PRIVACY POLICY

This document describes the principles for processing personal data of crossbrook group s.r.o (hereinafter, crossbrook group) Clients, in accordance with General Data Protections Regulations (GDPR).

The principles apply if a Client uses, has used or has expressed an intention to use or is in other way related to any of the services provided by crossbrook group.

1. DEFINITIONS 

crossbrook group: Customer Data responsible processor, legal entity

crossbrook group is a Limited Liability Company registered in Slovakia under registered no. 48106232. Registered office is Plynarenska 3A, 82109, Bratislava, Slovakia.

Client: any natural person or legal entity who uses, has used or has expressed a wish to use or is in other way related to any of the services provided by crossbrook group.

Client data: any information known to crossbrook group about the Client or its representatives.

Personal data: any information directly or indirectly related to the Client as a natural person.

Processing: any operation carried out with Client data (including collection, recording, storing, alteration, grant of access to, making enquiries, transfer to third parties, etc.).

2. GENERAL PROVISIONS

This document describes the general principles of how crossbrook group processes Client data.

crossbrook group ensures, within the framework of applicable law, the confidentiality of Client data and has implemented appropriate technical measures to safeguard Client privacy. crossbrook group also applies strict organisational measures from unauthorised access, unlawful processing or disclosure, accidental loss or destruction of such data.

crossbrook group may also use other processors for processing Client data. In such cases, crossbrook group ensures that such data processors process Client data under the instructions of crossbrook group and in compliance with the applicable law and employing adequate security measures.

3. CATEGORIES OF CLIENT DATA

crossbrook group may collect data from the Client and from external sources, such as public and private registers or other third parties. Main categories of Client data, which crossbrook group collects and processes, are enlisted below:

Identification data: name, identification code, date of birth, data regarding the identification document (passport, ID card);

Contact data: address, telephone number, email address, language of communication;

Professional data: data about educational or professional career;

Data about the relationships with legal entities: such as data submitted by the Client or obtained from public registers or through third parties to represent such legal entity;

Data on origin of assets or wealth: such as data regarding business activity and source of personal funds;

Data about trustworthiness: data that enables crossbrook group to perform its due diligence measures regarding money laundering and terrorist financing prevention and to ensure the compliance with international sanctions, including the purpose of the business relationship and whether the Client is a politically exposed person;

Data obtained and/or created while performing an obligation arising from law: such as data arising from enquiries made by investigative bodies, notaries, courts;

Data about the Client’s tax residency: data about the country of residence, tax identification number, citizenship;

Communication data: such as data which is collected through e-mails, messages and other communication mechanisms (social media). Data collected related to the Client’s visit at www.crossbrookgroup.com website or communication through other channels (such as the Client’s website);

Data related to the services: execution or non-performance of contracts, services purchased, enquiries, complaints, fees, etc.

4. PURPOSES AND BASIS OF PROCESSING CLIENT DATA

            crossbrook group processes client data primarily to:

• manage customer relations and provide access to its services;
• conclude and execute an agreement with the Client, keeping data updated and correct by verifying and enriching data both through external and internal sources;
• carry out risk assessments in order to determine whether the Client meets its risk assessment criteria;
• fulfil legal obligations and verify identity, in compliance with applicable law and international agreements (for example the performance of due diligence upon the “know your client” principle);
• discover and report potential money laundering and terrorist financing, being aware of whether the Client is a politically exposed person and is subject to financial sanctions imposed on the client;
• prevent misuse of its services and ensure adequate provisions of the same services;
• prove, enforce and defend legal claims;
• send information about services and products (customer newsletter),
• prepare internal statistics.

5. RECIPIENTS OF CLIENT DATA

Client data may be shared with other recipients, such as:

• authorities (law enforcement authorities, tax authorities, customs, notary offices, financial intelligence units, etc.);
• internal third parties such as group companies or associated legal entities wherewith crossbrook group exchanges and shares its professional services and expertise;
• external third parties such as financial institutions, credit institutions, intermediaries of financial services, professional service providers, auditors, legal and financial consultants, wherewith crossbrook group collaborates;
• third parties maintaining registers (such as commercial registers, securities registers, population registers or other registers holding or intermediating Client data).

