GDPR

Square Mile Financial Services takes your privacy seriously 

When you provide us with information from which you can be identified or which renders you identifiable (your “personal data”), or we have otherwise captured and use such information then you have certain statutory legal rights in relation to that information. This section is to provide you with some basic information as a helpful guide to the rights you generally have in respect to your personal data, the extent of those rights, and what to do should you wish to exercise any of them. 

Your Rights 

The following is a list of your rights – please note that most rights are not without their limitations and or pre-conditions that may apply to their exercise. 

1. We have a duty to provide you with certain information when we obtain your personal data. 
2. You have a right of access to your personal data. 
3. You have a right to take action to rectify inaccurate personal data. 
4. You have a right to erase personal data. 
5. You have a right to restrict the processing of your personal data. 
6. You have a right to data portability. 
7. You have a right to object to processing of personal data (including direct marketing). 
8. You have a right not to be subject to a decision based solely on automated processing of your personal data, including profiling, which produces legal effect or otherwise significantly affects you. 9. You have a right to seek compensation for any material or non-material damage caused by a breach of our statutory obligations to look after your personal data. 
10. You have a right to lodge a complaint with a data protection supervisory authority. 
11. You have a right to an effective judicial remedy against us. 

You should please note that we are entitled to ensure we have satisfied ourselves as to your identity and/or any authority under which you seek to exercise a right. 

Extent of Rights 

Our duty to provide you with certain information when we obtain your personal data. 
You are entitled to receive information from us about how we use your personal data. Usually, this information must be provided at the time we collect your personal data from you, or, in situations where we obtain your personal data other than directly from you.  

The information you can expect should usually tell you, the purpose for which we use your personal data, the lawful basis we rely on to process that personal data, information regarding who we share it with and why, information relating to how long we hold on to that personal data, and information relating to your rights in respect to it. Such information is provided in what’s generally referred to as a General Data Protection Regulations.  

The right of access to your personal data 

This is a right to obtain from us, without undue delay and in any event within a 1 month period of our receipt of a qualifying request from you: 
i) confirmation as to whether or not we process your personal data;

ii) where that is the case then access to a copy of that personal data; and

iii) additional information from us that is broadly the same as that outlined in the explanation of “Our duty to provide you with certain information when we obtain your personal data” above. 

You should please be aware that this right is to personal data as opposed to documents and that there are a number of general restrictions/exceptions which may apply to any given response on a case by case basis. 

When exercising your right of access then, in addition to satisfying ourselves as to your identity before being obliged to respond to your request, we are also entitled to obtain information from you to help us better source the personal data you are looking for prior to responding. 

Although your request needn’t be in writing then we will always ask that you please confirm it in writing and/or we will confirm it back to you in writing in order to ensure it has been properly understood and evidenced. 

To assist you when exercising this right we have prepared a template data subject access request letter which can be provided on request. 

The right to take action to rectify inaccurate personal data 

This is a right to obtain, without undue delay and in any event within 1 month of receipt of a request, the rectification of inaccurate personal data concerning you, including the right to have incomplete personal data completed, including by your provision of a supplementary statement. 

Unless it proves impossible or involves disproportionate effort then in responding to this right we are required to communicate the rectification to each recipient to whom the personal data have been disclosed and to inform you about those recipients if you so request it. 

In the event something more material needs correcting then our staff will request this please be put to us in writing. A template correction request letter can be provided to you on request. 

The right to erase personal data 

This is commonly referred to as the “right to be forgotten” and is the right to get us to erase personal data concerning you without undue delay and in any event within 1 month of our receipt of such a request. 

Unless it proves impossible or involves disproportionate effort then in responding to this right we are required to communicate the erasure to each recipient to whom the personal data have been disclosed and to inform you about those recipients if you so request it. 

This right is restricted in the sense that it DOES NOT apply to the extent that our processing is necessary, for example, to comply with a legal obligation to which we are subject or for us to establish, exercise or defend a legal claim. 

This right also only applies in one of the following scenarios: 
(a) the personal data are no longer necessary in relation to the purposes for which we needed it; 
(b) we are processing the personal data only with your consent and you withdraw that consent; (c) we are processing the personal data in our legitimate interests and you object to that processing and there are no overriding legitimate grounds for us to continue processing it; 
(d) we are direct marketing to you and you object to that direct marketing; 
(e) the personal data have been unlawfully processed by us; or 
(f) the personal data have to be erased for compliance with a legal obligation to which we are subject. 

A template for data removal request letter can be provided to you on request. 

