ensure we can follow-up with you and email you, your chat transcript, we will request your email address. This information is shared with our Chabot service, tawk.to inc. Their head office and servers are based in the United States of America.
- If you complete an online quiz or survey or form created by Marbral Advisory, it is usually built on a platform called Typeform. Typeform will store the data you have supplied, like your name, email address, location and industry. Typeform’s head office is based in Barcelona and your data is stored on their servers which are based in Spain
- If you have received an auto-responder email from us, in response to the completion of an online quiz or survey (through Typeform), we may contact you through a Gmail account (firstname.lastname@example.org). Gmail's Head Office, Google, is based in the United States of America. Google has signed up for the Privacy Shield program.
- If you consent to receive emails from Marbral Advisory from a Typeform form (online quiz or survey), we will use an integration called Zapier to transfer your personal information to our email marketing service; MailChimp
- Zapier’s head office is based in San Francisco and your data is stored on their servers which are in the United States of America. Zapier has signed up to the Privacy Shield program.
- We use MailChimp to send email newsletters. You will always find a link to unsubscribe from receiving future emails from Marbral Advisory in the footer of every email sent from this platform. MailChimp has signed up to the Privacy Shield Program.
- MailChimp’s head office is based in Atlanta and your data is stored on their servers which are in the United States of America. MailChimp have signed up to the Privacy Shield program.
- If you have booked a course or have engaged us to work with you, we may share your billing information and contact details with MT Virtual PA an outsourced, remote administration service. This is mainly for billing and admin purposes. MT Virtual PA is based in Jersey, Channel Islands. They store data on their server, which is based in Jersey, Channel Islands
- We use BullHorn to process personal data to manage online recruitment applications. BullHorn is based in the UK although their data is stored in Europe.
- We use the Litmos by CallidusCloud Learning Management System to host and provide access to our eLearning. Litmos’s head office is based in Silicon Valley, California and its servers are hosted in the United States of America. Litmos have signed up to the US Privacy Shield.
- On occasions, we may use Eventbrite to promote our events. Eventbrite's head office is based in San Francisco, the United States of America. Eventbrite has signed up to the Privacy Shield program.
- If you purchase training from us on our website, we use PayPal and Stripe as our payment processors. PayPal's head office is based in the United States of America. PayPal has signed up to the US Privacy Shield Program. Stripe's head office is based in the United States of America. Stripe have signed up to the US Privacy Shield Program.
- Our website is hosted on Squarespace. Squarespace may store your personal details (if you submit an order or book a course) and your IP address, through cookies. Squarespace's head office is based in the United States of America. Squarespace has signed up to the Privacy Shield program.
- All our data processors (listed above) have signed a Data Processing Agreement with Marbral Advisory to ensure they protect your personal data and operate in line with the relevant data protection legislation.
- Our online application forms are generated through JotForm. Their headquarters are based in the United States of America although form data is stored on servers located in the United States and Germany. JotForm is fully compliant with the European Union’s General Data Protection Regulation (GDPR).
+ Why we process your information...
a) To send you relevant emails that include our latest news, products and services
b) To invite you to events based on your location and role
c) To manage online job applications
d) To provide coaching and training service
e) For the completion of assessments
f) To fulfil our contract for services with you
We take appropriate measures to ensure that any personal data are kept secure and are kept for the duration of your use of our service. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data when transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
To safeguard against unauthorised access to personal information, all electronic personal information held by us is maintained on systems protected by secure network architectures that contain firewalls and intrusion-detection devices. The servers holding personal information are “backed-up” on a regular basis in an effort to avoid any inadvertent erasure or destruction of such personal information and are stored in facilities with appropriate security and fire-detection and response systems.
Marbral stores your data in Jersey, at its physically secure premises in Jersey, Channel Islands. In line with data protection regulation, personal data will not be stored outside the Channel Islands or European Economic Area.
Only people who need the information to perform a specific job are granted access to personal information. The computers/servers in which we store personal information are kept in a secure environment.
+ Retention of data...
Any personal data you provide to Marbral will be retained by us for as long as we need it for the purposes for which it was collected and subject to any applicable law or other legal obligation that may apply.
Cookies are small text files that are placed on your computer by the websites you visit. They are widely used to make websites work, or work more efficiently, to improve the user experience. They also provide certain information to the owners of a site.
The Site currently uses the following cookies:
Anonymous analytics cookies Purpose: Every time a user visits our website, web analytics software provided by a third party generates an anonymous analytics cookie. These cookies can tell us whether or not you have visited the Site before. Your browser will tell us if you have these cookies, and if you don’t, we generate new ones. This allows us to track how many individual unique users we have, and how often they visit the site. These cookies cannot be used to identify individuals; they are used for statistical purposes only.
Geo-targeting cookies Purpose: These cookies are used by software which tries to determine what country you are in from information supplied by your browser when it requests a web page. This cookie is completely anonymous and is only used to help target content and advertising.
Third-party advertising cookies Purpose: On some pages of the Site, third parties may also set their own anonymous cookies, for the purposes of tracking the success of their application, or customising the application for you. Because of how cookies work, Marbral cannot access these cookies, nor can the third parties access the data in cookies used by the Site.
+ Your Rights...
You have rights as an individual which you can exercise in relation to the personal data we hold about you. Your rights are listed below:
Right of access
You have the right to know what type of personal data we hold about you and details about how we use it. You also have the right to obtain copies of your personal data.
To find out what information we hold on you, please contact us.
Right to rectification
You have the right to have any errors or incomplete personal data corrected.
To submit your request to rectify any data we hold on you, please contact us.
Right to erasure (to be forgotten)
In certain circumstances, you have the right to request the deletion of all personal data relating to you.
To submit your request, please contact us.
Right to the restriction of processing
You have the right to restrict how we use your data e.g. you can request that we do not process your data for a particular purpose.
To submit your request to restrict how we use your data, please email the Data Protection Officer
Right to object to processing
You have the right to object to our use of your personal data (including for direct marketing purposes).
To exercise your right to object, please email the Data Protection Officer.
Right to withdraw consent
If you have previously given us consent to process your data for a particular purpose, you have the right to withdraw that consent at any time.
To submit your request to withdraw your consent to be contacted by Marbral, please contact us.
Right to data portability
You have the right to be supplied with all of your personal data you have given to us in a structured, commonly used and machine-readable format. You also have the right to have your personal data transferred from one controller to another.
To exercise your right to portability, please email the Data Protection Officer.
Right to lodge a complaint
You have a right to lodge a complaint with the relevant Data Protection Authority.
+ How we handle all data requests...
When you make a request to exercise one of your rights we will send you an email confirming that we have received your request. We will respond to all data requests within four weeks. If we have difficulties in meeting that deadline, we will contact you to discuss matters.
When you exercise your rights Marbral will consider any exemptions that may apply. It is possible an exemption may affect how we are able to respond to your request, if this is the case Marbral will explain this to you in writing.
+ Changes to this privacy statement...
If we make any changes to this privacy statement, we will post them on this website. We reserve the right to modify this privacy statement at any time, so please review it frequently.
Any changes will be effective immediately upon their posting on the website. If we make material changes to this statement, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
If you object to changes to our privacy statement, you must refrain from using our services, including the website.
If you remain unhappy with the way in which your request or data has been handled, you may email Marbral Advisory. Should we be unable to resolve your complaint, you may contact the Office of the Information Commissioner directly by email at email@example.com or by calling 00 44 1534 716 530.
+ Data Protection Authority...
Marbral Advisory Ltd is registered with the Office of the Information Commissioner in Jersey, Channel Islands.