FICT Limited and its subsidiaries ("FICT") are committed to protecting and respecting your privacy.
about you as a visitor to our website or premises or a contact at one of our customers or potential
suppliers or potential suppliers or other business partners or in any other cases where we specifically
that this policy will apply.
What personal information do we collect from you?
We may collect and process the following personal information about you:
Personal information that you give us:
This is information about you that you give to us by filling in forms on our website (or other forms that
ask you to complete), giving us a business card (or similar) or corresponding with us by telephone, post,
email or otherwise. It may include, for example, your name, address, email address and telephone number;
information about your business relationship with FICT; and information about your professional role,
background and interests.
Personal information that our website and other systems collect about you:
If you visit our website it will automatically collect some information about you and your visit,
the Internet protocol (IP) address used to connect your device to the Internet and some other information
as the pages on our site that you visit. This is used to monitor the performance of the website and
the experience of visitors to the website. Our website may also download "cookies" to your device – this
If you interact with us through social media services, we may be able to access certain information about
interaction, such as whether you have interacted with us through multiple social networks. We make
efforts to ensure that the social media providers have permission from you to allow us to access certain
information about you. Please note that we are not responsible for the manner in which social media
providers handle your personal information that they may collect from you, as this is their
For instance, our website may use plugins of social media networks such as Twitter, Facebook, Linkedin,
Google+. If you use one of these plugins, these plugins are able to establish a direct connection between
browser and the sites of the respective social media networks. As this transfer takes place directly
your browser and the respective network, FICT does not have any access, knowledge or control over any data
sent or the use of this data within the respective social media networks. If you make use of a social
any such content. We encourage you to read the privacy policies and terms and conditions of your social
service providers to understand how they handle your personal information.
Our website may contain links to websites of third parties who are not affiliated to FICT. If you access
third party websites by clicking on such links, we are not responsible for the way in which such third
process your personal information that they collect.
We may make web-based platforms available to our partners and suppliers and such platforms may collect
collected during the registration process and/or the use of such platforms.
If you exchange emails, telephone conversations or other electronic communications with our employees and
other staff members, our information technology systems may record details of those conversations,
including their content.
Some of our premises have closed circuit TV systems and other security and access management systems which
record you and certain information about your visit if you visit our premises, for security and safety
We may also collect some information from other sources. For example:
If we have a business relationship with the organisation that you represent, your colleagues or other
contacts may give us information about you such as your contact details or details of your role in the
We sometimes collect information from third party data providers or publicly available sources for
anti-money-laundering, export control, credit rating background checking and similar purposes, and to
our business and comply with our legal and regulatory obligations.
How will we use your personal information?
We may collect, store and use your personal information for the following purposes:
to operate, manage, develop and promote our business (including our products and services) and, in
our relationship with the organisation you represent (if any) and related transactions including, for
marketing purposes (when we have either gathered prior opt-in consent and/or have a legitimate interest to
send you communications which we believe to be relevant and of use to you);
product compliance processes;
accounting and billing / payment purposes (including to offer financing solutions to customers, together
our finance partners);
to operate, administer and improve our website and premises and other aspects of the way in which we
to provide you with services or information that you may have requested;
to keep you informed and updated on relevant products or services you may be interested in;
to enable you to take part in our online assessments and surveys;
to manage and maintain the relationship with investors; and
to operate recruiting activities;
to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials
other financial or business crimes;
to comply with our legal and regulatory obligations and bring and defend legal claims and assert legal
if the purpose is directly connected with an assigned purpose previously made known to you.
We may from time to time review your information held in our systems – including the contents of and other
information related to your email and other communications with us – for compliance and
purposes as described above. This may include reviews for the purposes of disclosure of information
to litigation and/or reviews of records relevant to internal or external regulatory or criminal
investigations. To the extent permitted by applicable law, these reviews will be conducted in a reasonable
proportionate way and approved at an appropriate level of management. They may ultimately involve
of your information to governmental agencies and litigation counterparties as described below. Your emails
other communications may also occasionally be accessed by persons other than the member of staff with whom
they are exchanged for ordinary business management purposes (for example, where necessary when a staff
is out of the office or has left FICT).
