Monaco Sports and Management SAM: Privacy Notice

General Data Protection Regulation

New regulations concerning Data Protection ("GDPR" or the General Data Protection Regulations) came into force in the European Union ("EU") with effect from 25th May 2018. The aim of the GDPR is to give further protection to people whose personal data is controlled or processed by third parties, such as Monaco Sports and Management SAM ("we", "us", or "our").

What Personal Data do we collect and what do we use it for?

In order to do the work our clients ask us to perform, we need to control and process personal data relating to our clients and in certain circumstances, Connected Parties*. This data could include some or all of the following:

Name
Address
Date of birth
Telephone numbers
Email addresses
Passport information
Tax identification numbers
National insurance or social security numbers
Bank account details
Investment account details
Similar data relating to your spouse and children

Most of this data has been obtained by us from our clients but occasionally we obtain it from third parties our clients put us in touch with.
We have a duty to treat this data carefully and only to use it for the purposes intended. Unless otherwise advised, we will only use the data for the purposes of the performance of our work for our clients, to comply with any legal requirements, to protect our legal position or to pursue our legitimate interest in administering our business.

How Long do we keep personal data?

We will not store personal data for longer than is necessary. We are obliged to keep some of this data for periods of six years or even longer in some cases in order to comply with tax law, for example. Our general policy is to keep client records for 10 years, and this will include data listed above. After this time, the records are destroyed, unless the records relate to investment work in which case they will be kept until 6 years after the relationship ends.

How do we keep your personal data secure?

We have policies and procedures in place in order to protect data from unauthorised access, loss or other forms of breach whether in physical or electronic form. The security measures we take are proportionate to the size of our business. Despite the security measures we implement, please be aware that the transmission of data via the internet is not completely secure. As such, we cannot guarantee that information transmitted via the internet will be completely secure and we do not accept any liability in connection therewith.

Who do we share personal data with?

In order to do the work that we do, we will from time to time need to pass personal data to third parties. For example, (without limiting the generality of the foregoing):-

(A) To Service providers: We might share personal data with third party agents and contractors for the purposes of providing services to our clients, (for example, accountants, professional advisors, IT and communications providers);

(B) To Business partners: For example, this could include asset managers or other business intermediaries, for example if a client needs a tax return prepared in a foreign country, this will be done with the help of a professional in that country who will need to know our client's name and other items of personal data.

(C) To the extent required by law, for example (i) in certain circumstances under anti money laundering legislation ("AML") we are under a duty to check the credentials of clients and Connected Parties and data relating to clients and Connected Parties will be to disclosed to external service providers for AML checks to be made; (ii) to any legal or government regulatory authorities in response to their requests for such information or to assist in investigations; (iii) We may also disclose personal data to third parties in connection with claims, disputes or litigation, or when otherwise required by law, or if we determine its disclosure is necessary to protect us or our clients.

We will only send data that is necessary and appropriate according to the circumstances.

Do we send any of your personal data outside of the EEA?

We will ensure that the third party to whom the data is sent will treat it in accordance with the GDPR, or if outside the EU, in a manner which is consistent with how your personal data would be protected in the EU.

Your rights

If you have a complaint about the use or mis-use of your personal data, you have the right to complain to Monaco Sports and Management SAM and also to the supervisory authority in the EU member state in which you are based. Details of your local supervisory authority can be found using the following link:-
http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

We would ask that if you are not clear about this subject, that you please contact us to discuss it in order to understand it better.

The GDPR includes the following rights for individuals:

The right to be informed: The right to be informed encompasses our obligation to provide 'fair processing information', typically through a privacy notice. It emphasises the need for transparency over how personal data is used.
The right of access: Under the GDPR, individuals will have the right to obtain confirmation that their data is being processed, access to their personal data, and other supplementary information, such as the information that should be provided in a privacy notice.
The right to rectification: Individuals are entitled to have personal data rectified if it is inaccurate or incomplete.
The right to erasure: The right to erasure enables an individual to request the deletion or removal of personal data when there is no compelling reason for its continued processing.
The right to restrict processing: When processing is restricted, it is permitted to store personal data, but not to further process it.
The right to data portability: The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services.
The right to object: Individuals have the right to object to processing based on legitimate interests
The right not to be subject to automated decision-making, including profiling: The GDPR provides safeguards for individuals against the risk that a potentially damaging decision is taken without human intervention.

If you want to exercise any of these rights, please contact us (details below). Note that your exercising certain of these rights (such as the right to erasure and the right to restrict processing) will likely mean that we are no longer able to provide client services.
You will not have to pay a fee to exercise your rights, unless your request is clearly unfounded, repetitive or excessive (in which case we can charge a reasonable fee). Alternatively, we may refuse to comply with your request in these circumstances. Where your request is legitimate, we will always respond within one month (unless there is a legal reason to take longer, such as where your request is particularly complex). We may also need you to confirm your identify before we proceed with your request if it is not clear to us who is making the request.

Contacts

Data Protection Officer:
If you have any questions in this regard, please contact Edward Porter on +377 93104250 or edward.porter@msm.mc , or at Monaco Sports and Management SAM, Est-Ouest, 24 Blvd Princesse Charlotte, Monte Carlo, 98000, Monaco

*Connected Parties means any party in relation to whom we are required by law to collect personal data and shall mean in particular (but without limiting the generality of the foregoing) persons or entities who a client receives money from, or pays money to; and persons or entities who act as directors or settlors or trustees or protectors of client entities.