1. Purpose of this notice
This Policy describes how Sarossa Plc collect and use personal data and provides information about individuals' rights in relation to such data, in accordance with the General Data Protection Regulation ("GDPR"), and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, as applicable in the Jersey ('Data Protection Legislation').
Personal data is any information relating to an identifiable living person. Sarossa Plc may process personal data for numerous purposes. For each purpose the means of collection, lawful basis of processing, disclosure and retention periods may differ.
2. About us
Sarossa Plc ("Sarossa", "the Company", "we", "us", "our") is an investment company registered in the Jersey with company number 115158. The Company's registered office is Floor 1 Liberation Station, The Esplanade, St Helier, Jersey, JE2 3AS.
If you have any questions relating to this notice, please write to us at the address detailed in Section 12 below.
3. How we may collect your personal data
You, or your employer, your nominee and broker or the Company's registrar and transfer agent may provide us with personal data via the completion of forms, submission of data files, through correspondence sent to us by post or by email, or over the telephone. This may also include sensitive information received directly from you in relation to the operations we conduct.
Personal data may be obtained from third parties as permitted by law. We may also use legal public sources to obtain information about you, for example to verify your identity. This information (including your name, address, date of birth, email address, etc) as relevant to us, will only be obtained from reputable third-party companies that operate in accordance with the General Data Protection Regulation (GDPR).
The provision of this personal data is essential for us to ensure that we are able to operate our business in a normal and reasonable manner. The lawful basis for our processing and holding of personal data will be one of more of the following:
- To enable us to meet contractual commitments
- To ensure our compliance with legal obligations
- As we have a genuine legitimate business interest in the information
4. The types of information we may hold about you
The types of information we hold about you may, inter alia, include the following:
- your personal details (such as your name, address, date of birth, social security number, tax code, email address, contact number, bank account details);
- our correspondence and communications with you;
- information about any complaints and enquiries you make to us;
- information we receive from other sources, such as publicly available information or third-party service providers.
5. How we use your personal data
We use your personal data to provide, manage and fulfil the statutory and regulatory requirements that we are obligated to comply with and to enable the provision of our services as would be reasonably expected. At all times we undertake to protect your personal data, in a manner which is consistent with our duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection. We will always take all reasonable security measures to protect personal data in storage and in transit. As applicable, the information provided may be used to (this list is not exhaustive):
Administer and manage our business
We process personal data in order to operate our business, including; managing our relationship with shareholders, employees and suppliers, developing our business and services, maintaining and using IT systems, and administering and managing our website and internal systems.
Provide investors and potential investors with information
We may use personal information in order to provide investors and potential investors with updates as to our financial performance, key operational developments and any upcoming Company meetings.
Comply with a requirement of law or regulation
As with any company of our nature, we are subject to legal, regulatory and professional obligations. We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide or elect to withhold certain information from us, we may not be able to perform the contract we have entered into with you. In addition we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
6. Sharing data
We will keep information about you confidential and secure. We will never share personal data with a third party unless there is a lawful basis for doing so and we will never share your data outside of the Company for marketing purposes.
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required to by law or regulation or where it is reasonably necessary in order to deliver the contract or relationship between us.
Which third-party service providers process my personal data?
Personal data held by us may be transferred to:
- Regulatory authorities including the Jersey tax authorities, HMRC, and other fraud prevention agencies for the purposes of fraud prevention and to comply with any legal and regulatory issues and disclosures;
- Any legal or crime prevention agencies and/or to satisfy any regulatory request if we have a duty to do so or if the law allows us to do so;
- Third-party organisations that provide software/applications/functionality, data processing or IT services to us, to support us in providing our services and to help provide, run and manage our IT systems. For example, providers of cloud-based or server-based accounting and payroll software, data back-up, identity verification services;
- Third-party organisations that may assist us, you, your employer, or our clients with the provision of services. For example, Auditors, Share Registrar and Transfer Agent, regulated nominated advisers, brokers and pension administrators.
7. Transferring personal data outside the European Economic Area (EEA)
In operating our business and website it may become necessary to transfer data that we collect from you to locations outside of the European Economic Area (EEA), for processing and storing. By providing your personal data to us, you agree to this transfer, processing or storing. This may involve the transfer of data by electronic media.
8. Data security
We have put in place commercially reasonable and 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 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
9. Rights of access, correction, erasure and restriction
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify your broker, nominee holder, the company's registrar or if applicable Sarossa Plc of any changes of which we need to be made aware.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please contact us.
You will not have to pay an initial fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
10. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
11. Changes to this notice
We reserve the right, at all times, to update, modify or amend this policy. Any significant changes we may make to our privacy notice in the future will be notified and updated on our website at www.sarossaplc.com.
This privacy notice was last updated on 24 May 2018.
12. Contact us
If you have any questions regarding this notice or if you would like to speak to us about the way we process your personal data, please either write to us at Floor 1 Liberation Station, The Esplanade, St Helier, Jersey, JE2 3AS or email us at [email protected].