Privacy Notice and FAQs

We collect directly from you and we use your Personal Data as a Client.

Types of Personal Data, which we collect from you as a prospective client during the period prior to entering into a contractual relationship with you, are your full name, your contact details (e.g. email address, telephone number etc.) and your IP address.

Types of Personal Data which we collect during the period of our contractual relationship are: (i) your full name, home, professional and email addresses, telephone number, copies of ID and passport, Tax Identification Number, nationality, country of residence, date of birth, gender, marital status and occupation; (ii) billing and payment details, bank accounts details, credit card details; (iii) clean criminal record certificate, CV, marital certificate, certificate of birth, proof of income.

In the course of our relationship you provide Personal Data to us such as full names, dates of birth, copies of IDs and passports, marital certificate, certificates of birth about other individuals such as your family members and/or dependants. By providing such information, you represent and warrant to us that you have obtained such individuals’ permission to so do and that such individuals are aware of, understand and accept our Privacy Policy and this Notice.

IMPERIO collects and processes your Personal Data for the following purposes: (i) taking steps at your request prior to entering into a contract; (ii) performing a contract or transaction to which you are a party; (iii) better understanding and address your interests and preferences; (iv) to comply with obligations imposed by law or regulations; and (v) managing and improving our products, services, programs, various types of communications, advertising campaigns, and/or promotional activities, our day-to-day operations.

We are committed to collecting and processing your Personal Data in accordance with applicable data protection laws. We will only process your Personal Data if at least one of the following conditions applies: (a) you have given us your consent; or (b) processing is necessary: (i) for the performance of a contract with you or to take steps at your request prior to entering into a contract; (ii) for compliance with a legal obligation; (iii) to protect your vital interests or of another individual; (iv) for the purposes of our or a third party’s legitimate interests and these are not overridden by your interests or fundamental rights.

We apply strict security rules regarding the processing of Personal Data and third parties’ access to our records and files. We only share your Personal Data when this is necessary to conduct our business or to fulfill an obligation imposed by law.

We may share your information with: (i) our affiliated companies, third-party partners, service providers, suppliers, management committee, bankers, insurance companies, insurance brokers, lawyers, Land Registry Office, Sewerage Board, Community Board, Electricity Authority and other boards and/or authorities and retail partners for the purposes of operating and providing you with the products and services that you have requested; (ii) professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities; (iii) any third party in order to meet our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts, tax, regulatory or other public authorities.

When we share Personal Data with other organizations/ third-parties, we safeguard that they keep them safe, that they are authorized to retain these data and that they must not use your Personal Data for other purposes. Such sharing or transfers of Personal Data will be protected by appropriate safeguards (e.g. appropriate contractual clauses, data processing contracts, intra-group disclosures of personal data, etc.) and if the recipient operates outside the EEA, appropriate protections will be put in place to make sure your personal data remains adequately protected including appropriate contract clauses such as standard contract clauses approved by European Commission.

We recognise the importance of information security, and we are constantly reviewing and enhancing our technical, physical, and logical security rules and procedures.

We are committed not to retain Personal Data for a period longer than necessary for the reasons that the Personal Data was obtained and/or to meet legal and regulatory requirements.

Under the circumstances and the conditions provided under GDPR, you have the following rights with respect to your Personal Data:

• The right to request from us access to and rectification or erasure of your Personal Data;
• The right to restrict processing, object to processing as well as in certain circumstances the right to data portability;
• The right to withdraw your consent to the processing at any time;
• The right to lodge a complaint with the competent Data Protection Authority.

To exercise any of your rights please submit the Data Subject’s Request Form to our Data Protection Officer at gdpr@imperio-group.com

Please note that we may ask you to verify your identify before we can act on your request. We may ask you for more information to ensure that you are authorized to make such a request when you contact us on behalf of another Data Subject.

The Company may amend this Privacy Notice from time to time in order to meet changes in the regulatory environment and business needs.

“Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject“); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

“Special categories of personal data” means the Personal Data referring to racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation;

“processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, use, disclosure, alignment, restriction, erasure;

“consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he/she, by a statement or by a clear affirmative action, signifies agreement to the processing of Personal Data relating to him or her;

“Data Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data;

“Data Processor” means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller.