Crystal Amber Fund Limited are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us (here, by phone, by email or otherwise), will be processed by us. We will only collect and use personal data in ways that are described here and in a manner that is consistent with our obligations and your rights under the law. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.crystalamber.com or www. crystalamber.com (each, “our Site”) you are accepting and consenting to the practices described in this policy.
1. Definitions
In this policy, the following terms shall have the following meanings:
“Cookie” means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in section 11, below; “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 or superseding legislation; “personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via our Site. This definition shall, where applicable, incorporate the definitions provided in the following legislation: the Data Protection Act 1998 unless and until replaced by EU Regulation 2016/679 — the General Data Protection Regulation (“GDPR”); and “We/Us/our” means Crystal Amber Fund Limited and, for the purposes of the Data Protection Act 1998, We are the data controller.
2. Your Rights
2.1 As a data subject, you have the following rights under the GDPR, which this policy and our use of personal data have been designed to uphold:
The right to be informed about our collection and use of personal data;
The right of access to the personal data We hold about you (see section 10);
The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 12);
The right to be forgotten — i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 12);
The right to restrict (i.e. prevent) the processing of your personal data;
The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
The right to object to Us using your personal data for particular purposes; and Rights with respect to automated decision making and profiling.
2.2 If you have any cause for complaint about our use of your personal data, please contact Us using the details provided in this policy and We will do our best to resolve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
3. What Data Do We Collect?
Depending upon your use of our Site, We may collect personal and non-personal data (please also see section 11 on our use of Cookies and similar technologies) including: time-zone; demographic information such as post code; IP address; web browser type and version; web browser plug-in type and version; operating system; a list of URLs starting with a referring site and the site you exit to; your activity on our Site including date and time, content you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
4. How Do We Use Your Data?
4.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. At all times, We will comply with our obligations and safeguard your rights under the applicable legislation: i.e. the Data Protection Act 1998 unless and until replaced by the GDPR. For more details on security see section 5, below.
4.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or if there are other legitimate grounds under applicable laws. Specifically, We may use your data for the following purposes:
Providing and managing your access to our Site; Personalising and tailoring your experience on our Site; Providing you with information, products and services that you request from Us; Carrying out our obligations arising from any contracts entered into between you and us; Providing you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about; Notifying you about changes to our service; Replying to emails from you; Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by contacting us; Market research; Analysing your use of our Site and gathering feedback to enable Us to continually improve our Site and your user experience; Administering our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
4.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with our obligations under the and the Privacy and Electronic Communications (EC Directive) Regulations 2003, the Data Protection Act 1998 and, upon its implementation, the GDPR.
4.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
4.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases): for so long as you actively interact with our Site, landing pages and/ or communications sent to you by us and for no more than 36 months after you cease such activity.
5. How and Where Do We Store Your Data?
5.1 We only keep your personal data for as long as We need to in order to use it as described above in section 4 and/or for as long as We have your permission to keep it.
5.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”). You are deemed to accept and agree to this by using our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Act 1998 and, upon its implementation, the GDPR.
5.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through our Site.
5.4 Steps We take to secure and protect your data include: secure servers, use of strict procedures and security features to prevent unauthorised access.
6. Do We Share Your Data?
6.1 We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
6.2 We may sometimes contract with third parties to supply services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
6.3 We may compile statistics about the use of our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
6.4 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Act 1998 and, upon its implementation, the GDPR.
6.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
7. What Happens If our Business Changes Hands?
7.1 We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
7.2 In the event that any of your data is to be transferred in such a manner, you will not necessarily be contacted in advance and informed of the changes. However, you retain the right to request the deletion of your data along with all other rights applicable to you as a data subject under the GDPR.
8. How Can You Control Your Data?
8.1 In addition to your rights under the GDPR upon its implementation, as set out in section 2, when you submit personal data via our Site, you may be given options to restrict our use of your data. In particular, We aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).
8.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
9. Your Right to Withhold Information
9.1 You may access certain areas of our Site without providing any data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.
9.2 You may restrict our use of Cookies. For more information, see section 11.
10. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the Data Protection Act 1998, We require the payment of a small fee which will not exceed £10. Under the GDPR, upon its implementation, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact us for more details at CrystalAmberTeam@Ocorian.com
11. Our Use of Cookies
Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of our Site and to provide and improve our services. By using our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on our to improve your experience of our Site. In addition, our Site uses analytics services provided by Google analytics which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use our Site.
11.1 All Cookies used by and on our Site are used in accordance with current Cookie Law.
11.2 Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our Site may not function fully or as intended. You may also be given the opportunity to allow only first party Cookies and block third party Cookies.
11.3 Our Site uses analytics services provided by Google analytics and other third party analytics service providers from time to time. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how our Site is used. This, in turn, enables Us to improve our Site and the services offered through it. You do not have to allow Us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our Site, it does enable Us to continually improve our Site, making it a better and more useful experience for you.
11.4 The analytics service(s) used by our Site use(s) Cookies to gather the required information.
11.5 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
11.6 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
11.7 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
12. Contacting Us
If you have any questions about our Site or this privacy policy, please contact Us by email at CrystalAmberTeam@Ocorian.com, by telephone on +44 (0)1481 742742, or by post at PO Box 286 - Floor 2, Trafalgar Court, St Peter Port, Guernsey, GY1 4LY.
13. Changes to our privacy policy
We may change this privacy policy from time to time (for example, if the law changes). Any changes to this privacy policy in the future will be posted on our Site and, where appropriate, may be notified to you by email. Please check back frequently to see any update or changes to our privacy policy because you will be deemed to have accepted them on your first use of our Site following the alterations.