1.1 STEREOMAFX ASSETS LIMITED (the “STEREOMAFX” or “Company”) is an International Investment Firm (the “IF”) incorporated in the SVG with Company Number 0000
1.2 The Company is authorised and regulated by the SVG Securities and Exchange Commission (the “VFSC”), with a Dealer in Securities Principal License (the “License”) granted by the Minister of Finance and Economic Management of SVG. The foundations of the services offered to Clients are based on the License of the Company.
1.3 STEREOMAFX ASSETS LIMITED (the “STEREOMAFX” or “Company”) is committed to protecting your privacy and handling your data in an open and transparent manner. The personal data that we collect and process depends on the product or service requested and agreed in each case.
2.1 Protecting the privacy and safeguarding the personal and financial information of STEREOMAFX clients and website visitors is one of our highest priorities. The following General Data Protection (the “GDP”) Policy explains how we collect, store and protect your information.
2.2 Your data can be referred to as “personal information” or “personal data”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal data or any such action as “processing” such personal data.
2.3 For the purposes of this policy, personal data shall mean any information relating to you which identifies or may identify you and which includes, for example, your name, address, identification number.
3.1 We collect and process different types of personal data which we receive from our clients (potential and current) via their representatives or via our alternative channels of communication such as our website or members area, in the context of our business relationship.
3.2 We may also collect and process personal data which we lawfully obtain not only from you but from other entities within the Company Group, or other third parties e.g. individuals, public authorities, companies that introduce you to us, companies that process card payments.
3.3 Additionally, we may also collect and process personal data from publicly available sources (e.g. the Department of Registrar of Companies and Official Receiver, commercial registers and media outlets) which we lawfully obtain and we are permitted to process.
Primary contact details (Director)
4.1 In order that we may be in a position to proceed with a business relationship with you, you must provide your personal data to us which is necessary for the commencement, execution of a business relationship and the performance of our contractual obligations. We are furthermore obligated to collect such personal data given the provisions of the money laundering law which require that we verify your identity before we enter into a contract or a business relationship with you (or the legal entity for which you are the authorized representative/ agent or beneficial owner). You must, therefore, provide us at least with your identity card/passport, your full name, place of birth (city and country), and your residential address so that we may comply with our statutory obligation as mentioned above.
5.1 As mentioned earlier we are committed to protecting your privacy and handling your data in an open and transparent manner and as such we process your personal data in accordance with the GDPR and the local data protection law for one or more of the following reasons:
We process personal data in order to offer you financial services. Therefore, we require you to fill appropriateness form with additional data, which will enable us to provide you with best suited product. Such information, which we are obligated to collect, is necessary for us to be able to provide you with our services. The purpose of processing personal data depends on the requirements for each product or service our Client Agreement provides more details with regards to this matter.
There are a number of legal obligations emanating from the relevant laws to which we are subject as well as statutory requirements, e.g. the Money Laundering Law and various supervisory authorities whose laws and regulations we are subject to. Such obligations and requirements impose on us necessary personal data processing activities for identity verification, compliance with court orders, tax law or other reporting obligations and anti-money laundering controls.
We process personal data so as to safeguard the legitimate interests pursued by us or by a third party. A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you, therefore, our objective is to process your data in fair, transparent and lawful manner. Examples of such processing activities include:
6.1 Provided that you have given us your specific consent for processing (other than for the reasons set out herein above) then the lawfulness of such processing is based on that consent. You have the right to revoke consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected.
7.1 In the course of the performance of our contractual and statutory obligations your personal data may be provided to various departments within the Company but also to other companies of STEREOMAFX. Various service providers and suppliers/contractors may also receive your personal data so that we may perform our obligations. Such service providers and suppliers enter into contractual agreements with the Company by which they observe confidentiality and data protection according to the data protection law.
7.2 It must be noted that we may disclose data about you for any of the reasons set out herein above, or if we are legally required to do so, or if we are authorised under our contractual and statutory obligations or if you have given your consent.
7.3 Under the circumstances referred to above, recipients of personal data may be, for example:
8.1 We may process your personal data to inform you about products, services and offers that may be of interest to you or your business.
8.2 The personal data that we process for this purpose consists of information you provide to us and data we collect and/or infer when you use our services, such as information on your transactions. We study all that information to form a view on what we think you may need or what may interest you. In some cases, profiling is used, i.e. we process your data automatically with the aim of evaluating certain personal aspects in order to provide you with targeted marketing information on products.
