(together the “Data Subjects” and each such person a “Data Subject“).
CEH Global collects and processes a Data Subject’s Personal Data in accordance with all applicable data protection and privacy laws and regulations it is subject to (the “Data Protection Law“) as described herein.
Information Data Subjects provide
CEH Global collects Personal Data about Data Subjects when they interact with it, either online or offline, for any of the purposes described under Section 4 below.
This can include the following categories of Personal Data:
CEH Global collects the above Personal Data from a number of sources, either directly from the Data Subjects, or from Investees, Suppliers and Service Providers, Partners, Applicants and/or their respective Representatives as part of the conduct of its business.
CEH Global collects and processes Personal Data about the categories of Data Subjects identified under Section 1 for the purposes described under Section 4 on one or more of the following legal bases:
The purposes for which CEH Global collects and processes Personal Data, and the legal bases for such processing, are as follows:
|Purpose of Processing||Legal basis of the Processing|
|To provide Data Subjects with the services they request from CEH Global, to manage contractual relationships, for payment and invoicing and/or to answer questions about CEH Global activities,CEH Global processes: Basic Identification and Contact data, Compliance data, Investee data, Suppliers and Service Providers data, Partners data and Applicants data.||Contract Performance and Legitimate Interests|
|To manage CEH Global business operations, carry out CEH Global business activities and administer CEH Global Investee Companies or Portfolio Companies/Suppliers and Service Providers/Partners relationships,CEH Global uses Basic Identification and Contact data, Compliance data, Investee data, Suppliers and Service Providers data, Partners data and CCTV data. This processing is necessary in order to perform CEH Global business activities and the obligations under contracts with Data Subjects.||Contract Performance and Legitimate Interests|
|To provide relevant marketing such as providing Data Subjects with information about CEH Global business activities that may be of interest to them, by email or other communication means, CEH Global uses Basic Identification and Contact data, Compliance data, Investee data, Suppliers and Service Providers data, Partners data and Applicants data. It is necessary for CEH Global’s Legitimate Interests to process this information in order to provide Data Subjects with tailored and relevant marketing and updates.||Legitimate Interests and Consent|
|To address compliance and legal obligations, such as checking the identity of Investees/Partners and to prevent money laundering and/or fraud, CEH Global uses Basic Identification and Contact data and Compliance data.||Contract Performance and Legal Obligation|
|To consider individuals for employment and contractor opportunities and manage recruitment processes,CEH Global uses Basic Identification and Contact data, Compliance data, and Applicants data.||Contract Performance and Legal Obligation|
|To ensure safety and security at its premises, CEH Global uses CCTV data in accordance with local requirements.||Legitimate Interests|
|To fulfil other legitimate purposes disclosed to Data Subjects at the time they provide their Personal Data or as otherwise permitted or required to comply with applicable laws and regulation.||Legitimate Interests|
CEH Global shall obtain a Data Subject’s prior express consent (opt-in) for the above-listed purposes where required under applicable law.
CEH Global does not sell or otherwise disclose Personal Data which Data Subjects provide to it or that it collects about Data Subjects, except as described below or with a Data Subject’s prior express consent.
It may be necessary to share a Data Subject’s Personal Data with:
Except as described above, CEH Global shall not provide a Data Subject’s Personal Data to other third parties without obtaining their prior permission, unless it is required to do so under a statutory provision or court order. In particular, CEH Global may disclose a Data Subject’s Personal Data in the following circumstances:
These recipients may be located in countries other than the country in which Personal Data was originally collected, inside or outside the European Economic Area (“EEA“).
Certain recipients may be a CEH Global entity located in Hong Kong or in the Cayman Islands, (which are countries that have not been recognized by the European Commission as providing an adequate level of protection of Personal Data within the meaning of the applicable Data Protection Law).
Any transfer of Personal Data to one of the above recipients located in a country outside the EEA that is not recognized as providing an adequate level of data protection, will be made on the basis of data transfer agreement(s) conforming to the EU Commission Standard Contractual Clauses for the transfer of data to third countries (Article 46, 2., (c) of the GDPR, as of 25 May 2018), or (ii) other appropriate safeguards or derogations in accordance with applicable Data Protection Law. A copy of the relevant data transfer agreements may be obtained by using the contact details below (see Section 11).
In specific situations, transfers of a Data Subject’s Personal Data may be based on their explicit consent, after having been informed of the possible risks of such transfers for Data Subjects.
CEH Global takes, and requires that any service provider and/or third party processor processing Personal Data on behalf and under the instructions of CEH Global takes appropriate technical and organizational measures to protect a Data Subject’s Personal Data against accidental or unlawful destruction or accidental loss, misuse, unauthorized access, disclosure, alteration or destruction, and against any other unlawful form of processing of information as defined by the applicable law.
However, please note that no electronic transmission or storage of information is 100% secure. Therefore, despite the security measures that CEH Global has put in place to protect a Data Subject’s Personal Data, it cannot guarantee that loss, misuse, or alteration of data will never occur.
Under applicable Data Protection Law, Data Subjects have the following rights (under the conditions set out in applicable Data Protection Law): (i) to access Personal Data CEH Global holds about Data Subjects, (ii) to request rectification or erasure of Personal Data about Data Subjects, (iii) to request CEH Global to restrict the collection, processing or use of Personal Data about Data Subjects, (iv) in certain circumstances, to object for legitimate reasons to the processing of a Data Subject’s Personal Data (including the right to object, upon request and free of charge, to the processing of Personal Data for direct marketing purposes), and (v) to request data portability. Data Subjects also have the right to lodge a complaint with the competent supervisory authority.
If a Data Subject wants to exercise his/her rights under applicable law, or for more details and questions relating to CEH Global’s data processing activities, Data Subjects may make contact by sending a signed request, together with a valid identification document, to the address below or via e-mail to the contact address set out in Section 11.
Personal Data will not be kept for longer than reasonably necessary for the purposes identified herein, which may be for up to ten years after the end of a Data Subject’s contractual relationship with CEH Global (if any), unless shorter or longer retention periods apply under applicable law.
CEH Global may retain a Data Subject’s personal data relating to a specific job application and selection process to which Data Subjects participated for a period of 5 years following the selection process.
What are the consequences of not providing Personal Data?
Does CEH Global engage in automated decision-making without human intervention?
CEH Global does not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning Data Subjects or otherwise significantly affects them.
Core Equity Holdings SA
326 Avenue Louise
Core Equity Holding SA is the representative of Core Equity Holding Limited in the EU for the purpose of Data Protection Law.