This Data Protection Policy reflects the agreement between you and CiliaFormosa Financial Advisors Ltd (CF) with respect to the processing and security of data in relation to the General Data Protection Regulation (GDPR).
Aim of data protection legislation
The General Data Protection Regulation 2016 / 679 (GDPR) is in place to protect the data subjects from unlawful processing of their personal information. CF will take all the steps reasonably necessary to ensure that personal data is treated securely and in accordance with this Data Protection Policy, and in accordance with the GDPR.
Who we are
CiliaFormosa Financial Advisors Ltd (hereinafter ‘CiliaFormosa’, ‘CF’, ‘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.
The 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, marital status, nationality ID Card number; - Details on your dependants/spouse/partner/family;
- Information about your current and previous employment and occupation,
including salary; - Professional background
- Information in relation to your or a family members status as a PEP, or otherwise
- Information about your income, assets and liabilities
- Identification document information;
- Bank account details
- Payment information
- Investment history
- Details of Source of Wealth and Source of Funds to be invested
- Results of checks relating to prevention of fraud and/or terrorist activities;
- Results of risk tolerance questionnaires, identifying your tolerance to risks related
to investments - Your marketing preferences;
- IP addresses when visiting our webpage without disabling Cookies including
related location data; - Signature/s;
- Such other information that may be necessary in order for us to comply with our regulatory obligations whether in Malta or outside of Malta.
We also collect other information about you from other sources and this in accordance with our obligations arising from anti-money laundering and anti-terrorist financing legislation and legislation relative to financial markets abuse amongst others.
Scope of processing
We will only collect and use your personal information when the law allows us to. Most commonly, we will use your Personal Information:
- For the purpose of preparing investment proposals;
- Where we need to perform the contract we have entered into with you;
- 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; and/or
- For training purposes, to improve our services and their delivery, including by recording telephone calls.
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).
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations. We will not use Personal Information for any other purpose incompatible with the purposes described in this Data Protection and Privacy Policy, unless it is required or authorised by law or authorised by you.
How we share your information within CF
We may share and aggregate information about you from across the company, including personal information held within CF relating to other investments, products or services held with us, and depending on your preferences, we may use this information to:
- Help us identify products and services that may be of interest to you, to tailor and package our products and services;
- To determine pricing and/or offer available discounts; and conduct customer research and develop marketing campaigns.
If you request a quote, or purchase a product or service from us, your personal information will be used and shared within CF for the purposes of administration (including processing of purchase or sale orders of shares, bonds and funds, issuing of contract notes, processing income and issuing of income certificates and identifying your tolerance to risks related to investments). We will use your information to communicate with you about your investment, product or service.
We may, as a matter of law, and without requiring notice or consent, use your information for crime and fraud prevention, systems administration within CF and to monitor and/or enforce CF’s compliance with any regulatory rules and codes.
How we share your information outside of CF
We will ensure that your personal data is processed in a manner that is compatible with the purposes indicated above.
For the stated purposes, your personal data may be shared with and processed where applicable by:
- Our associated companies, introducers, intermediaries and agents;
- Service providers, transfer agents, fund administrators, registrars, auditors and
other professional advisors; for the purposes of administration, including third parties providing services to them.
Your information may be disclosed when we believe in good faith that the disclosure is required:
- By law;
- To protect the safety of our employees, the public or CF property;
- 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, as well as with other public bodies including the Police and other organisations and may undertake credit or fraud searches with relevant agencies.
We may disclose your information to third party suppliers or service providers to conduct our business, including to help administer your investments, to help us manage and store data, provide data analytics, conduct market research and to communicate with you effectively. This may include any online or digital partners we work with.
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 reorganisation, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock;
- 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.
Who may give us information about you?
For the stated purposes, we may receive personal information relating to you or your dependants/ spouse/ partner/ family from third parties such as those listed above or others such as (but not limited to) the Court Judgements database and the Registry of Companies, which are legally entitled to communicate such data and that such data may
be processed for the stated purposes.
We may also record telephone conversations for training, security and quality control purposes. CCTV cameras are in use throughout our premises and branches.
Where will my personal data be processed?
Please note that your personal data may be disclosed to or exchanged with all employees of CF, its subsidiaries, associates and agents, including trusted third parties. Your information may be transferred to and stored in locations outside the European Economic Area (EEA), including countries that may not have the same level of protection for personal information. When we do this, we will make sure that it has an appropriate level of protection and that the transfer is lawful. We may need to transfer your information in this way to carry out our contract with you, to fulfil a legal obligation, to protect the public interest and/or for our legitimate interests. We will only share your information with people who have the right to see it.
Data retention
CF will not retain your personal information for longer than it is required for the maintenance of your account, or for any legal or regulatory requirements.
Data security
We will take appropriate measures to protect 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.
Cookies
When you visit CF ’s Website, CF ’s web server automatically records details about you, such as IP address, the website from which you were redirected to CF ’s website, type of browser and CF ’s website pages visited by you including date and duration.
CF will use your personal data:
- for the purposes of technical administration and research & development of CF ’s Website,
- for user administration and marketing,
- to inform you about our services and products.
Data subject rights
Your rights in connection with personal information under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
Access requests and marketing options
If you wish to exercise your rights or change your marketing preferences, you may do so directly at CF, or by sending an email to:
or in writing mailed to:
CiliaFormosa Financial Advisors Ltd
90, Triq Id-Delu,
Mosta MST3355
Malta
Should you not visit CF in person, CF may need to contact you in order to verify your identity.
Updates to this data protection policy
We reserve the right to update this Data Protection Policy at any time. The updated Data Protection Policy will be published on our website.
Contact details of CF and the supervisory authority:
Data Protection Officer: Josman Cilia
Contact Number: +356 2226 0200
Email: info@ciliaformosa.com
Supervisory Authority Contact Details:
Land Line: +356 2328 7100
Email: idpc.info@idpc.org.mt
Last update: July 2021
