We, PWS Group LTD, (henceforth "PWS Group"), as responsible for the processing, value your privacy and data protection is of a particularly high priority for us. The processing of personal data by PWS Group shall always be in line with applicable data protection laws and with the European General Data Protection Regulation ("GDPR").

This privacy policy is made available publicly to inform data subjects of the data processing by PWS Group. PWS Group provides personal financial planning and wealth management services ("Service").

1. Name and Address of the controller:

1.1. Controller

Stephen Stewart Responsible for collecting and processing your personal information as a controller is PWS Group with the following contact details:

PWS Group
Bay Square, Business Bay, Building 11, Office 701
P.O. Box 74650, Dubai, United Arab Emirates
Phone: +971 (0) 4 556 1433
Email: DPO@pws-intl.com
Website: www.pws-intl.com

1.2. Representation for Data Subjects in the EU:

PWS Group has appointed a representative according to Art 27 GDPR. If you want to make use of your GDPR data privacy rights via our representative, please visit: https://gdpr-rep.eu/q/12612575

Representative is:

GDPR-Rep.eu
iuro | Dr. Andreas Mätzler
Attorney at Law
c/o PWS Group
Schellinggasse 3/10
1010 Vienna, Austria

Please add the following subject to all correspondence:

GDPR-REP ID: 12612575

1.3. Data Protection Officer

PWS Group has appointed Stephen Stewart as Data Protection Officer according to Art 37 GDPR. Data Protection Officer and its contact details are:

Mr Stephen Stewart
PWS Group
Bay Square, Business Bay, Building 11, Office 701
P.O. Box 74650, Dubai, United Arab Emirates
Phone: +971 (0) 4 556 1433
Email: DPO@pws-intl.com
Website: www.pws-intl.com

2.  Which personal information is collected and processed

2.1. PWS Group's Service

  • Your personal information may be collected during the provision of PWS Group's Services or through the use of our website.

Personal information processed includes, information you provide us with such as

  • basic Personal Data (such as name; age; address; gender; nationality; citizenship; address; telephone numbers; email address; date of birth); and
  • financial or tax information, as requested in connection with PWS Group's Services (such as advisor details; investment details; banking or other financial details; employment history; social and/or national insurance number; tax identification number(s) and details of tax residency).

and information about you collected or generated or obtain from other sources, such as

  • information regarding transactions, such as amounts and dates of trades, amount of account assets, and communications with us;
  • a file with your contact history to be used for enquiry purposes to check satisfaction with services provided;
  • information we are legally obligated to generate or collect, such as information for compliance or record-keeping obligations.

We do not track or profile by systematically sourcing publicly available data on you.

We do not process sensitive data or data of children and minors.

2.2. Log files through use of our Website

Through your use of the Website, we gather, collect and store the following data:

  • IP Address and IP location
  • Referring (exit pages and URLs)
  • Number, duration and time of visits (your interaction with the Website)
  • Search engines, key phrases and keywords used to find our site
  • Browser type, type of device, screen size, internet service provider and operating system

We collect these log files automatically by using cookies (for further details please see below). The log files collected are only used for statistical evaluations in an aggregated form for the purpose of operation, security and optimization of the Website.

3. How and on what legal basis PWS Group use your personal information

We use your information to:

  • provide and improve the Services we provide;
  • to promote our Services, by sending news and publications, newsletters and details of events;
  • orient and direct our relationship with you and our clients;
  • provide and improve our website, including by auditing and monitoring its use;
  • to process your request and provide information requested by you;
  • for recruitment purposes

We use your personal information on the following grounds:

  • in the stadium prior to entering a contract or negotiations and due to contractual obligation, especially by the Services we offer;
  • with your specific consent, especially to process your requests;
  • to comply with regulatory and legal obligations especially regarding data protection;
  • due to overriding legitimate interest in case of the log files through your use of our website.

4. For how long we keep personal information

We store your personal data just for as long as we need it for the fulfilment of the abovementioned purposes and our contractual and legal obligations. When we no longer need your personal data, we erase it from our systems and records or anonymise it so that you cannot be identified anymore.

5. With whom we share your personal information

5.1. With which types of providers/contractors do we share your personal data

We may share your personal information with third parties in accordance with contractual rights and obligations, including:

  • To provide PWS Gourp's Services with third party financial institutions;
  • our professional consultants and auditors;
  • IT-providers, providers of other tools, software solutions and marketing tools as well as further providers with similar services; these are at the moment Microsoft for Office 365, Salesforce for CRM and Box.com (UK) Ltd.for secure file holding.
  • third parties involved in the Services we provide, such as lawyers, enforcement agents, local consultants and others;

Some of the above-mentioned entities may be controller on their own and process your personal data under their own responsibility, such as third party financial institutions. Entities which are processor process your data solely on our behalf and on the basis of our instructions for the purposes as described above.

If, in the future, we reorganize or transfer all or part of our business, we may need to transfer your personal information to new entities linked to PWS Group or to third parties through which PWS Group's Services will be provided.

PWS Group does not commercially sell, rent or dispose of personal information to any third party.

PWS Group transfer personal data to data centers in third countries in respect of the Services:

  • Microsoft for Office 365,
  • Salesforce for CRM and
  • Box.com (UK) Ltd.

