Privacy Notice

GVP Limited is located at 36 Hope Street, Douglas, Isle of Man, IM1 1AR

Company registration no. 019507V

Isle of Man Information Commissioner Registration: TBC

Our Data Protection representative can be contacted by email on: [email protected]

This privacy notice describes how we collect, use and store personal information about you during and after your business relationship with us, in accordance with the Data Protection Act 2018 (DPA 2018) and, the EU General Data Protection Regulation (EU GDPR).

GVP Limited is a data controller. This means that we are responsible for deciding how we hold and use and store personal information about you. We are required under the DPA 2018 / EU GDPR to notify you of the information contained in this privacy notice.

We may update this notice at any time. If relevant (and feasible), we will notify you.

It is important that you read this notice, together with any other privacy notices we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using your personal information.

DATA PROTECTION PRINCIPLES

We will comply with all relevant data protection law (including the DPA 2018 / EU GDPR). This requires that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
7. We are accountable as a Controller for the principles and individual rights with respect to the processing we undertake.

THE KIND OF INFORMATION WE COLLECT AND HOLD ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified, whether directly or indirectly. It does not include data where an individual cannot be identified (anonymous data).

We collect personal data across the business.

For our clients, this is limited to full name, address, telephone number, email address, tax number

For our suppliers and business associates, this is limited to full name, job title and email address.

Personal data is collected through registrations to our client portal on our website (https://www.gvp.partners/) – this is restricted to name and email address. Our website also contains links to third party websites – you should take time to read the Privacy Notices for these.

This personal data is shared with external organisations who support our business operation. These organisations include:

• Google Workspace Platforms (including Gmail)
• Professional advisers
• Regulators and authorities associated with our industry

HOW WE WILL USE INFORMATION ABOUT YOU

As a Data Controller:

We need all the categories of personal data detailed above to allow us to conduct our business operation. Some of the grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you are a client or supplier, then we will need to process your data in line with our legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.

The situations in which we will process your personal information are listed below.

• Administration of a contract we have entered with you and providing our products and services to you.
• Business management and planning, including accounting and auditing. In these instances, we will share your personal data with our accountants and associated reporting platforms.
• Planning for the on-boarding or termination of our contracting relationship.
• Dealing with legal disputes involving you, or any disputes that may arise under the contract that we have with you or the way in which we provide our products and services to you.

RIGHTS OF ACCESS, CORRECTION, ERASURE & RESTRICTION

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

Your Rights:

• Subject Access Request – this enables you to receive a copy of the personal information we hold about you. To action this request, please email the data protection contact: [email protected]
• We require a suitable form of identification and under normal circumstances, we will supply this to you within one calendar month of your request and of identification being received.
• No fee is usually payable; however, we may apply an appropriate fee if the request is deemed to be excessive, or repetitive.
• Request Correction – this enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request Erasure – this enables you to delete or remove personal information when there is no good reason for us to continue processing it.
• Object to Processing – in certain circumstances, you have the right to request we suspend the processing of your data. Please contact us if you require more information on this.
• Request the Transfer – you have the right to request the transfer of your personal data to a third party. Please contact us if you require more information on this.
• Right to Withdraw Consent – where we rely on consent to process your data, you have the right to withdraw this at any time, without giving reason. To withdraw your consent, please contact the data protection officer. Once received, we will not process your data for the reasons you have agreed to, unless we have another legal basis for doing so.
• Right to Complain – you have the right to complain at any time to the Isle of Man Information Commissioner regarding data protection issues - https://www.inforights.im

TRANSFERS OF PERSONAL DATA

Personal data is stored on our Google Workspace platforms. Access to personal data on this is permission-based and stored in the EU, therefore is covered by the existing adequacy agreement.

We reserve the right to update this privacy notice at any time. If you have any questions about it, please contact us at [email protected]

Last updated: April 2022.