The right to object to processing of personal data 

This is a right to object to our processing your personal data where we have deemed such processing necessary in our legitimate interests and you disagree. 

 Where you disagree then we need to stop processing the personal data unless we can demonstrate compelling legitimate grounds for processing which override your interests, rights and freedoms, or where our processing is necessary for the establishment, exercise or defence of legal claims. We cannot however override an objection you may make to direct marketing communications.  

Where you exercise this right then we must respond without undue delay and in any event within 1 month of receipt of the objection. 

A template objection request letter can be provided to you on request. 

You also have a right to object at any time to our processing your personal data for direct marketing purposes and if this is exercised we will stop sending you direct marketing communications – please follow the instructions on our marketing communications to unsubscribe to action this specific objection. 

The right to seek compensation for any material or non-material damage caused by our breaching our statutory obligations to look after your personal data 

Where we process your personal data then we can be held liable by a competent court to compensate you for damage caused which infringes our statutory obligations to look after that personal data. 

A data processor (another party who processes your personal data on our behalf and in accordance with our instructions) can also be held liable to compensate you for damage caused by their processing but only where that processor has either not complied with the statutory obligations specifically directed at data processors or where it has acted outside or contrary to our lawful instructions.  

It is a defence against liability for the alleged infringing party to prove that it is not in any way responsible for the event giving rise to the damage.  

If you feel that you have suffered any damage as a result of our processing your personal data then we should always be grateful for the opportunity to try and resolve any issue you might have in the first instance and would ask that you please put your detailed grievance in writing to us. 

In the event that we are unable to satisfactorily resolve your issue and you feel you have suffered damage as a result then you should please seek your own professional legal advice. 

The right to lodge a complaint with a data protection supervisory authority 

You have a right to complain about our handling of your personal data to a data protection supervisory authority regardless of any other administrative or court remedy you may seek. 

Your complaint can either be made to the data protection authority (“DPA”) where you reside, or the authority in the country/territory you work in, or the authority in the place of the alleged infringement of the GDPR. Your complaint can be made to the relevant DPA – our details for DPA in our jurisdictions are at the end. 

The supervisory authority should then keep you informed on the progress of the complaint including the possibility of any judicial remedy you may have. If you have an issue with our processing of your personal data then we should always be grateful for the opportunity to try and resolve any issue you might have in the first inst
Your Rights 
The following is a list of your rights – please note that most rights are not without their limitations and or pre-conditions that may apply to their exercise. 

1. We have a duty to provide you with certain information when we obtain your personal data. 
2. You have a right of access to your personal data. 
3. You have a right to take action to rectify inaccurate personal data. 
4. You have a right to erase personal data. 
5. You have a right to restrict the processing of your personal data. 
6. You have a right to data portability. 
7. You have a right to object to processing of personal data (including direct marketing). 
8. You have a right not to be subject to a decision based solely on automated processing of your personal data, including profiling, which produces legal effect or otherwise significantly affects you. 9. You have a right to seek compensation for any material or non-material damage caused by a breach of our statutory obligations to look after your personal data. 
10. You have a right to lodge a complaint with a data protection supervisory authority. 
11. You have a right to an effective judicial remedy against us. 

You should please note that we are entitled to ensure we have satisfied ourselves as to your identity and/or any authority under which you seek to exercise a right. 

Extent of Rights 

Our duty to provide you with certain information when we obtain your personal data. 
You are entitled to receive information from us about how we use your personal data. Usually this information must be provided at the time we collect your personal data from you, or, in situations where we obtain your personal data other than directly from you.  

The information you can expect should usually tell you, the purpose for which we use your personal data, the lawful basis we rely on to process that personal data, information regarding who we share it with and why, information relating to how long we hold on to that personal data, and information relating to your rights in respect to it. Such information is provided in what’s generally referred to as a General Data Protection Regulations.  

The right of access to your personal data 

This is a right to obtain from us, without undue delay and in any event within a 1 month period of our receipt of a qualifying request from you: 
i) confirmation as to whether or not we process your personal data; ii) where that is the case then access to a copy of that personal data; and iii) additional information from us that is broadly the same as that outlined in the explanation of “Our duty to provide you with certain information when we obtain your personal data” above. 

You should please be aware that this right is to personal data as opposed to documents and that there are a number of general restrictions/exceptions which may apply to any given response on a case by case basis. 

When exercising your right of access then, in addition to satisfying ourselves as to your identity before being obliged to respond to your request, we are also entitled to obtain information from you to help us better source the personal data you are looking for prior to responding. 

