Privacy

1. INTRODUCTION

Finelk Limited (“we” or the “Company”) is a strategic financial and corporate communications company. We are committed to being transparent about how we collect and use personal data and to meeting our data protection obligations. Where the Company is the data controller of any personal information provided to it by clients, vendors and suppliers this statement will explain how we may process and use such information.

2. WHAT PERSONAL DATA WE COLLECT ABOUT YOU

The personal information we collect about our clients, vendors and suppliers is very limited. We collect information only about their employee representatives (contact information – work address, email address and telephone numbers – and areas of professional interest).

3. HOW THIS PERSONAL DATA IS COLLECTED

We may collect personal data about you in a number of different ways including, but not limited to the following:

in the course of our contracts with you;
from business cards;
from your interactions with us; and/or
through third party agencies, service providers and/or publicly available information.

4. HOW WE USE PERSONAL DATA

We may use your information for:

performing the contract we are about to enter into or have entered into with you;
sharing with you information of specific interest and relevance to your professional activity
maintaining and developing our relationship with you;
facilitating our internal business operations including accounting, billing, collections, and payments;
fulfilling our legal and regulatory obligations;
monitoring and analysing our business;
sending you press releases and other promotional materials on behalf of our clients; and/or
invitations for corporate hospitality and other events.

This is not intended to be an exhaustive list and we may use personal data provided to us for related and/or ancillary purposes.

We set out below the lawful bases on which we rely to process your data:

Purposes	Legal basis for processing
Purposes	Allows us to perform our contract with clients	Enables us to comply with legal obligations	Pursue legitimate interests of our own or those of third parties
Entering into the contract with clients	√
Performing the contract we are about to enter into or have entered into with clients	√	√	√
Maintaining and developing our relationship with clients	√
Facilitating our internal business operations including accounting, billing, collections, and payments	√	√
Fulfilling our legal and regulatory obligations		√
Communicating with those journalists relevant to our clients’ businesses			√

Visitors to Company offices

When attending our offices, you may be asked to provide identification documents to clear our security checks.

5. SHARING YOUR PERSONAL INFORMATION

We may share your personal data:

for auditing and accounting purposes;
with regulators, courts and law enforcement agencies as necessary;
with third party service providers and in doing so we will ensure the confidentiality, integrity and security of your personal data is maintained when being handled by any such service provide; and
in other circumstances where we have your express consent to do so.

Third party personal information shared with us

Where we receive personal data relating to someone else from a third party database (“discloser”), the onus is on the discloser to ensure that they have the relevant authority and/or consent to disclose that personal data to us and that the information that they have provided is accurate and up to date. On this basis, we may collect, use and disclose that personal data as described in this Privacy Policy.

6. INFORMATION SECURITY

We will take reasonable steps to ensure the information we hold about you is kept confidential and secure. In addition to personal information being kept electronically, we may also store physical documents on file.

Updating your personal data

Should you wish to amend the personal information that we hold for you, please contact info@finelk.eu. We will not be responsible for any losses arising directly or indirectly from any inaccurate and/or incomplete information provided to us by you.

Retention of your personal information

We will retain your personal information only for as long as is reasonably necessary in the circumstances and in compliance with our legislative and regulatory requirements.

To determine the appropriate retention period for personal data, we consider the volume, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

7. YOUR RIGHTS

In accordance with EU and UK data privacy laws where we operate, you have the right to:

request access to the personal information which we hold about you;
request correction of personal information;
request the transfer of your personal information to another party;
request the restriction of processing; and
request the deletion of your personal information if the Company or its group entities are no longer under a legal obligation to process such data. We can also refuse to delete your data if in our view the information is necessary for the defence of legal claims against the Company.

If you wish to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact info@finelk.eu in writing.

9. STATUS OF THIS PRIVACY POLICY

We review this Privacy Policy regularly and reserve the right to revise it or any part of it from time to time to reflect changes in the law, information security and technology practices or in the way in which we process your personal information.

10. CONTACT INFORMATION

If you have any questions about this Privacy Policy, or want to submit a written complaint to us about how we handle your personal information, please contact us at info@finelk.eu.

You may also have the right to submit a complaint to the UK Information Commissioner’s Office.