In the following, we inform about the collection of personal data when using our website and services. Personal data is all data that is personally identifiable to you, e.g. name, address, e-mail addresses, user behaviour.
The body responsible, pursuant to Art. 4 VII GDPR is Sirio Multilateral Strategies Ltd, 86-90 Paul Street, London, England, EC2A 4NE, represented by Alessio Villanacci alessio@sirio-strategies.com
When you contact us via e-mail or a contact form, the data you provide (your e-mail address, if applicable your name and your telephone number) will be stored by us to answer your questions. We delete the data arising in this context after the storage is no longer necessary or limit the processing if statutory retention obligations exist.
You have the following rights regarding personal data concerning you:
· Right of information,
· Right of correction or deletion,
· Right of limitation of processing,
· Right of opposition to the data processing,
· Right to data Transferability.
You also have the right to complain to a data protection supervisory authority about our processing of your personal data.
When using the website for information purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, it is necessary for us to display our website to you and to guarantee stability and security. The legal basis is Art. 6 Para. 1 S. 1 lit. f GDPR (EU General Data Protection Regulation):
· IP address
· Date and time of the request
· Time zone difference to Greenwich Mean Time (GMT)
· Content of the request (specific page)
· Access status/HTTP status code
· The amount of data transferred in each case
· Website from which the request comes
· Browser
· Operating system and its interface
· Language and version of the browser software.
In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive assigned to the browser you use and through which certain information flows to the place that sets the cookie (here by us). Cookies cannot run programs or transmit viruses to your computer. They serve to make the Internet offer more user-friendly and effective overall.
a) This website uses the following types of cookies, the scope and functioning of which are explained below:
i. Transient cookies (see b)
ii. Persistent cookies (see c).
b) Transient cookies are automatically deleted when you close your browser. This includes in particular the session cookies. These store a so-called session ID, with which different requests of your browser can be assigned to the common session. This will allow your computer to be recognized when you return to our website. Session cookies are deleted when you log out or close your browser.
c) Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. You can delete cookies at any time in the security settings of your browser.
You can configure your browser settings according to your wishes and, for example, refuse the acceptance of third party cookies or all cookies. Please note that you may not be able to use all functions of this website.
We use cookies to identify you for follow-up visits if you have an account with us. Otherwise you will have to log in again for each visit.
Your information is processed with the utmost care to facilitate the provision, enhancement, and administration of our Services. Additionally, we engage in communication with you, implement security and fraud prevention measures, and fulfil legal obligations. In certain instances, with your explicit consent, we may process your information for ancillary purposes beyond the aforementioned scope.
Your personal information may be disclosed in the specific circumstances delineated herein, as well as to the third parties identified below:
· Business Transactions: In the event of a merger, asset sale, finance negotiations, or acquisition of our business, either in whole or in part, we reserve the right to transfer or share your personal information as part of the transaction.
· Affiliated Entities: Your personal data may be shared with companies affiliated with us, including our parent company, subsidiaries, joint venture entities, or any other companies under a common control framework. These affiliates are mandated to comply with the provisions of this privacy policy in the handling of your personal information.
Our use of cookies and similar tracking technologies, such as web beacons and pixels, sustains our ability to gather and retain your information. Detailed insights regarding the application of these technologies, along with guidance on the management and refusal of certain cookies, are comprehensively explicated in our Cookie Notice.
Details surrounding the sharing of data can be located within our Data Protection Agreement (“DPA”) distributed upon request. However, for clarity it must be noted that all personal data gathered will automatically be hidden by the AI Triangulation Platform tool and is not visible to either Sirio, our internal users of the tool, nor our sub-processors. This does not apply if the Customer sends Sirio a file manually which contains such data. In this circumstance, we will remove it manually or upload it to the tool for it to be removed automatically through the ‘standard process’ as explained in the DPA.
Your personal information may be subjected to data transfer, storage, and processing across international borders as our servers are positioned in various global locations. Should you access our Services from jurisdictions beyond our server locations, it is important to understand that your data may traverse into, be stored, or be processed in our facilities, or by those third parties with whom we share your information.
For residents of the European Economic Area (EEA) or United Kingdom (UK), it is acknowledged that the data protection laws in these third countries might not be as comprehensive as those within your country of origin. Nonetheless, we commit to implementing all necessary safeguards to protect your personal data in line with this privacy notice and the prevailing legal requirements.
Should you have any questions or need assistance regarding the transfer, storage, or processing of your personal information, please feel free to contact us.
You may review, change, or terminate your account at any time. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you would at any time like to review or change the information in your account or terminate your account, you can. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Your personal information is retained only for the duration required to fulfil the objectives articulated in this privacy notice, except when an extended retention period is necessitated or sanctioned by law due to tax, accounting, or other statutory exigencies.
Upon the expiry of a legitimate business necessity for processing your personal information, we commit to either systematically delete or render it anonymous. In instances where deletion or anonymisation is not immediately feasible (for instance, if your data resides within backup systems), we pledge to securely safeguard your personal information from any additional processing and isolate it until such time as deletion can be affected.
Our Services do not intentionally gather or employ data from individuals who have not attained the age of majority, which is generally recognized as 18 years. By engaging with our Services, you affirm either that you have reached the age of 18 or that you are the parent or legal guardian of a minor, and you grant your consent for such dependent minor's use of the Services.
Should we discover the inadvertent collection of personal information from individuals under the age of 18, we will take immediate action to disable the relevant account and endeavour to expeditiously remove the said information from our systems. If you are aware of any data that may have been obtained from a child under the age of 18, we urge you to reach out to us via email.
We reserve the right to amend this privacy notice periodically to ensure adherence to applicable legal standards. Any revision will be denoted by a new "Revised" date, and amendments will become binding upon publication. In the event of significant modifications, we will inform you by either conspicuously publicizing an announcement of the changes or delivering a direct communication to you. We recommend that you regularly examine this privacy notice to remain apprised of the safeguards we have in place for your information.
Should you have any concerns or require assistance with our privacy practices, please reach out to us.
If you have questions or comments about this notice, you may email us at alessio@sirio-strategies.com.