Although your request needn’t be in writing then we will always ask that you please confirm it in writing and/or we will confirm it back to you in writing in order to ensure it has been properly understood and evidenced. 

To assist you when exercising this right we have prepared a template data subject access request letter which can be provided on request. 

The right to take action to rectify inaccurate personal data 

This is a right to obtain, without undue delay and in any event within 1 month of receipt of a request, the rectification of inaccurate personal data concerning you, including the right to have incomplete personal data completed, including by your provision of a supplementary statement. 

Unless it proves impossible or involves disproportionate effort then in responding to this right we are required to communicate the rectification to each recipient to whom the personal data have been disclosed and to inform you about those recipients if you so request it. 

In the event something more material needs correcting then our staff will request this please be put to us in writing. A template correction request letter can be provided to you on request. 

The right to erase personal data 

This is commonly referred to as the “right to be forgotten” and is the right to get us to erase personal data concerning you without undue delay and in any event within 1 month of our receipt of such a request. 

Unless it proves impossible or involves disproportionate effort then in responding to this right we are required to communicate the erasure to each recipient to whom the personal data have been disclosed and to inform you about those recipients if you so request it. 

This right is restricted in the sense that it DOES NOT apply to the extent that our processing is necessary, for example, to comply with a legal obligation to which we are subject or for us to establish, exercise or defend a legal claim. 

This right also only applies in one of the following scenarios: 
(a) the personal data are no longer necessary in relation to the purposes for which we needed it; 
(b) we are processing the personal data only with your consent and you withdraw that consent; (c) we are processing the personal data in our legitimate interests and you object to that processing and there are no overriding legitimate grounds for us to continue processing it; 
(d) we are direct marketing to you and you object to that direct marketing; 
(e) the personal data have been unlawfully processed by us; or 
(f) the personal data have to be erased for compliance with a legal obligation to which we are subject. 

A template for data removal request letter can be provided to you on request. 

The right to object to processing of personal data 

This is a right to object to our processing your personal data where we have deemed such processing necessary in our legitimate interests and you disagree. 

 Where you disagree then we need to stop processing the personal data unless we can demonstrate compelling legitimate grounds for processing which override your interests, rights and freedoms, or where our processing is necessary for the establishment, exercise or defence of legal claims. We cannot however override an objection you may make to direct marketing communications.  

Where you exercise this right then we must respond without undue delay and in any event within 1 month of receipt of the objection. 

A template objection request letter can be provided to you on request. 

You also have a right to object at any time to our processing your personal data for direct marketing purposes and if this is exercised we will stop sending you direct marketing communications – please follow the instructions on our marketing communications to unsubscribe to action this specific objection. 

The right to seek compensation for any material or non-material damage caused by our breaching our statutory obligations to look after your personal data 

Where we process your personal data then we can be held liable by a competent court to compensate you for damage caused which infringes our statutory obligations to look after that personal data. 

A data processor (another party who processes your personal data on our behalf and in accordance with our instructions) can also be held liable to compensate you for damage caused by their processing but only where that processor has either not complied with the statutory obligations specifically directed at data processors or where it has acted outside or contrary to our lawful instructions.  

It is a defence against liability for the alleged infringing party to prove that it is not in any way responsible for the event giving rise to the damage.  

If you feel that you have suffered any damage as a result of our processing your personal data then we should always be grateful for the opportunity to try and resolve any issue you might have in the first instance and would ask that you please put your detailed grievance in writing to us. 

In the event that we are unable to satisfactorily resolve your issue and you feel you have suffered damage as a result then you should please seek your own professional legal advice. 

The right to lodge a complaint with a data protection supervisory authority 

You have a right to complain about our handling of your personal data to a data protection supervisory authority regardless of any other administrative or court remedy you may seek. 

How to complain about the use of your data:

If you wish to raise a complaint about how we have handled your personal data, including in relation to any of the rights outlined above, you can contact our Data Protection Officer, Alan West, at Alan.West@squaremileint.com or write to him at the Prague address.

If you are not satisfied with our response or believe we are processing your data unfairly or unlawfully, you can complain to The Office for Personal Data Protection: https://www.uoou.cz

Disclaimer 

Whilst every care has been taken in preparing this booklet, no member of the Square Mile Financial Services gives any representation, warranty or undertaking and accepts no responsibility or liability as to the accuracy, or completeness, of the information. The information contained does not purport to be complete and is subject to change. 

For the avoidance of doubt, our duties and responsibilities do not include legal, or other specialist or technical advice or services. You are to rely on your independent appraisal of and investigations into the information provided, and we advise you received specialist legal advice if you have any concerns regarding your data protection rights

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