6. GEOGRAPHICAL AREA OF PROCESSING

The Client’s data is processed within European Union/European Economic Area, but in some cases may be transferred and processed to countries outside the European Union/European Economic Area.

The transfer and processing of Client’s data outside the European Union can take place only provided that there is a legal ground to do so, such as legal requirement, due diligence or Client’s consent and confirmation that appropriate safeguards are implemented. Upon request the Client can receive further details from crossbrook group on data transfers to countries outside European Union/European Economic Area.

7. DATA RETENTION

Client data will be processed and retained no longer than necessary. The retention period is no longer than 10 (ten) years, and may be based on applicable law (for example, laws relating to accounting, auditing, money laundering or foreclosure laws, other private law) or other specific agreements.

8. CLIENT RIGHTS AS A NATURAL PERSON

Unless subject to an exemption under the data protection laws, the Client has the following rights with respect to personal data:

• request his/her personal data to be corrected if it is incorrect or incomplete;
• object to processing of his/her personal data, for example in relation to newsletter, offers, participating in surveys, etc;
• request the deletion of his/her personal data (such right does not apply if personal data is being processed also based on other legal grounds such as legal obligation or agreement);
• submit complaints about the use of personal data to the relevant local data protection authority, if the Client finds that the processing of his/her personal data violates his/her rights.

9. THIRD-PARTY LINKS

Our website may include links to third-party websites, plug-ins and applications, which fall outside of our control. 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 we are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

10. CHANGES TO THIS NOTICE

Changes to this privacy policy will be made when required in response to changing legal, technical or business developments.

This privacy policy was last updated on 21st May 2018 and historic versions can be obtained by contacting us.

11. QUERIES, REQUESTS OR CONCERNS

To exercise all relevant rights, queries or complaints in relation to any data protection matter between you and us, or to request whatsoever information to this privacy notice, please in the first instance contact us by email at info@crossbrookgroup.com and we will investigate the matter and report back to you as soon as possible.

If this does not resolve your complaint to your satisfaction, you have the right to submit a complaint to your local data protection authority.

COOKIES

A cookie is a small file sent from a website and stored on your computer while you are browsing. It helps to remember information or to record your browsing activities. It can also be used to remember information that you previously entered into form fields such as names, addresses, passwords, and credit card numbers.

We generally use cookies to identify which pages are being mostly used, this helps us to analyse data about web page traffic and improve our website in order to better tailor it to our customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

A cookie no gives us access to your computer or any information about you, other than the information you choose to share with us.

You can choose to decline cookies but this may prevent you from taking full advantage of our website. Most browsers automatically accept cookies, and you can easily modify your browser setting to decline cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

By continuing to browse the website, you are accepting our use of cookies.

We may use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website.
• Analytical/performance cookies. They may allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This may enable us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies and advertising cookies. The placement and the use of cookies by such third parties are subject to the privacy policy of these third parties.

These cookies help the third parties to:

• count the number of users who clicked on a website, allowing them to calculate the amounts of traffic and thereby establish statistics;
• recognise your device at any subsequent browsing of any other site or service on which these third parties also place these cookies and, if necessary, adapt these third party sites and services to your device.

Third party cookies on our website include:

• Google Analytics, a web analytics service provided by Google Inc., which uses its own cookies to gather information about how visitors use our site. This information is then used for the purpose of compiling statistical reports to enable us to measure and analyse the number of visits to the site and its pages, the average time spent on the site and the pages viewed.
• Social Network cookies, of whom social buttons are visible on our website in order to allow you to share content via the main social networks, including Facebook, Pinterest, Twitter and Instagram. Cookies are placed by these platforms on our site, and allow them to collect information about your browsing.

Except for essential cookies, all cookies will expire after 30 days.

If you require any further information about our Cookie Policy, please contact us.