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Privacy policy

Data Protection & Privacy Policy 

WHO WE ARE 

Independent Captive Management Malta Ltd and Independent Captive Management SA in Luxembourg (hereinafter ‘ICMS, ‘us’, ‘our’, ‘we’) are the data controllers as defined by relevant data protection laws and regulations. We control and are responsible to keep and use personal data in paper or electronic files. 

OUR APPROACH TO PRIVACY 

The privacy and security of your personal information is very important to us. We want to assure you that your information will be properly managed and protected whilst in our hands. 

THE KIND OF INFORMATION WE HOLD ABOUT YOU 

We may collect, store, and process the following categories of personal information about you (“Personal Information”): 

  • Basic personal details such as your name, address, e-mail address, telephone number, date of birth or age, gender, nationality ID Card Number;
  • Identification document information;
  • IP addresses when visiting our webpage without disabling Cookies including related location data;
  • Results of checks relating to prevention of fraud and/or terrorist activities;
  • Your marketing preferences; 

HOW WE WILL USE INFORMATION ABOUT YOU 

We will only collect and use your personal information when the law allows us to. Most commonly, we will use your Personal Information: 

  • where we need to comply with a legal obligation;
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • We may also use your personal information in the following situations, which are likely to be rare:
  • Where we need to protect your interests (or someone else’s interests).
  • Where it is needed in the public interest (or for official purposes). 

HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION 

Sensitive Personal Information requires higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances: 

  • In limited circumstances, with your explicit written consent.
  • Where we need to carry out our legal obligations and in line with this Data Protection and Privacy Statement.
  • Where it is needed in the public interest, such as for equal opportunities monitoring, and in line with this Data Protection and Privacy Statement. 

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. 

We will not use Personal Information for any other purpose incompatible with the purposes described in this Data Protection and Privacy Statement, unless it is required or authorized by law, authorized by you, or is in your own vital interest. 

HOW WE SHARE YOUR INFORMATION OUTSIDE ICMS 

We will ensure that your personal data is processed in a manner that is compatible with the purposes indicated above. Your information may be disclosed when we believe in good faith that the disclosure is required: 

  • by law; or
  • to protect the safety of our employees, the public or ICMS property; or
  • to comply with a judicial proceeding, court order or legal process; or
  • in the event of a merger, asset sale, or other related transaction; or
  • for the prevention or detection of crime (including fraud). 

In order to prevent and detect fraud we may share your information with regulatory bodies in Malta or if applicable, overseas, public bodies including the police and other organizations and may undertake credit or fraud searches with relevant agencies. 

In addition, depending on your marketing preferences, we may share your information with third parties who help run our marketing campaigns. We do not share personal data with non-affiliates third parties for their own marketing use without your permission. 

We may also share your personal data: 

  • in the event of any contemplated or actual reorganization, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock; and
  • to meet any legal obligation, including to the relevant ombudsman if you make a complaint about the product or service we have provided to you. 

WHERE WILL MY PERSONAL DATA BE PROCESSED? 

Your personal data may be processed both inside and outside of the European Economic Area (EEA) by the parties specified above, subject always to contractual restrictions regarding confidentiality and security in line with applicable data protection laws and regulations. We will not disclose your personal data to parties who are not authorized to process them. 

SECURITY 

We will take appropriate measures to protect Personal Information and Sensitive Personal Information that are consistent with applicable privacy and data security laws and regulations, including requiring service providers to use appropriate measures to protect the confidentiality and security of Personal Information and Sensitive Personal Information. 

DATA INTEGRITY AND RETENTION 

We will take reasonable steps to ensure that the Personal Information and Sensitive Personal Information processed is reliable for its intended use, and is accurate and complete for carrying out the purposes described in this notice. We will retain Personal Information and Sensitive Personal Information for the period necessary to fulfil the purposes outlined in this notice unless a longer retention period is required or permitted by law. 

YOUR RIGHTS 

Where permitted by applicable law or regulation, you have the right to: 

  • Access your personal data held about you and to learn the origin of the data, the purposes and ends of the processing, the details of the data controller(s), the data processor(s) and the parties to whom the data may be disclosed;
  • Withdraw your consent at any time where your personal data is processed with your consent e.g. direct marketing;
  • Update or correct your personal data so that it is always accurate;
  • Delete your personal data from our records if it is no longer needed for the purposes indicated above;
  • Restrict the processing of your personal data in certain circumstances, for example where you have contested the accuracy of your personal data, for the period enabling us to verify its accuracy;
  • Obtain your personal data in electronic format for onward transmission by you to another entity without hindrance from Us; and
  • File a complaint with us.
  • You may exercise these rights by contacting us by email or by post as follows 

Independent Captive Management Malta Ltd 
Data Protection Officer 
Suite A, Level 1, Cornerstone Business Centre, 
16th September Square, Mosta MST1180 
Malta 

Email: info@icms.mt 

Or 

Independent Captive Management SA 
Data Protection Officer 
Windhof Business Center 4, 
ancienne route d’Arlon 
L-8399 Winhof 
Luxembourg 

Email: info@icms.lu 

It is important that you include your name, email address and purpose of your request when contacting us. Please note, however, that certain Personal Information and Sensitive Personal Information may be exempt from such access, correction and erasure requests pursuant to applicable data protection laws or other laws and regulations. 

HOW OFTEN DO WE UPDATE THIS DATA PROTECTION NOTICE 

We may revise this Data Protection and Privacy Statement from time to time, and will post the most current version on our website. If a revision meaningfully reduces your rights, we will notify you.