1.1. Data controller
This Privacy Statement, as amended or otherwise changed from time to time (the “Privacy Statement”), explains the manner in which Aster. (“Aster”, "we", "us", "our") collects, uses, maintains and discloses user information obtained through and in relation to the provision of the services (the “Services”) and/or through our website and any related applications (the “Site”). Aster is the Data Controller of your Personal Data.
1.2. As Data Controller subject to ADGM's Data Protection Regulations 2015 (as amended), we must ensure that any Personal Data we Process are:
1.3. We are also required to ensure that Personal Data which are inaccurate or incomplete, having regard to the purposes for which they were collected or for which they are further Processed, are erased or rectified.
1.4. ADGM Supervisory Authority
We are registered as a Data Controller with The Office of Data Protection for ADGM. The Office of Data Protection is responsible for promoting data protection within ADGM, maintaining the register of Data Controllers, enforcing the obligations upon Data Controllers and upholding the rights of individuals. As part of ADGM's data protection regime, all ADGM registered entities that process Personal Data are required to register as a Data Controller. Additionally, businesses must not process an individual’s data without their knowledge or consent and they must provide individuals with access to any personal information they hold, on request.
1.5. European Supervisory Authority
If you are located in Europe, you have the right to make a complaint at any time to a the Supervisory Authority established for the purposes of the European General Data Protection Regulation (GDPR) in the country in which you are based.
If you are located in the United Kingdom you may also (or alternatively) make a complaint to the Information Commissioner's Office (ICO) (the UK supervisory authority for data protection issues (www.ico.org.uk)).
We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority so please contact us in the first instance.
On occasion, we may revise this Privacy Statement to reflect changes in law, our Personal Data collection and use practices, the features on the Site, or advances in technology. If material changes are made to this Privacy Statement, the changes will be prominently posted on the Site.
Please note: This Privacy Statement does not cover any information that we may receive about you through channels external to Aster.
3.1. We collect and Process Personal Data as described below.
3.2. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
3.3. Some information is collected automatically by our servers:
3.4. Some information is collected from third parties:
We may obtain Personal Data about you from other sources, including through third party services such as sanctions screening services and other organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
3.5. If you fail to provide Personal Data:
Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you. In this case, we may have to close your Account but we will notify you if this is the case at the time.
4.1. You may give us personal information about yourself, or other individuals involved in or relating to your matter, to help us provide you with the Services you have asked us for.
4.2. Under Data Protection Law, we can only Process and use your Personal Data if we have a lawful basis for doing so. We will use Personal Data where on or more of the following lawful bases applies:
4.3. A legitimate interest is when we have a business or commercial reason to use your personal information, so long as this is not overridden by your own rights and interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. Personal Data revealing or concerning (directly or indirectly) racial or ethnic origin, political opinions, religious or philosophical beliefs, criminal record, trade‐union membership and health or sex life is Sensitive Personal Data. We will only Process Sensitive Personal Data where:
5.1. We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
5.2. Please note that we may process your Personal Data without your knowledge or consent where this is required or permitted by law.
5.3. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
5.4. Data collected automatically will be used to administer or improve our Services and for other lawful purposes.
We use IP addresses to make our Site and Services more useful to you, and to perform identity verification.
5.5. We use information from log files to analyse trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. Except as noted in this Privacy Statement, we do not link this automatically-collected data to Personal Data.
5.6. We may use third parties to verify your identity by determining whether a selfie you take matches the photo in your form of identification. Facial recognition technology collects information from your photos that may include facial recognition or biometric data, and it shares this information with us. We use that information to verify your ID. We will store your biometric data for as long as is necessary to perform the Services and comply with applicable law.
5.7. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
5.8. We may create aggregated or de-identified records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this to analyse request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use and aggregated and other de-identified information for any purpose and disclose to third parties in our sole discretion.
5.9. Where European Union data protection laws apply, such as the General Data Protection Regulation, we will process your Personal Data for the purposes described above and for marketing (described below) where we have a lawful basis to do so, as set out at the start of this section 5. For example, for processing necessary to provide you with the Services, the lawful basis will generally be that it is necessary for the purposes of performing our contract with you. For marketing (described below), we may send you marketing based on it being in our ‘legitimate interests’ to do so (where you are a corporate customer) or based on consent where you are acting in an individual capacity. Other processing we do, such as that for product development and improvement, may not be ‘necessary’ to provide the Services but may still be necessary for our ‘legitimate interests’ of running a business and offering the Services.
6.1. We provide you with choices regarding certain Personal Data that we use, particularly around marketing and advertising. We have established the following Personal Data control mechanisms:
7.1. We disclose your Personal Data as described below and as described elsewhere in this Privacy Statement.
7.2. Other than as stated in this Privacy Statement, we do not disclose any of your Personal Data to third parties unless required to do so by law enforcement, court order, or in compliance with legal reporting obligations.
8.1. We may share your Personal Data within our affiliated group of companies in various locations globally. If you are based in Europe, this will involve transferring your data outside the European Economic Area (EEA).
8.2. In addition, many of our external third parties are also based outside of the EEA so their processing of your Personal Data will involve a transfer of data outside the EEA. Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by putting in place appropriate safeguards, as required by applicable law.
8.3. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
9.1. You can update your information by contacting support and making a request.
9.2. We will retain your information for as long as your Account has not been closed or as needed to provide you access to your Account. If you wish to close your Account, open a ticket in our Support Centre by contacting us at firstname.lastname@example.org. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms.
We retain Personal Data for as long we need it for the purposes set out in this Privacy Statement. This period will vary depending on the nature of the information and your interactions with our Site and our Services. For example, we keep a record of transactions on our site for up to two years, to protect us from legal claims, and we will retain information associated with your Account for up to two years after it has been closed unless there are other legal needs to retain it. If you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
11.2. We may also use service providers such as Google Analytics and others to collect information regarding visits, and behaviour and visitor demographics on our Services. For more information about Google Analytics: www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
11.4. We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your Personal Data for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
11.5. Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. At this time, we do not respond to DNT signals.
12.1. We take the protection of your Personal Data seriously. We use industry-standard data encryption technology and have implemented restrictions related to the storage of and the ability to access your Personal Data.
12.2. Please note that no transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure.
13.1. Under certain circumstances, you have rights under data protection laws in relation to your Personal Data which are set out in more detail below:
13.2. If you wish to exercise any of the rights set out above, please contact us
13.3. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your rights to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Unfortunately, if you are under 18, you cannot use our Services. We do not knowingly solicit or collect information from anyone under 18. If we become aware that a person under the age of 18 has provided us with personal information, we will delete it immediately.