Introduction

This document applies to all personal information held by InScope-AML as the controllers of your personal data and goes into detail on how we process your data, why we process it, with whom this data may be shared, in what situations we may share this data and all the measures we are taking to ensure that your data is safe and secure. The terms of this policy will apply as long as you are a client of InScope-AML but will also continue to apply after you cease to be a client. It also applies if you have sent us your data to be part of our marketing mailing list and also if you have applied for a position with InScope-AML.

InScope-AML refers to the following company as Controller of your Personal Data:InScope Limited, a company incorporated under the laws of Malta, having company registration number C 82598 and address at 50, Triq Giorgio Preca, San Gwann, SGN 3510, Malta.

On our website, you may also find links to other websites which are not managed or owned by InScope-AML. InScope-AML is not responsible for any such websites and this privacy policy shall not apply in this regard. The businesses operating these websites, may or may not have their own privacy policy and in this regard, InScope-AML is no way responsible for the way such companies manage the processing of your personal data.

1. Data Controller
2. What is GDPR?
3. What is Personal Data?
4. What are Special Categories of Personal Data?
5. What are Controllers and Processors?
6. Data we collect, Legal Basis for Processing your Personal Data and Retention periods
7. How we store and transmit Personal Data
8. Cookies
9. Your Rights
10. Transfers to Third Countries
11. Data Security Measures
12. Breach
13. Updates to this Policy
14. Hyperlinks
15. Contacting Us

1. Data Controller

The data controller as defined under the Regulation (EU) 2016/679 which is generally referred to as the General Data Protection Regulation (hereinafter referred to as “GDPR”), is InScope-AML as defined above.

2. What is GDPR?

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) or “GDPR” is a European regulation intended to protect Personal Data of individuals. We collect various kinds of Personal Data from you and it is thus very important that your Personal Data is managed in terms of this regulation. Personal Data is very important for us and thus we strive to ensure the highest level of its protection.

3. What is Personal Data?

Personal Data is personal information about an individual, like you. We collect such information about our customers for relationship management, statistical reasons and for marketing purposes and also on our employees or potential employees when they apply for a position with us. We may also collect some personal information from other individuals who are not our customers, for marketing purposes, subject to their consent. As InScope-AML, we also process Personal Data of the customers of our clients when they engage us to provide services to them.

Personal Data may also be of a general nature and of a special nature. Generic Personal Data refers to data such as names, surnames, contact details and similar data which can be used to identify a person. Special categories of Personal Data relate to more confidential kind of Personal Data such as health data. Information regarding the different kinds of Personal Data we collect can be found in section 6 of this document.

4. What are Special Categories of Personal Data?

Certain more sensitive kind of Personal Data is defined under law as Special Categories of Personal Data, which relates to:

  • Racial or ethnic origin;
  • Political opinions;
  • Religious or philosophical beliefs;
  • Trade union membership;
  • Genetic data;
  • Biometric data for the purpose of uniquely identifying a natural person;
  • Data concerning health;
  • Data concerning a natural person’s sex life or sexual orientation

We generally do not process such Personal Data. However, when we provide our services to our Clients, the customer data of our clients will need to be processed by InScope-AML so that InScope-AML can provide its service. However such processing shall always be in line with the relevant legal requirements. In any case, we will always specify the purpose where such Personal Data shall be used and on what legal basis. We will also only use such Personal Data for the purposes that such Personal Data would have been collected and not for any other purposes.

5. What are Controllers and Processors?

When you provide your Personal Data to a third party, you are passing such data to either a controller or a processor.

A Controller of your Personal Data is an individual or a company who has the power to determine the exact uses of the Personal Data you have supplied to him. On the other hand, a Processor is a third party who is processing and thus utilising your Personal Data on behalf of a controller.

6. Data we collect, Legal Basis for Processing your Personal Data and Retention periods

This section shall outline the various ways we collect Personal Data from you from different situations. In this regard, all Personal Data collected must have a proper legal ground justifying collection and such is stated in each situation were Personal Data is Collected. Finally, the retention period for each set of Personal Data Collected is also listed herein.

  1. Employees
  2. Third party individuals who are engaged by the companies (subcontractors)
  3. Suppliers

Browsing

Description Data Collected Legal Basis Retention Period
When you browse this website, we may collect data through some tracking cookies as explained in the cookie section of this Policy. Otherwise, we do not collect Personal Data unless you voluntarily and knowingly provide it to us, for example by signing up to our mailing list. Kindly refer to cookie section. Consent, when dealing with non-essential cookies. Kindly refer to cookie section.

SUBMITTING A QUERY ON A SERVICE THROUGH OUR WEBSITE

Description Data Collected Legal Basis Retention Period
When contacting us through our website, we would need some personal data to be able to reply to your query.
  1. Name and Surname
  2. Email
  3. Contact Number
Consent 1 year unless the party is engaged.

