The privacy notice explains how Sparling Financial (hereafter referred to as “SPARLING”) collects, uses, discloses, retains and secures your personal data as part of its business practices. The policy clearly articulates the legal justifications for the processing of your personal data and also lists your data subject rights under the Cayman Islands’ Data Protection Law, 2017 (“DPL”) and the General Data Protection Regulation (“GDPR”).
SPARLING respects your privacy, and you are entitled to have your personal data processed in accordance with the DPL. The key principles SPARLING applies when processing your personal data are as follows:
- Lawfulness: SPARLING will only collect personal data in a fair, lawful and transparent manner.
- Data minimisation: SPARLING will limit the collection of personal data to what is directly relevant and necessary for the services provided.
- Purpose limitation: SPARLING will only collect personal data for specified, explicit and legitimate purposes.
- Accuracy: SPARLING will keep personal data accurate and up to date while there continues to be a client relationship, and in certain circumstances, after that relationship has ended.
- Data security and protection: SPARLING will implement technical and organisational measures to ensure an appropriate level of data security and protection considering the sensitivity of the personal data. Such measures provide for the prevention of any unauthorized or unlawful processing of personal data and against accidental loss or destruction of, or damage to that data.
- Access and rectification: SPARLING will process personal data in line with clients’ legal rights.
- Retention limitation: SPARLING will retain personal data in a manner consistent with the applicable DPL and DPL Regulations and no longer than is necessary for the purposes for which it has been collected in accordance withits retention policy.
- Protection for international transfers: SPARLING will ensure that if personal data is transferred, it is adequately protected.