Data Protection Policy

Data Protection Policy – Specific information related to Farad Group Services (FGS)

In the event of doubt in the application of the principle described below, the employee shall refer to its superior and/ or escalate the matter to the Senior Management.

All personal data collected prior to 25/05/2018 are considered compliant with this Policy and GDPR. Personal data received prior to 25/05/2018 and process after 25/05/2018 shall be fully revised in light of GDPR and this Policy

1.      Qualification

 FGS qualifies as processor in its relation with SELECTRA Management Company S.A.; FIA Asset Management S.A. and Farad International S.A

2.        Lawfulness, fairness and transparency

 The process of personal data is based on the consent of the data subject when any other legal basis cannot be used. The process of personal data is always considered as lawful when based on what is necessary for the performance of a contract and/ or to comply with European and Luxembourg laws and regulations related to the financial sector such as legislation related to anti-money laundering and fight against financial terrorism.

In addition to the aforementioned information, each time an employee of FGS collect personal data, it shall explain to the data subject the purpose followed in the collection of personal data and the legal ground to collect personal data.

3.      Right to data subject

 Prior to collect any personal data, FGS and its employees inform the data subject about their rights and invite them to consult their website.

In addition , FGS or its employees provide the contact details or person to contact in case of any question related to GDPR and/or the contact detail of the DPO (if any)

4.      Purpose limitation, minimisation, accuracy and storing period

 FGS’s specific, explicit and legitimate purpose to process personal data is defined in article 3 of the article of incorporation of FGS. Within FGS each department followed this purpose based on the activity performed at department level. Each time personal data already collected and processed are process again, the employee of FGS processing the personal data ensures that the processing is in line with the initial purpose for which the processing initially occurred.

FGS processes only personal data which are adequate, relevant and necessary to comply with the law or follow its purpose as indicated above.

FGS or its employees ensure that the personal data provided by the data subject are accurate and if necessary, request the data subject to send up to date personal data information

FGS store personal data for a limited period taking into account the objective pursued by the processing. When the storage period ends, FGS shall either anonymise the personal data or destruct them.

The person of contact for any GDPR query at the level of FGS is Mrs. Nicoletta Morsut.

Full Data Protection Policy document available here