We, at Strand Advisory Limited (“us”, “we” or “our”), put great efforts in making sure that we secure the personal data related to you (“Personal Data”) and use it properly.
This policy explains our privacy practices for processing Personal Data related to as a visitor to our website available at: www.Strandadvisory.eu, (the “Site”).
We process Personal Data subject to the terms of this policy.
What Type of Personal Data do We Collect?
You provide most of the Personal Data related to you through the registration and the login processes as well as while using our Site. Note, that you are not required by law to provide us with any information about you.
When you use our Site, for example, if you fill-in the contact form, we will collect contact details and additional information that you choose to provide.
We will also collect online usage information related to you, such as the Internet Protocol (IP) address used to connect your access device to the internet or which content you have viewed or downloaded and the country that you are located at. In addition, we will collect information about the time and date of the log in, details about the device which is used while using the Site and about its screen size and resolution, operation system and the browser used by you, such as browser type, version, and time zone setting, browser plug-in types and versions, operating system, and platform.
We also offer, through the ‘Contact Us’ form and links to our email address available on the Site, the opportunity to reach out to us. The Personal Data collected by us through such form, will only be used for the purpose of evaluating the subject matter of such form and contacting the person who sent it.
How do We Collect the Personal Data?
We collect the Personal Data related to you, directly from you, when you visit our Site or otherwise contact us through our Site.
Like many sites and services, we use “cookies” (for further information about cookies – see the “Cookies” section below), and we obtain information on your use of our Site.
Processing Personal Data related to you is necessary in order to enable you to use our Site.
What do We do With Personal Data?
We use the Personal Data we collect for all of the following purposes:
· To maintain our Site;
· To study and analyze the functionality of the Site and visitors’ activities;
· To manage business relationships with our service providers;
· To comply with court orders and warrants, and assist law enforcement agencies and to take any action in any legal dispute and proceeding;
· For our recordkeeping and protection of our legal rights;
· For analytics purposes;
· To prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Site; and –
· 
Subject to your consent, if such is required under applicable law, to send you e-mail, text messages, notifications or other messages or newsletters about us or our services, including through one of our service providers. At any time, you can unsubscribe from our mailing list by clicking on the unsubscribe link on the message.
We commit to process Personal Data solely for the purposes described in this policy. To the extent relevant and possible, we will make efforts to maintain the Personal Data accurate, complete and up-to-date.
Sharing Personal Data with Third Parties
We do not sell Personal Data related to you. We will share Personal Data related to you with our service providers and other third parties, as necessary to fulfill the purpose for collecting such information, according to this policy. Any such third party will commit to protect your privacy as required under applicable laws.
For example, we will share Personal Data related to you with third parties, such as:
· We engage trusted third-party companies and individuals to facilitate or provide services on our behalf or to perform Site-related services and analysis for the purpose of providing and operating our services. Such engagement will be only to the extent necessary.
· We will disclose or use Personal Data related to you to defend or enforce our legal rights and in accordance with any applicable laws.
· We will disclose, share or transfer Personal Data related to you in connection with a merger, acquisition, reorganization or sale of our assets or in the event of bankruptcy.
Cross-border Transfer
We store and process Personal Data mainly within Europe, but we may access and use service providers in various other jurisdictions throughout the globe.
Whenever we transfer Personal Data related to you to third parties based outside of the European Economic Area (EEA), then such transfer will be to countries that have been recognized by the European Union as providing an adequate level of protection for Personal Data by the European Commission, or subject to specific contracts, or any other arrangement, approved by the European Commission and in accordance with applicable laws.
How do We Secure the Personal Data?
We maintain the confidentiality of Personal Data related to you and we take reasonable steps to ensure that the Personal Data is accurate, complete, current and reliable for its intended use. We take reasonable measures to protect Personal Data related to you from loss, misuse and unauthorized access, disclosure, alteration and destruction.
We have put in place appropriate physical, electronic and organizational procedures to safeguard and secure Personal Data related to you from loss, misuse, unauthorized access or disclosure, alternation or destruction.
These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that our Site or Services will be immune from cyber-attacks, malicious activities, malfunctions, honest mistakes or other types of abuse and misuse. We would appreciate if you ensure that your passwords are not shared with anyone else and are kept securely.
Aggregated and Analytics Information
We use standard analytics tools. The privacy practices of these tools are subject to their own privacy policies and they use their own cookies to provide their service.
We use the standard analytics tools, such as of Google Analytics, to learn about how you use our Site, how we should improve your user experience and which improvements we should prioritize. We will use additional or other analytics tools, from time to time, in support of our services-related activities and operations. The privacy practices of these tools are subject to their own privacy policies.
