• This Privacy Statement sets out how Westian Global, (“our,” “us,” or “we”) uses your data in connection with services supplied to you ("services”). For purposes of this Privacy Statement, " data" means any information by which we can identify you as an individual.
• This Privacy Statement only applies to the data usage of (prospective) clients we are responsible for. We qualify as Controller as per the General Data Protection Regulation (2016/679/EU) ("GDPR"), as further described in this Privacy Statement. This data type is collected through various channels, such as in the sales process, by telephone calls, via forms you submit to us, or by email.
2. Data we collect
The data we collect about you when you use our services include the following:
• Contact details, including your name, address, telephone number, email address.
• Your gender, profession, marital status, or other information requested to identify you as a client or client representative.
• Your communication data, such as requests or complaints you may have made, and any other data we receive if we correspond with you via email, speak on the telephone, or otherwise.
• Any other data, including data you provide to us during your relationship with us, either voluntarily or upon request.
We are required by law to conduct "know your client" procedures. To comply with our legal obligations, we also collect first and family names, copies of ID, proof of address, nationality, tax residence, phone number, email address, date of birth, marital status, profession, annual income, and estimated wealth from clients.
3. How we use your data
We collect and use your data for the purposes below and on a legal basis. To the extent that we already hold information about you, we may use that information for the same purposes.
To fulfill our agreement with you:
• We use your data to carry out our obligations resulting from any contracts between you and us and to deliver the information and services that you ask for.
Use of consent-based information:
• We use prospective client data to send marketing communications by email, other means, or telephone after we have your consent to do so. You can remove your consent at any time.
For legal reasons:
• Any information referred to above under Paragraph 2 may be used to fulfill legal obligations, such as maintaining appropriate business records, undertaking KYC procedures, responding to lawful requests by governmental agencies and authorities, and complying with applicable laws and regulations or as otherwise required by law.
For our legitimate commercial interests:
• If you are an existing client, we may use your data, such as your contact details and your email address, to advertise services that may be of interest to you or to make contact with you for marketing or other commercial purposes.
For client administration:
• We use your data for client administration purposes, such as client services agreements administration, internal administration of work done under client services agreements.
For analyzing and improving our services:
• We use your data for analyzing and improving the quality of our services and understanding you as a client, which allows us to evaluate what may interest you or understand the effectiveness of advertising.
Legitimate commercial interests:
• In addition, we use your data for our legitimate commercial interests such as to operate and expand our business activities, to develop and improve or alter our services, to generate aggregated statistics about the users of our services, to help with security and fraud prevention, to operate our website and for internal operations.
For system integrity:
• We also use your data for system integrity purposes, to facilitate our business operations, to operate company policies and procedures; to enable us to make corporate transactions, such as any merger, sale, reorganization, acquisition, bankruptcy, or similar event, or for other legitimate business purposes allowed by law.
5. How we share your data
We share data with:
• Data controllers. Your data will be shared for internal administrative purposes, management purposes, analytical purposes, and other business-related purposes. Your data will only be used by us for marketing purposes if you have given your consent to that or where we have a legitimate interest to do so.
• Service providers and processors. We engage third parties to provide services on our behalf, which may have access to your data, including:
• Business partners, such as legal, tax, and accounting firms or financial service providers, including subcontractors performing services under client agreements.
• IT service providers and marketing and advertising companies.
• Analytics and search engine providers that help us improve and optimize our website (Google Analytics).
• We will disclose your data if demanded by law or as part of an investigation, regulatory requirement, court proceeding, or legal process served on us, or to protect the rights or safety of the website or ourselves.
• In addition, information about our clients, including data, may be disclosed as part of any corporate transaction, such as a merger, sale, transfer of assets, acquisition, bankruptcy, or similar.
• We also share information about you with any other third party where you have consented or requested that we do so.
6. International data transfer
• Due to the global nature of our business operations, we transfer data you provide to us to countries other than where you reside. The laws of these countries may not offer the same protections, so we seek to ensure that all adequate protections are in place and that all laws and regulations are complied with in connection with such transfers, especially for data transferred to countries outside the EEA.
7. Security
• We will take measures to ensure that data is appropriately secured using technical, physical, and organizational steps to protect against unauthorized or unlawful use, alteration, unauthorized access or disclosure, accidental destruction, deletion, or loss. We limit access to your data to those who need it for one of the purposes listed in this Privacy Statement. Additionally, we ensure that any third party accessing your data provide the same levels of confidentiality and integrity.
8. Data Retention
We keep your data for as long as necessary to satisfy the purpose it was collected and used unless a more extended period is needed for legal reasons or to defend a legal claim. The data that we collect of ultimate beneficial owners is retained for ten years to cover the different requirements under the national legislations of the countries where such information is collected.
9. Your Rights
Subject to the conditions set out in applicable law, you have the right to request, review, correct, update, restrict or delete data that you have provided to us. In your request, please tell us what data you would like to have changed, updated, restricted, or deleted.
Please be aware that we may need to keep some data for recordkeeping purposes or complete any transactions that you started before requesting a change or deletion. In the event your data is processed on a consent basis, you can retract your consent at any time by emailing us specifying your request.
You may complain to a supervisory authority, particularly in your country of residence, if you consider that the collection and use of your data overstep this Privacy Statement or applicable law.
10. Amendments to the Privacy Statement
This Privacy Statement may be amended occasionally. If a significant change to the nature of your data is involved or if the difference is in any other way relevant to you, we will inform you in advance of the change.
If you have any questions about this Privacy Statement or our management of your data, please contact us.
