Privacy Policy

Terminal Investment Limited S.à.r.l Corporate Data Privacy Policy

Introduction

Purpose of this privacy policy

This privacy policy explains how Terminal Investment Limited S.à.r.l (“TiL”) collects and processes your personal data that you furnish with us, including through your use of this website.

It is important that you read this privacy policy together with any other additional privacy undertakings we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we use your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

TiL is the corporate head office for a group of different legal entities, consisting of TiL’s subsidiaries, other affiliates and joint ventures. This privacy policy is issued on behalf of the TiL group as an overarching corporate standard, and TiL is the controller to the extent you provide your Personal Data through this website or directly to TiL.

In the event that you access the individual website of any member of the TiL group, when we mention 'COMPANY', 'we', 'us' or 'our' in this corporate privacy policy, it should be understood that we are referring to the relevant company in the TiL group responsible for processing your data, i.e. when you purchase a product or service with the relevant terminal, such terminal will be the controller and will also be responsible for its policies and for the management of its website.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise [your legal rights], please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: Terminal Investment Limited Sàrl
Email address: CH106-data.protection@tilgroup.com
Postal address: 12-14 Chemin Rieu, Gevena 1208 Switzerland
Telephone number: +41227039255

You also have the right to make a complaint at any time to the Geneva cantonal data protection office, telephone: +41 22 546 52 40, email: ppdt@etat.ge.ch Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the cantonal authority so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, nationality, names of close relatives, status as politically exposed person].

• Business Information includes list of associated businesses, directorships, officer positions, shareholdings and relevant business history.

• Contact Data includes [email address and telephone numbers].

• Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

• Usage Data includes [information about how you use our website].

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Personal Data [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • enter into an agreement with us.

  • give us feedback or contact us.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for our legitimate interests (or those of a third party).

• Where we need to comply with a legal obligation.

We will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

The following are the cookies used to ensure a correct navigation of our website:

Disclosures of your personal data

We may share your personal data with other companies in the TiL group acting as joint controllers or processors and who are based in Switzerland and/or the EU and provide IT and system administration services and undertake leadership reporting.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We may share your personal data within the TiL group and to certain advisors, consultants and other representatives of TiL including our shareholders. This will involve transferring your data outside the European Economic Area (EEA).

Some of TiL’s our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring the following safeguards: we may use specific contracts approved by the European Commission or the Swiss Data Protection Authority or specifically negotiated contractual protections.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data.

• Request correction of your personal data.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

• Request transfer of your personal data.

• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

last updated on October 2022