In order to find out how Google uses data when you use their services you can visit: http://www.google.com/policies/privacy/partners/.
We use anonymous, statistical or aggregated information and will share it with our partners for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that we or others can associate specifically to you.
Your Choice
At any time, you may opt-out of our mailing list, or request that the Personal Data related to you will not be shared with our affiliates, business partners, and service providers, by contacting us. It may take up to ten (10) business days for your opt-out request to take effect.
You can exercise your choices by contacting us at: [email protected].
We request and collect Personal Data that we need for the purposes described in this policy. At any time, you can stop using the Site. Thereafter, we will stop collecting any respective Personal Data related to you.
However, we may store and continue using or making available certain Personal Data related to you. For further information, please read the Data Retention section in this policy.
Accessing Personal Data Related to You
If you find that the Personal Data that we keep about you is not accurate, complete or up-to-date, please provide us the necessary information to correct it
At any time, you can contact us at: [email protected] and request to access the Personal Data that we keep about you. We will ask you to provide us certain credentials to make sure that you are who you claim to be and to the extent required under applicable laws, will make good-faith efforts to locate the Personal Data that you request to access.
Your Rights as an European Data Subject
We base our processing of Personal Data as a Data Controller on the following lawful grounds:
· We process your Personal Data to perform our contract with you in relation to your use of the Site, and as necessary for the performance of any additional agreement between you and us.
· We will process Personal Data related to you to comply with a legal obligation and to protect your and others’ vital interests.
· We will rely on our legitimate interests, which we believe are not overridden by your fundamental rights and freedoms, for the following purposes:
o Communications with you, including direct marketing where you make contact with us through our Site and other digital assets;
o Cyber security;
o Support, customer relations, services operations;
o Enhancements and improvements to your experience with our Site;
o Fraud detection and misuse of our Site.
· All processing of Personal Data related to you which are not based on the lawful grounds indicated below, are based on your consent.
At any time, you can contact our Data Protection team at: [email protected], and request to exercise your rights in accordance with the provisions provided by law:
· You are entitled to access the Personal Data that we keep about you together with information about how and on what basis the Personal Data is being processed and to rectify when such information is inaccurate. If you find that the Personal Data related to you is not accurate, complete or updated, then please provide us the necessary information to correct it.
· You can contact us if you want to withdraw your consent to the processing of Personal Data related to you. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
· You are entitled to request to delete or restrict access to Personal Data related to you in limited circumstances as described under the GDPR. If we need to delete Personal Data related to you following your request, it can take time until we completely delete residual copies of Personal Data related to you from our active servers and from our backup systems.
If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions under the law, you are entitled to request to be informed that third parties that hold Personal Data related to you, in accordance with this policy, will act accordingly.
· You are entitled to request the transfer of Personal Data related to you in accordance with your right to data portability.
· You are entitled to object to the processing of Personal Data related to you, for example in relation to direct marketing.
· You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
· You have the right to obtain a copy of or access to safeguards under which Personal Data related to you is transferred outside of the EEA.
· You have a right to lodge a complaint with a data protection supervisory authority.
We will look into your query and make good-faith efforts to resolve any existing or potential dispute with you. Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us credentials to make sure that you are who you claim to be and will further ask you questions to understand the nature and scope of your request.
If you have any concerns about the way we process Personal Data related to you, you are welcome to contact our Data Protection team at: [email protected].
Data Retention
We retain different types of Personal Data for different periods, depending on the purposes for processing such information, our legitimate business purposes as well as pursuant to legal requirements.
We will maintain your contact details, to help us stay in contact with you. At any time, you can contact our Data Protection team at: [email protected], and request to delete your contact details. Note that we may keep your details without using them unless necessary, and for the necessary period of time, for legal requirements and proceedings.
We will keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the information.
In any case, as long as you use the Site, we will keep information about you, unless the law requires us to delete it, or if we decide to remove it at our discretion, according to the terms of this policy.
Changes to this Privacy Policy
From time to time, we will need to update this policy. Substantial changes will be effective 30 days after we initially posted a notice on the Site.
Until the new policy takes effect, you can choose not to accept it and terminate your use of the Site. Continuing to use the Site after the new privacy policy takes effect means that you agree to the new privacy policy. Note that if we need to adapt the privacy policy to legal requirements, the new privacy policy will become effective immediately or as required.
Contact us
To address any questions, comments, or concerns related to this privacy policy, please send a detailed message to: [email protected].
This privacy policy was last updated on February 10, 2021.