BECOMING A CLIENT OF INSCOPE-AML

Description Data Collected Legal Basis Retention Period
When you engage us to provide services, we would require significant amounts of personal data
  1. Name and Surname
  2. Contact Details
  3. Email
  4. Names and surnames of employees and their contact details
  5. Bank details
  1. Contract
  2. Legitimate Interest
  3. Compliance with laws and regulations
5 years from when we stop providing you with our services.

SUBMITTING PERSONAL DATA THROUGH THE PORTAL

Description Data Collected Legal Basis Retention Period
Client data on the InScope-AML System
  1. Name and Surname
  2. Contact Details
  3. Email
  4. Identification documentation
  5. Financial and banking documentation
  6. Due diligence documentation
  7. Other documentation as may be required which may contain Personal Data
Contract Within one (1) month after termination of relationship with the service provider and such data is only held for backup purposes until the final transfer process is finalised.

Third Party Service Providers

Description Data Collected Legal Basis Retention Period
When we engage with you for the provision of goods and services to us, we collect personal data
  1. Name and Surname
  2. Contact Details
  3. Email
  4. Names and surnames of employees and their contact details
  5. Bank details
  1. Contract
  2. Legitimate Interest
  3. Compliance with laws and regulations
5 years from when we stop providing you with our services.

CONTACING OUR CUSTOMER CARE TEAM/SOCIAL MEDIAL TEAMS

Description Data Collected Legal Basis Retention Period
Should you contact our customer care or social media teams, we shall collect some Personal Data to be able to process your request.
  1. Name and Surname
  2. Email
  3. Contact Number
To protect our legitimate interest 3 months

WHEN YOU APPLY FOR A POSITION WITH INSCOPE-AML

Description Data Collected Legal Basis Retention Period
When you apply for a position with us, we would need to process your Personal Data to be able to verify your suitability for the role you have applied to.
  1. Name and Surname
  2. Your CV and Personal Data contained within
  3. Residential Address
  4. Contact Number
  5. Email
  6. Date of Birth
  1. Legitimate Interest
  2. Consent
4 months minimum. One year of consent is obtained.

WHEN YOU VISIT OUR PREMESIS

Description Data Collected Legal Basis Retention Period
When you visit our premises, we collect CCTV data for security purposes. CCTV Footage To protect our legitimate interest 7 days

7. How we store and transmit Personal Data

In addition to the required information sharing described above, we use the services of third party agents, such as e-mail service providers, hosting services providers, data centers and mail houses for the purpose of providing our services or mailing materials to our clients. These parties are contractually prohibited from using Personal Data for any purpose other than for the purpose specified in their respective contracts. We do provide non-personally identifiable information to certain service providers for their use on an aggregated basis for the purpose of performing their contractual obligations to us. We do not permit the sale of Personal Data to third parties for any use unrelated to our operations or use of Personal Data by third party for their own purposes.

Below is a list of sub processors:

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Name of Processor Address Task to be performed and Personal Data to be Processed Location of Processing
Cleverbit Software 50,Triq Giorgio Preca
San Gwann SGN3510
Malta
Installations, maintenance and support services. Data to be processed as outlined in the Data Access Annex point 4. Malta
Amazon Web Services EMEA SARL 38 avenue John F. Kennedy
L-1855
Luxembourg
Searches against sanctions, PEP and adverse media provided via services hosted on Amazon AWS. Germany, Ireland
Microsoft Microsoft Ireland Operations, Ltd.
Attn: Data Protection
One Microsoft Place
South County Business Park
Leopardstown
Dublin 18, D18 P521, Ireland
Office 365 subscription (email, document management system) EU
StartKYC 27, Triq Sir Ugo Mifsud, Lija, LJA1050, Malta Searches against AML/KYC database of PEPs, Sanctions and Adverse Media EU
Acuris Risk Intelligence Ltd Queen Street Place
London EC4R 1BE
Searches against AML/KYC database of PEPs, Sanctions and Adverse Media Ireland
Freshdesk Freshworks GmbH
Neue Grünstraße 17, 10179
Berlin
Helpdesk software used by our support team. EU
Sub contractor Hungary Installations, maintenance and support services. Data to be processed as outlined in the Data Access Annex point 4. Hungary
Sub contractor Portugal Installations, maintenance and support services. Data to be processed as outlined in the Data Access Annex point 4. Portugal

8. Cookie Policy

Our website only uses “cookie” technology as a tracking tool. Cookies do not retain registered guests’ information provided during the online reservations. Cookies identify your browser, rather than you and cannot be used by themselves to disclose your individual identity. Cookies enable us to track the number of page visits from the same computer or browser to be aggregated for statistical purposes.

Cookies do not corrupt or damage your computer, programs, or computer files. The purpose for which cookies — other than those which are either exclusively intended to enable or facilitate communication by electronic means or strictly necessary for the provision of an online communication service at your express request — are used on our website is set forth in a banner appearing the first time you land on such website.

For more information, kindly visit our cookie policy.

9. Your Rights

You have certain rights under law to your Personal Data.