8.3 We can only use your personal data to promote our products and services to you if we have your explicit consent to do so or, in certain cases, if we consider that it is in our legitimate interest to do so. You have the right to object at any time to the processing of your personal data for marketing purposes, which includes profiling, by contacting at any time the Company in writing at privacy@STEREOMAFX.com.
9.1 We will keep your personal data for as long as we have a business relationship with you (as an individual or in respect of our dealings with a legal entity you are authorized to represent or are beneficial owner). Once our business relationship with you has ended, we may keep your data for up to ten (10) years. We may keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons.
9.2 For prospective client personal data [or authorized representatives/agents or beneficial owners of a legal entity prospective client] we shall keep your personal data for 6 months from the date of notification of the rejection of your application for our services and/or facilities or from the date of withdrawal of such application.
10.1 You have the following rights in terms of your personal data we hold about you:
10.1.1 Receive access to your personal data. This enables you to e.g. receive a copy of the personal data we hold about you and to check that we are lawfully processing it. In order to receive such a copy, you can complete our web form through the Company’s website (https://www.STEREOMAFX. com/en/contact-us).
10.1.2 Request correction [rectification] of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
10.1.3 Request erasure of your personal information. This enables you to ask us to erase your personal data (known as the ‘right to be forgotten’) where there is no good reason for us continuing to process it.
10.1.4 Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms. You also have the right to object where we are processing your personal data, for direct marketing purposes. This also includes profiling in as much as it is related to direct marketing. If you object to processing for direct marketing purposes, then we shall stop the processing of your personal data for such purposes.
10.1.5 Request the restriction of processing of your personal data. This enables you to ask us to restrict the processing of your personal data, i.e. use it only for certain things, if:
10.1.6 Request to receive a copy of the personal data concerning you in a format that is structured and commonly used and transmit such data to other organisations. You also have the right to have your personal data transmitted directly by ourselves to other organisations you will name [known as the right to data portability].
10.1.7 Withdraw the consent that you gave us with regard to the processing of your personal data at any time. Note that any withdrawal of consent shall not affect the lawfulness of processing based on consent before it was withdrawn or revoked by you.
10.2 To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact your account manager, visit any of our offices, or send a message to privacy@STEREOMAFX.com
11.1 A personal data breach is a “breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed”.
11.2 A breach is therefore a type of security incident and there are three different types of breach that may occur:
11.3 A personal data breach would, for example, include:
11.4 Notification to the Office of the Commissioner 11.4.1 Not all personal data breaches are necessary to be notified to the Office of the Commissioner. 11.4.2 Every suspicion of a data breach has to be notified to the Data Protector Officer of the Company. 11.4.3 The DPO will gather all the necessary information as soon as possible and assess the level of risk in order to decide if the case needs to be communicated with the Office of the Commissioner. 11.4.4 The breach will only need to be notified if it is likely to result in a risk to the rights and freedoms of data subjects, and this needs to be assessed internally by the Company on a case-by-case basis. A breach is likely to result in a risk to the rights and freedoms of data subjects if, for example, it could result in:
11.5.1 We can provide this information in phases, without undue further delay, if it cannot all be provided at the same time.
11.6 Awareness of the breach occurs when we have a reasonable degree of certainty that a breach has occurred. In some cases, it will be relatively clear from the outset that there has been a breach. However, where it is unclear whether or not a breach has occurred, we will have a short period of time to carry out an initial investigation and assessment after becoming aware about a potential breach in order to establish with a reasonable degree of certainty whether or not a breach has in fact occurred. If, after this short initial investigation, we establish that there is a reasonable degree of likelihood that a breach has occurred, the 72 hours starts to run from the moment of that discovery.
12.1 If you have exercised any or all of your data protection rights and still feel that your concerns about how we use your personal data have not been adequately addressed by us, you have the right to complain by contacting support (https://www.STEREOMAFX.com/en/contact-us).
13.1 We may modify or amend this privacy statement from time to time.
13.2 We will notify you appropriately when we make changes to this privacy statement and we will amend the revision date at the top of this page. We do however encourage you to review this statement periodically so as to be always informed about how we are processing and protecting your personal information.
14.1 Clients shall communicate with the Company with the communication methods described within this policy and/or at the following address: Correspondence Address: Suite 305, Griffith Corporate Centre, Beachmont, Kingstown, Saint Vincent and the Grenadines Customer ServiceE-mail:support@STEREOMAFX.com