The EU General Data Protection Regulation 2016/679 (the "GDPR"), which entered into force on 25th May 2018, applies throughout the European Union ("EU") and also applies to controllers and/or processors outside the EU when goods or services are offered to data subjects in the EU. As Tempest offers services in the EU, where it processes personal data of data subjects residing in the EU, the GDPR applies in addition to Monaco Law No 1,165 of 23 December 1993 on the protection of personal data - consolidated by Monaco Law No 1,454 of 30 October 2017.
We therefore respect above all Monegasque law on the protection of personal data to which we must add the impact in Monaco of the EU General Data Protection Regulation. This includes concise, transparent, understandable and easily accessible information for those concerned. In addition, we protect your personal data with technical and organisational security measures that comply with current security standards.
You will find below several sections detailing how we treat your personal data, updated to ensure compliance with the EU General Data Protection Regulation (GDPR).
- The person responsible for data processing operations
- The data we process
Personal data is information relating to an identified or identifiable natural or legal person. Within the framework of the conclusion and execution of our legal relationship, we process your personal data to the extent permitted by law, taking particular account of the principle of data minimisation.
- The personal information you provide to us
Personal information is any information that can be used to identify you or that we may link to you and that we have in our possession or control. Your privacy is important to us. By providing personal information such as your name and e-mail address via the registration forms on this website, you agree that we may contact you regarding the information provided.
Some forms on our website also include a check box asking permission to be added to our mailing list. This is an opt-in mailing list and your personal information will only be used by us (and all such emails include an opt-out link).
- How we use your personal information
We use the data you provide to us via this website to:
- Communicate with you, for example we use contact information such as e-mail address or telephone number to respond to inquiries made through online forms.
- Monitor website trends, for example we use Google Analytics to help us aggregate traffic so that we can monitor website usage.
- Operate our business more efficiently, for example we seek documentation and use it to improve our service.
- Our legitimate reasons for collecting and processing your personal data
Monegasque law and The General Data Protection Regulation (GDPR) together constitute the main body of legislative texts which define your rights regarding the processing of your personal data. It requires us to state on which of the six "legitimate reasons" we rely when we process your personal data: we operate on the basis of consent when sending newsletters (you will not receive a newsletter unless you have explicitly chosen to receive one) and we operate on the basis of safeguarding legitimate interests when we communicate with you by other means (for example, when we respond to your request). Furthermore, it is part of the performance of a contract or pre-contractual measures, and is intended to fulfil a legal obligation.
- The protection of your personal data
We attach great importance to data security. We treat data in accordance with the requirements of Article 32 of the GDPR and rely on technical and organisational security measures that comply with internationally recognised and constantly revised IT standards.
No personal information will therefore be collected without your knowledge, nor transferred to third parties.
We only process your personal data if we have a legal basis for doing so. In general, this is due to one of the following:
- Consent: if we need and obtain your consent to use your personal data. You may withdraw your consent by contacting us.
- Contract Performance: we may need to collect and use your personal data to perform a contract to which you are a party or to take action at your request before entering into a contract.
- Legitimate Interest: we may use your personal data to the extent necessary to pursue our legitimate interests (including the provision of legal services).
- Respect of the law or regulations: we may use your personal data if necessary to respect legal or regulatory obligations.
- Sharing and transferring your personal data
From time to time, we may transmit personal data such as your name and e-mail address to other departments that we use to send newsletters and other communications (electronic and printed). However, your personal data will remain in the EU or in countries considered by the EU to have equivalent policies such as Jersey, Guernsey, Switzerland, New Zealand and Canada. US-based companies that have been certified under the EU-US Privacy Shield program are also considered EU-authorised destinations (this includes popular US products such as Gmail, DropBox and MailChimp).
- How long your personal data is kept for
Personal data may be stored by this website for up to 90 days, after which it is automatically deleted.
As far as the data we have on our clients is concerned, we keep it physically and electronically before archiving it in accordance with our internal archiving policy (immediate-intermediate-definitive).
- Your rights regarding your personal data
According to prevailing regulation, as a data subject you have a right of access, rectification and opposition to information concerning you:
- Right of access: this allows you at any time to ask us for information about the data we hold about you. You can receive a copy of your data free of charge.
- Right of rectification: this authorises you to request the rectification of your data on the basis of more recent information made available to us.
- Right of opposition: you may at any time object to the processing of your data for reasons relating to your particular situation, provided that the processing is based on your consent, on our legitimate interests or those of a third party.
You also have a right of deletion, a right to limit the processing, a right to the portability of your data or a right to decide the fate of your data after your death.
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- Privacy of our website and use of Google Analytics
We use Google Analytics to monitor the use of our website to make improvements. Our use of Google Analytics requires us to provide Google with your IP address (but no other information) - Google uses this information to prepare site usage reports for us, but Google may also share this information with other Google services. In particular, Google may use the collected data to contextualise and customise ads on its own ad network.
In the event of a significant change in the processing of your data, we will inform you in good time.
- Contact Information
Any request relating to the processing of your data must be addressed through one of the following means:
Postal address: Palais de la Scala - Suite 1273, 6th Floor - 1, avenue Henry Dunant - MC 98000, Monaco
Email address: firstname.lastname@example.org
Telephone: +377 97 98 10 97