  1. You have the right to access your data. You have the right to ask for a copy of your Personal Data.
  2. You have the right of rectification of incorrect data. If any data we have is incorrect, you have a right to ask for correction of such data.
  3. You have the right to be forgotten and that your data is erased after the passage of time. You may file a request, so that any data that we have on you is deleted. As stated above, due to legal requirements, your data will be held by us for the periods stated in the data retention section and then deleted.
  4. You have the right to restriction of procession. This can be done in the following cases:
    • Where you are contesting the accuracy of the data, while such a claim is being checked;
    • If we process your data unlawfully
    • If we no longer need your data but are keeping the data because we need it for a legal claim;

    Kindly note however the if you exercise this right, it will hinder our ability to provide you with the required services, since we may need your Personal Data to be able to provide you with our services.

  5. You have the right to data portability. Your data may be requested in a machine-readable format and you may also request that your data is transferred directly to another person or service provider directly.
  6. You may object to the processing of your data. You may at any time inform us that you are objecting to the use of your data for direct marketing and after which we shall stop using your data for such purposes.
  7. If you have provided consent for the processing of your data you have the right to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.

In making your request in relation to the above, please note that:

  • We will analyse your request and provide you with a reply within 1 month, except in extreme situations as allowed under law. In such a case we will provide information as to why your request was not acceded to within the 1 month period.
  • We have the right to refuse your request, if your request is not justified. In this case we shall inform you as to the reasons of why your request was refused.
  • We have the right to charge a fee or refuse your request in extreme situations where your requests are manifestly repetitive or excessive.
  • When you are making a request, we may request documentation to identify the person making the request.

You have the right to lodge a complaint to the data protection authority of your habitual residence if you believe that we have not complied with the requirements of the law.

In order to protect your Personal Data, we will require that you prove your identity to us in relation to your request to access your Personal Data, which may consist of a copy of a government-issued identification, your signature and correspondence address so we can check them against our records and satisfy ourselves as to your identity. The above information is required to create an audit trail of how the request has been handled. Where a request is made, any correspondence or application may be kept and added to your Personal Data.

10. Transfers to Third Countries

We shall strive to send your data only to other EU countries or other countries which ensure proper protection for your data. When transferring your data to countries which are not deemed as such, proper measures in terms of the law shall be applied to ensure the protection of your Personal Data. In cases where such measures cannot be achieved, Personal Data shall only be sent to these countries if necessary, to perform our services and also subject to any of the required measures imposed under GDPR. Some of the recipients referred to above are located in or process Personal Data outside of your country. The level of data protection in another country may not be equivalent to that in your country. However, we only transfer your Personal Data to countries where the EU Commission has decided that they have an adequate level of data protection or we take measures to ensure that all recipients provide an adequate level of data protection. We do this for example by entering into appropriate data transfer agreements based on Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of Personal Data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council).

11. Security of Data

We shall take all the necessary measures as required by law to ensure proper security and protection to your Personal Data. Such measures may include encryption, use of firewalls, anti-virus software and specialized security software, access restrictions and limitations, strict enforcement of policies and any other measures that we may enforce from time to time. Our measures shall strive to ensure that:

  • There is no unlawful destruction of your Personal Data;
  • That your Personal Data is not subject to unauthorized access;
  • That your Personal Data is not subject to unauthorized disclosure;
  • That your Personal Data is not subject to unauthorized modifications.
    • Despite our best efforts however, we cannot provide a 100% guarantee in relation to our system security.

      12. Breach

      In the event of a Data Breach following your Personal Data, we shall always abide by the law and inform you and the competent authorities as required.

      13. Updates to this Policy

      This data privacy statement was last updated on the 31st January 2024 in line with the last EU legislation to meet the GDPR requirements. In the future, we may need to make additional changes. All additional changes will be included in the latest data privacy statement published on this website, so that you will always understand our current practices with respect to the information we gather, how we might use that information and disclosures of that information to third parties. You can tell when this privacy statement was last updated by looking at the date at the top of the statement. Any changes to our statement will become effective upon posting of the revised statement on this site. We will seek your express consent to any changes to how we use or disclose your Personal Data if requested by law but otherwise use of this site or our services following such changes constitutes your acceptance of the revised statement then in effect.

      14. Hyperlinks

      Kindly note that our website contains hyperlinks to other websites. Please note that InScope-AML is not responsible for the content of these other websites or their respective adherence to data protection laws and rules. InScope-AML does not provide any quality controls to such websites and shall accept no responsibility for their performance, security, accuracy, content or privacy in relation to your personal data.

      15. Contacting Us

      If you wish to make any inquiry regarding your personal data, wish to have any of your data corrected or request access to your personal data, you may contact us on the below details. Please note that we may charge a fee or refuse requests which are manifestly repetitive or excessive.
      Any request must be in writing and must also include your name, address and a description of the information or correction required. We may also ask for other identification documentation. Such information is essential so that we can identify you properly.

      Email: dpo@inscope-aml.com
      Name: Dr Josef Cachia Fenech Gonzi
      Address: 50, Triq Giorgio Preca, San Gwann, SGN 3510, Malta