We will only process your personal information as necessary so that we can pursue the purposes described
and where we have a legal basis for such processing. Where our lawful basis for processing is that such
processing is necessary to pursue our legitimate interests, we will only process your personal information
where we have concluded that our processing does not prejudice you or your privacy in a way that would
override our legitimate interest. In exceptional circumstances we may also be required by law to disclose
otherwise process your personal information.
Disclosure and international transfer of your personal information
We may disclose your personal information, where reasonably necessary for the various purposes set out
to the other members of the FICT group of companies;
to your colleagues within the organisation that you represent;
to service providers who host our web services or other information technology systems or otherwise hold
process your information on our behalf, under conditions of confidentiality and security required by law;
business partners, channel partners, service partner, agents, suppliers and sub-contractors for the
performance of any contract we enter into with them or you;
to a person who takes over our business and assets, or relevant parts of them; or
in exceptional circumstances:
to competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any
country or territory; or
where we are required by law to disclose.
These disclosures may involve transferring your personal information overseas. If you are dealing with us
within the European Economic Area, you should be aware that this may include transfers to countries
the European Economic Area, which have not been determined by the European Commission to have an adequate
level of data protection. In those cases, where we transfer your personal information to other members of
FICT group or our service providers, we will ensure that our arrangements with them are governed by
legal mechanisms and safeguards including data transfer agreements, designed to ensure that your personal
information is protected, on terms approved for this purpose by the European Commission.
How long do we keep your personal information?
We will delete your personal information when we no longer need such personal information, for instance
- it is no longer necessary for us to retain your personal information to fulfil the
for which we
had collected it;
- we believe that your personal information that we hold is inaccurate; or
- in certain cases where you have informed us that you no longer consent to our
your personal information.
- there are legal or regulatory requirements which may require us to retain your personal
information for a specified period, and in such cases we will retain your personal information for
specified period; and
- we may need to retain your personal information for certain longer periods for product
liability purposes or in relation to legal disputes, and in such cases we will retain it for such
periods to the extent required.
What are your rights?
You have the following rights (subject to applicable local laws) in relation to the personal information
we hold about you:
to access your personal information, and some related information, under relevant data protection law;
to require any inaccurate personal information to be corrected or deleted;
to object to our use of your personal information for direct marketing purposes at any time and you may
the right to object to our processing of some or all of your personal information (and require them to be
deleted) in some other circumstances;
to require us to delete your personal information in certain circumstances;
to require us to restrict or block the processing of your personal information in certain circumstances
processing is restricted, we can still store your personal information, but may not use it further);
to obtain from us your personal information, in a structured, commonly used and machine-readable format in
certain circumstances. Further, you may have the right to require us to transmit your personal information
directly to another person (for instance a new provider) where it is technically feasible to do so; and
where we are processing your personal information based on your consent to such processing, to withdraw
consent at any time.
Further information and advice about your rights can be obtained from the data protection regulator in
If you wish to exercise any of these rights (subject to applicable local laws), or have complaints about
processing of your personal information, please contact us as set out below. You can also lodge a
about our processing of your personal information with the body regulating data protection in your
We request you not send to or share with us any sensitive personal information (e.g. information related
racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric
criminal background or trade union membership).
Personal Information of Children
FICT respects the privacy of children and does not knowingly collect, use or disclose personal information
children under 16 years of age without verifiable consent from a parent or guardian.
If FICT becomes aware that the information submitted to or collected by FICT is personal information of
children without first receiving verifiable consent from a parent or guardian, FICT will take prompt steps
delete such personal information. If a parent or guardian wishes to raise a concern regarding personal
information pertaining to a child, please contact us as set out below.
Automated Decision Making
We may use technology which tracks your use of our website and your interactions with us and which helps
build a profile of your preferred products and information requests. If we do this, what this means for
that you are more likely to receive offers and information that are tailored to your specific preferences,
based on your previous profile activity.
If we use automated decision making in respect of any specific service or product and such automated
making produces legal effects concerning data subjects or similarly significantly affects them, we will
provide information required by applicable laws in respect of such automated decision making.
If you have any questions, comments and requests regarding this privacy statement or our processing of
personal information, please Contact us.
Changes to this policy
future will be posted to our website and also available if you Contact us. Please check back frequently to