5.2. What are the safeguards to protect your personal data when transferred outside the European Economic Area ("EEA")

PWS Group is located outside the EEA. We may transfer personal data to providers/contractors inside and outside the EEA.

In case PWS Group transfers personal data from inside the EEA to providers/contractors outside the EEA, appropriate safeguards to protect such information are taken. This may be done in a number of ways, for instance:

  • the recipient might have signed "model contractual clauses" approved by the European Commission, obliging the recipient to protect your Personal Data;
  • the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data; or
  • where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme (or such equivalent scheme as approved by appropriate Regulatory Bodies from time to time).

Such a transfer outside the EEA may also be conducted where you have consent to do so. If we rely on your consent to transfer Personal Data outside the EEA, you have the right to withdraw such consent at any time. In all cases, we will endeavour that any transfer of your Personal Data is compliant with relevant data protection law.

You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA (including a copy of any standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us.

6. Use of Cookies, Social Networks, Web Analyses and Re-Targeting

Cookies

Cookies are used in different parts of our website. Cookies are small text files which are able to recognise users when they use our website on another occasion. They do not save any personal details such as a person's name or address, however. This means that you cannot be identified due to the corresponding information.

We use cookies for the purpose of configuring our offers to your requirements and for analysing the way in which these offers are used. You can make the appropriate settings on your browser so that your consent must be obtained before the use of a cookie, or so that the general use of cookies is blocked. You can generally also use our website without cookies.

Social networks

We cooperate with a variety of social networks. If you use these social networks, your browser will connect automatically with the appropriate network. In this context, it will transfer your IP address and other information such as cookies if you have previously visited the appropriate platform.

As far as possible, we avoid this method of data transfer unless you actually interact with one of the platforms. By clicking on the appropriate symbol (such as the Facebook logo), you indicate that you are prepared to communicate with the chosen platform and that information regarding your person such as your IP address will be transferred to this social network.

Web analytics

Provided that you have consented to the use of cookies, the website uses Google Analytics, a web analysis service of Google Inc. ("Google"). Google Analytics uses cookies to enable analysis of the use of the website. The information created by cookies about the use of this website by the users is ordinarily transmitted to a Google server in the USA or a different state outside of the EU and saved there.

The following data is collected by Google Analytics: IP address, browser, device type, device model, state, service provider, screen resolution, length of stay on the Website, language, operating system, and visited pages on the Website. Google will use this information to evaluate your use of the Website and create reports about the Website activities for us.

You can also prevent the placement of cookies through the settings of your browser or by downloading and installing the browser plug-in available at the following link:

http://tools.google.com/dlpage/gaoptout?hl=de.

Re-targeting

To allow us to configure our advertising messages to your interests and to be able to offer you products and services that are as suitable as possible, we use re-targeting and tracking software. During the course of re-targeting and tracking, cookies are placed during your visit to our website and your IP address is forwarded to third parties (advertisers, web services, data management platforms, media agencies, publishers). We do this so that we can offer you customised advertising, offers and services.

7. How your personal information is protected

We use a variety of technical and organizational measures to help protect your personal information from unauthorized access, disclosure, modification, loss or destruction in accordance with applicable data protection laws.

8. What rights do you have?

GDPR and other applicable data protection laws protect certain rights for data subjects. In particular:

Right of Access - right to obtain confirmation of which of your personal information is processed and information about it, for instance, which are the purposes of the processing, what are the conservation periods, among others.

Right of Rectification - right to request modification of your personal information that is inaccurate or request incomplete personal information, such as the address, VAT, email, telephone contacts, or others.

Right to Erasure or "right to be forgotten" - right to erase your personal information, provided that there are no valid grounds for its retention, for example in cases where PWS Group has to keep the data to comply with legal obligation or because a court case is in progress.

Right to Data Portability - right to receive the data you have provided us in a digital format of current use and automatic reading or to request the direct transmission of your data to another entity that becomes the new responsible for your personal information, however only if technically possible.

Right to Withdraw Consent or Right of Opposition - right to object or withdraw consent at any time to data processing, for example in the case of data processing for marketing purposes, provided that no legitimate interests exist prevailing over your interests, rights and freedoms, such as defending a right in a judicial process.

Right of Limitation - right to request the limitation of the processing of your personal information, in the form of: (i) suspension of processing or (ii) limitation of the scope of processing to certain categories of data or purposes of processing.

Right to object and automated individual decision-making - When the processing of personal information, including the processing for the definition of profiles, is exclusively automatic (without human intervention) and may have effects in your legal sphere or significantly affect it, the Client shall have the right not to remain subject to any decision based on such automatic processing, except as otherwise provided by law and shall have the right that PWS Group take appropriate measures to safeguard its rights and freedoms and legitimate interests, including the right to have human intervention in decision making by PWS Group, the right to express its point of view or contest the decision taken on the basis of automated individual information processing.

Right to complain - right to complain to the supervisory authority, in addition to PWS Group.

The exercise of rights is free of charge, except in the case of a manifestly unfounded or excessive request, in which case a reasonable fee may be charged regarding its costs.

The information must be provided in writing but may be given orally if requested. In this case, PWS Group should verify your identity by means other than oral.

The response to requests should be provided within a maximum of 30 days, unless it is a particularly complex request.