Privacy Policy

 

 

Protecting your personal information is an important priority for us. This privacy policy is designed to support this objective and, where applicable, sets out how we – SM Real Estates EAD, will process personal information as a Data Controller.

We collect non-public personal information provided by you or your representative on applications or other forms furnished to us or through other interactions that you or your representative have with us. We urge you to read this Privacy Policy carefully as it contains important information on who we are, how and why we collect, store, use, and share personal information and on how to contact us and supervisory authorities in the event you have a complaint. This Privacy Policy applies to this website elysian-chalet.com owned and operated by SM Real Estates EAD, and as well as all services provided by SM Real Estates EAD.

We do not disclose any non-public personal information about you, except as permitted by law.

How and Why We Obtain Information

We may receive non-public personal information about you (the “Personal Information”) from any of the following sources:

Your applications or forms (for example, name, address, assets); Information from consumer reporting agencies;

Information from other third-party data services (for example, to verify your identity and to better understand your product and service needs); Other sources with your consent;

We may process the Personal Information for the following purposes:

  • Managing our relationship with you (the “Services”);
  • Contact you with regards to your enquiry;
  • We will (or through a third party e.g. credit reference agency) process certain information about you or your directors, officers and employees, and your beneficial owners (if applicable) in order to carry out anti-money laundering (AML) checks and related actions which we consider appropriate to meet any legal obligations imposed on us relating to, or the processing in the public interest or to pursue our legitimate interests in relation to, the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with Wallex‘s AML procedures;
  • to report tax-related information to tax authorities in order to comply with a legal obligation;
  • to monitor and record calls and electronic communications for investigation and fraud prevention purposes, for crime detection, prevention, investigation, and prosecution, and to enforce or defend to report tax-related information to tax authorities in order to comply with a legal obligation;
  • to monitor and record calls and electronic communications for investigation and fraud prevention purposes, for crime detection, prevention, investigation, and prosecution, and to enforce or defend our and our affiliates’ rights, itself or through third parties to whom it delegates such responsibilities or rights in order to comply with a legal obligation imposed on us or to pursue our legitimate interests in relation to such matters or the processing in the public interest;
  • to monitor and record calls for internal quality, business analysis, training, and related purposes;
  • to update and maintain records and for fee billing;
  • to carry out statistical analysis and market research;
  • to provide you with information about products and services which may be of interest to you or to the institution you represent, and which processing is necessary to perform a relevant contract with you, comply with legal obligations, and/or which is necessary for our legitimate interests indicated above and/or where the processing is in the public interest; and
  • to retain AML and other records of individuals to assist with the subsequent screening of them, including in relation to investment in other funds or the provision of other services by us, to pursue our and (in some circumstances) our clients’ legitimate interests.

 

 

How We Protect Information About You

We take reasonable security measures consistent with applicable law to protect the security of your Personal Information from being accidentally lost, or used, or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it.Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. We also implement the use of encryption or Secure Socket Layers connections for the transmission of any Personal Information. In so much as personal email is generally not encrypted, we request that no Personal Information be sent to us via email.

We will retain your Personal Information for the duration of our business relationship with you, or in case of a terminated relationship for a period of up to 5 years.

You may, at any time, instruct us to remove Personal Information, but you should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our servers. We will also retain your Personal Information as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

User preferences and opt-out choices

Email, Direct Mail;

To opt out of:

  • Receiving promotional or marketing emails from us at a specific email address;
  • Receiving direct mail;
  • Receiving calls;
  • Receiving notifications provided as part of the Services;
  • Disclosure of your information to third-parties; and
  • Use of your information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized.
  • You may contact us via email at sales@smholding.io to opt out;

 

 

How We Share Information About You

We may share the personal information that we collect about our customers, prospects, or former customers with their brokers or with:

  • Our corporate affiliates, including internal service providers;
  • Unaffiliated service providers (for example, printing and mailing companies, and other entities who may provide services to us)
  • Government agencies, other regulatory bodies, and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)
  • To credit reference agencies in order to carry out money laundering and identity checks and comply with legal obligations;
  • To our corporate affiliates and third-party vendors in order to process the data for legitimate purposes;
  • Other organizations, with your consent or as directed by your broker (for example, if you request personalized performance reporting) or as permitted or required by law (for example, for fraud prevention or to respond to a subpoena)
  • To competent authorities, courts, and bodies as required by law or requested or to affiliated for internal investigations and reporting.The disclosure of personal information to the affiliates and other third parties set out above may involve the transfer of data to the USA and other jurisdictions outside the European Economic Area (EEA). Such countries may not have the same data protection laws as your jurisdiction. We have put in place the Standard Contractual Clauses approved by the European Union Commission for such transfers of personal data. Please contact gdpr@smholding.io should you require more information on our international data transfer solution. Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by us.

 

Online Privacy

Privacy, security, and service in our online operations are just as critical as in the rest of our business. We use firewall barriers, encryption techniques, and authentication procedures, among others, to maintain the security of your online session and to protect our systems from unauthorized access.

When you visit our websites, we may collect technical and navigational information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our websites. We use this information for a variety of purposes, such as maintaining the security of your online session, facilitating site navigation, improving our website design and functionality, and personalizing your experience on our websites. Additionally, the following policies and practices apply when you are online: We provide information to our clients through electronic means only. These include Email, website, and online platform. Kindly note that to receive information electronically from us, a valid Email address is required. We provide information through our website which may not be addressed personally to you.

Cookies and similar technologies

We use cookies and similar technologies to support the operation of our websites. Cookies are small amounts of data that website exchanges with a web browser or application on a visitor’s computer or mobile device.

Cookies help us to collect information about visitors to our websites, including date and time of visits, pages viewed, amount of time spent on our sites, or general information about the device used to access the site. Wallex cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie when on our website, or if you delete cookies, you may experience some inconvenience in your use of the websites.

Protecting children’s privacy online

Our websites are not directed to individuals under the age of eighteen (18). We do not intentionally collect information on our websites from those we actually know are under 18, and we request that these individuals do not provide personal information through the sites.

Access to Your Information

You may access and, if necessary, correct your account information through a variety of media offered by your broker and us (e.g., statements or online services). Please contact your broker or us at gdpr@smholding.io if you require any additional information.

Data Subject Rights You have the following rights, in certain circumstances, in relation to your personal information:

  • Right to access your personal information.
  • Right to rectify your personal information.
  • Right to restrict the use of your personal information.
  • Right to request that your personal information is erased.
  • Right to object to processing of your personal information.
  • Right to data portability (in certain specific circumstances).

Where you have provided your consent to processing (e.g. to receive information about products and services which may be of interest to you or to the institution you represent), you may withdraw your consent at any time by contacting us by email at gdpr@smholding.io

Where we require your personal information to comply with AML or other legal requirements, failure to provide this information means we may not be able to provide the Services or the service to the institution you represent. You have the right to lodge a complaint with a supervisory authority.

Additional Information

If you are a former customer, your information is treated in the same manner as the information of current customers. We offer several options for accessing and, if necessary, correcting your account information. You can review your information using your statements, or through our automated telephone or Internet services. You may also write or call us with your request for information. If we serve you through an affiliate, please contact them directly.

How To Complain

We hope that we can resolve any query or concern you raise about our use of your information. Those in Designated Countries (being the European Union, European Economic Area or Switzerland) may contact our Privacy Officer at gdpr@smholding.io