1. Introduction

Esterad Capital Limited is committed to processing data in accordance with its responsibilities under applicable Personal Data Protection Laws and Regulations, to protect the confidentiality of personal data of clients, employees and other stakeholders, prevent any breach of its regulatory obligations and to protect its reputation.

2. The data we collect

Esterad Capital Limited collect basic identification information (e.g. Name, Date of Birth, Nationality, Address Details) as required under applicable laws and regulations, specifically in connection with the legal services provided and Anti-Money Laundering requirements in line with the nature of Esterad Capital Limited’ business activities.

3. How we collect data

We collect and process data from Clients and Business Partners:
• upon request for provision of services
• prior to establishing a business relationship
• during the lifetime of the business relationship

3.1 Cookies

The Internet pages of Esterad Capital Limited use cookies. Cookies are text files that are stored in a computer system via an Internet browser.
Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers which contain other cookies.
Through the use of cookies, Esterad Capital Limited can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

4. The legal bases we use to process data

The lawful basis on which Esterad Capital Limited processes Personal Data, will be one of the following:

• The Data Subject has given consent to the processing for specific purposes;
• The processing is necessary for the performance of a contract to which a Data Subject is a party, or in order to take steps at the request of a Data Subject prior to entering into such contract; or
• The processing is necessary for compliance with Applicable Law that a Controller is subject to.

5. How we use data

We use Client related data so we can:
• Provide Clients with legal services in the best interest of the Client
• Comply with financial services rules and regulations
• Comply with AML rules and regulation applicable to Esterad Capital Limited and its affiliates
• Comply with any other applicable laws and regulations to which Esterad Capital Limited is subject

6. How we store data

Esterad Capital Limited stores data in electronic format. Esterad Capital Limited has implemented technical and organisational security measures to keep personal data secure, including being protected against unauthorised or unlawful processing (including transfers), and against accidental loss, destruction or damage.

7. Who we share data with

We share your data with:
• Relevant regulatory and supervisory authorities in the jurisdictions in which Esterad Capital Limited operates
• Third-party service providers in connection with Esterad Capital Limited’ business

8. How we delete data

When Esterad Capital Limited is required to stop processing the Data Subject’s data, we ensure it is Securely and permanently deleted, where permitted under applicable laws and regulations.

9. How long we keep data

Esterad Capital Limited will store personal data as required by applicable laws, and only for the time necessary for the purpose it was collected.

10. Marketing and opting out

We will not use Personal Data for direct marketing purposes.

11. Data protection rights

Subject to some exemptions, Data Subject have the right to:
• Know whether we are processing personal information;
• Request a copy of the personal information we hold about the Data Subject, in a structured, commonly used, machine readable format such as email;
• Have any inaccuracies corrected or and have incomplete personal data completed;
• Have the Data Subject’s personal data erased if it is no longer needed;*
• Ask Esterad Capital Limited to restrict the processing of their data;
• Object to Esterad Capital Limited processing their data;
• Object to processing that is carried out in our legitimate interests;
• Not be subject to a decision based solely on automated processing if it produces legal effects or similarly affects them;
• Make a complaint to the Supervisory Authority; and
• Not be discriminated against when the Data Subjects exercises any of their rights.

The information must be made available free of charge and within one month of the request.

* As a result of for example AML laws and regulations, financial services regulations and other legal obligations, not all data pertaining to the Data Subject may be removed, e.g. AML related data must be retained during the lifetime of the client relationship and for 6 years after ending of the relationship.

12. Google reCAPTCHA

We use Google reCAPTCHA to protect our website from spam and automated abuse. reCAPTCHA analyzes interactions with the website to determine whether a visitor is a human. This analysis may include information such as IP address, browser information, and user behavior. The data may be transmitted to Google for processing as part of the reCAPTCHA service.