Privacy Statement Introduction

This website is managed by Moore Stephens Services SAM("MSSSAM")

Moore Stephens Services SAM is a member firm of Moore Stephens International Limited ("MSIL"), a worldwide network of independent accounting and consulting firms.

For the purposes of this Privacy Statement, member firms, correspondent firms and associated firms of MSIL are together described as Participant Firms.

MSSSAM is committed to the protection of personal information supplied by clients and prospective clients. MSSSAM is the data controller, collecting the information obtained by this website for specified purposes as outlined below. Personal information submitted to the website may be transferred to other participant firms and other member firms of MSIL ("international firms") to the extent necessary to meet the purpose for which the information was submitted

 

Collection of Information

MSSSAM will only collect and use personal data voluntarily and openly provided to this Site. Authorised users are able to browse the Site without disclosing any personal information. An authorised user of this Site may choose to provide MSSSAM with limited personal data as required in order to register for certain services; once registered the information will only be used for the specified purpose(s).

At the present time IP addresses of authorised users are not logged for either administrative or other purposes. The IP address indicates the location of the authorised users' computer on the Internet. If it is decided to log IP addresses in the future, the information so obtained may be aggregated to provide statistical information about the users of the Site. However no individual user will be identifiable from such information and IP addresses will not be used to track the access to the Site. MSSSAM does not require registration for access to the Site.

It will normally be clear when personal information is being collected. The information required is the minimum necessary to enable MSSSAM to deal with the services requested, but additional information may be requested in order for MSSSAM to provide the most appropriate response. If such additional information is requested it is highlighted and its provision is voluntary.

Sensitive personal data includes gender, race or ethnic origin, political opinions, religious or other beliefs, trade union membership, physical or mental health, sexual life or criminal records. We do not solicit sensitive personal data through the Site except where legally required to do so. We would suggest information of this nature is not provided except where legally provided to do so.

At the present time the standard technology known as "cookies" is not used on the Site. Cookies are small text files placed on the authorised user's hard drive that allow the Site to store tokens of information in connection with use of the Site by allocation of an identifier to an authorised user while the Site is in use. Use of cookies would enable MSSSAM to analyse the operation of the Site, thus permitting continuous improvement of the service that it provides, but cannot retrieve any other data from the hard drive of the authorised user's computer or capture the authorised user's e-mail address. In any event it is not intended to link personal data to information that may be contained in a cookie to determine or track the identity of any user of the Site.

Use of Information

Information is used only for the specific purpose for which it was provided except where there has been an explicit selection to receive other information from MSSSAM. Personal data provided through the Site will be made available to the provider of the information on request as any individual whose personal data is held on the Site may be entitled under the Data Protection Act to the information constituting his or her personal data. Personal information may be deleted from the Site at any time. Requests for copies or deletion of information may be made by e-mailing Peter Brigham at any time.

Provision of Information to Third Parties

MSSSAM will provide personal information to third parties in the following circumstances:

• Where the transfer is necessary to fulfil the requirements of the operation for which the information was provided, and the third party is a Participant Firm
• In order to fulfil a request which involves other Participant Firm
• So as to assist MSSSAM's professional advisors regarding matters referred to them concerning the operation of the Site
• Where requested explicitly by an authorised user of the Site or;
• As required by a court order or any other legal or regulatory requirement.

MSSSAM does not collect or compile personal data or information obtained by the Site for dissemination or sale to outside parties not Participant Firms for the purposes of marketing or mailing by or on behalf of third parties. MSSSAM does not undertake marketing activities for third parties.

Retention of Information

Information collected from authorised users of the Site will only be kept in order to provide the required services. Once the service has been completed all information will be destroyed in accordance with MSSSAM's data retention policies. Where the information has been collected in connection with an expression of interest in working for MSSSAM or a Participant Firm it is agreed that MSSSAM may use, hold and destroy personal data supplied in connection with the initial expression of interest in accordance with MSSSAM's standard recruitment procedures:

• Details may be retained for up to the next twelve months for the purpose of notification of suitable vacancies that might arise; and
• Details may be used for the purpose of research and analysis designed to improve recruitment and human resources policies and practices.

Where the authorised user of the Site has provided additional information, personal details will be retained for a period of time reasonable in the context of the nature of the request.

If these conditions are not acceptable the site should not be further used.

Security of Information

MSSSAM has implemented accepted standards of technical measures and security policies that are aimed at protecting the personal data it has under its control from:

• Unauthorised access
• Improper use or disclosure
• Unauthorised modification
• Unlawful destruction or accidental loss

All MSSSAM personnel are required to keep personal information confidential and only authorised persons have access to such information.

Children

MSSSAM understands the importance of protecting children's privacy especially in an online environment. The Site covered by this privacy statement is not intentionally designed or directed at children 13 years of age or younger and it is MSSSAM policy never to knowingly collect or maintain information about anyone under the age of 13 years.

Other Matters

Please note that the Site contains links to other sites (including sites maintained by Participant Firms) which are not governed by this privacy statement.If you have any questions about this privacy statement please e-mail Peter Brigham.

Data Protection in Monaco

In accordance with Law no. 1.165 of 23 December 1993, personal information concerning individuals that is collected as computerised data by companies in Monaco, including MSSSAM, may give rise to the exercise, at request, of a right of access, of correction and for legitimate reasons, of opposition by the individual concerned.

According to our legal obligations Moore Stephens Services SAM is committed to take all precautions in order to safeguard personal details held in our records, and to prevent it from being misused, damaged or communicated to unauthorised third parties.

For further information on your rights you are referred to the website of "La Commission de Contrôle des Informations Nominatives” the administrative body governing data protection in Monaco.