PRIVACY STATEMENT

1. Introduction

CPA Global Limited, Liberation House, Castle Street, St Helier, JE1 1BL, Jersey (“CPA Global”) is committed to protecting and respecting your privacy and your right to fair and just processing of your personal data. When you choose to provide us with data about yourself, we recognise that you trust us to act in a responsible manner. The data we collect about you will only be used to help us provide you with better products and services.

This Privacy Notice sets out the basis on which your personal data will be processed by CPA Global, the data controller of your personal data under the compliance requirements of the Jersey Data Protection Laws (the “Act”). Please also note that this Privacy Notice complies with the provisions of all applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679.  Please read the following carefully to understand our views and practices regarding your personal data and how it will be treated by us.

CPA Global’s nominated representative for the purpose of the Act is: Ms Lucy Archer, Chief Privacy Officer, email address: larcher@cpaglobal.com

2. Personal data we may collect from you

Our objective at CPA Global is to be your IP solutions provider of choice by providing you with the information and services that are most relevant to you. To achieve this goal and to pursue our legitimate interests as a service provider to render the requested services, we need to collect information to understand what differentiates you from each of our other unique clients. We may collect the following types of personal data from you:

  • Device information: information such as what kind of browser a visitor is on, what operating system they are using, their IP address, cookie information, time stamp (time page accessed as well as time spent per web page) and their clickstream information (for example, which pages they have viewed and how long they have been there).
  • Contact details and CPA Global account details: In certain sections of the website, it may invite you to contact us to pose questions, request information or complete a registration form. We may ask for Personal Data to be entered as a means of registration before accessing a certain part of the website. “Personal Data” means any information that identifies you directly or indirectly, including, without limitation, by reference to your name, e-mail address, login ID and other contact or location data or to one of more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity, that you voluntarily transmit with your communication to us. Visitors of the website can always opt not to enter any of their Personal Data.
  • Transaction information: The website may also collect Personal Data when you use certain CPA Global services, through the use of the website or hypersite web pages, or when you enter promotions or contests offered by CPA Global on and through the website.

Note that information is only gathered while the visitor is on the website. The website monitors how a visitor arrives at the website, but cannot and will not gather information about other third party sites the user has visited. The website automatically receives and records such information on our server logs from your browser.

There may also be instances where we will require your Personal Data for the purposes of complying with our duties and exercising our rights and obligations under a contract for services that we have with you, without which we may not be able to provide such services.

3. What we use your personal data for

We may use data held about you in the following ways for the purpose of internal administration and to ensure that the content on this website is presented in the most effective manner for you and for your computer:

Personal data used

Purpose

  • CPA Global Account Details
  •  Contact Details
  • To allow us to verify your username and password when you are logging on to certain restricted areas of the website
  • To register you to use CPA Global services
  • To contact you to deliver certain services or information you have requested
  • To provide you with notices regarding our services
  • Transaction information
  • Contact Details
  • Device information
  • To provide you with information, products or services that you request from us or which we feel may interest you such as important changes to this website, new CPA Global services or changes to existing services and special offers we think you will find valuable (which may be considered ‘profiling’ under the GDPR)
  • To allow you to participate in interactive features of our service where you choose to do so
  • To improve the content and general administration of the website and our services
  • To understand our visitors

 

 

The website may process information that will be maintained, used and disclosed in aggregate form only and which will not contain your Personal Data, for example, without limitation, the total number of visitors to our website, the number of visitors to each page of our website, browser type, External Websites (as set out in section 7 below) linked to and IP addresses. CPA Global may analyse this data for trends and statistics in the aggregate, and we may use such aggregate information to administer the website, track users’ movement, and gather broad demographic information for aggregate use.

4. Who we share your personal data with

We may share your Personal Data with the following parties:

  • Companies in the same group of companies as us: We may disclose your Personal Data to any member of our group which means any company or partnership which is wholly or partly owned by any of CPA Global’s general partners and any subsidiary or holding company of such company or partnership or any partnership of which such company is a partner (the “CPA Global Group”).
  • Third parties: We will only disclose your Personal Data to third parties under the following conditions:
    a) if we are required to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply our Terms and Conditions or any other agreement; or protect the rights, property, or safety of CPA Global, our customers, or others. This includes exchanging information with other companies and organisations for protection against credit risk and fraud;
    b)in the event that we sell or buy any business or assets in which case we may disclose your personal data to the seller or buyer of such business or assets;
    c) if CPA Global or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will of course be one of the transferred assets; and/or
    e) with your specific consent either at the time you register with this website, or subsequently.

We do not disclose personal data to anyone else except as set out above.

IP Addresses and Cookies

We may collect information about your computer or device including where available your IP address, operating system and browser type for system administration. This is data about our users’ browsing actions and patterns and may also identify any individuals and be considered Personal Data based on whether it is combined with account data you provide to us.

For the same reason, we may obtain information about your general Internet usage by using a cookie file which is stored on the hard drive of your computer or mobile device. Cookies contain information that is transferred to your computer’s hard drive or mobile device. They help us to improve our website and to deliver a better and more personalised service. They enable us:-

  • to estimate our audience size and usage pattern
  • to store information about your preferences and so allow us to customise this website  according to your individual interests
  • to speed up your searches
  • to recognise you when you return to this website

You may refuse to accept cookies by activating the setting on your browser, which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of this website. For more information, please refer to our Cookie Notice.

5. Where we store your personal data

Given the global nature of our company, the Personal Data we collect from you will be transferred to and stored in different locations around the world. This means that, if you reside inside the European Union, for example, your Personal Data may be transferred to locations outside the European Union, and vice versa. All information you provide to us is stored on our secure servers. Where we have provided you with or where you have chosen a password which enables you to access certain parts of this website, you are responsible for keeping this password confidential. You must not share your password with anyone.

Where CPA Global establishes that a transfer of personal data to a third country is required, CPA Global will determine whether that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

In such circumstances, CPA Global may determine to put in place adequate safeguards to protect the data - for example:

a. by the use of a data-transfer agreement incorporating certain standard model protection clauses; and

b. compliance with the European Union-United States Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Data from EU member countries. CPA Global maintains a Privacy Shield certification.

We will take all reasonable steps to ensure that your Personal Data is only used in accordance with this Privacy Notice and applicable European data protection laws, and is respected and kept secure.

6. How long do we keep Personal Data for

We will keep your Personal Data for as long as you are a client of CPA.  After our relationship is terminated we will keep your Personal Data for a reasonable period to maintain our records and legal obligations to you.

7. Your rights

If you would rather not receive any further information from us please complete our online contact form and ask to be removed from our mailing lists. If possible, please include a copy of the communication you received to help facilitate a timely and accurate removal.

This website may from time to time contain links to and from external websites, as well as our partner and/or affiliate websites. If you follow a link to their websites, please note that these websites will be covered by their own privacy policy statement (PPS) and/or personal information collection statement (PICS). CPA Global does not accept any responsibility or liability for protection of Personal Data which you may submit to a third party’s website. We recommend that you check the wording of the relevant privacy policies before you submit any personal data to those websites.

Subject to certain provisions, you have the following general rights in relation to your Personal Data:

  • the right to be informed about how your Personal Data is being used;
  • the right to access the Personal Data we hold about you;
  • the right to opt-out of receiving direct marketing messages;
  • the right to request the correction of inaccurate Personal Data we hold about you;
  • the right to request the blocking or deletion of your Personal Data where the processing does not comply with applicable data protection laws;
  • The right to object to object to processing activities, including where profiling activities occur;
  • The right to request that our processing activities are restricted, where for example you have contested that the Personal Data held by us may be inaccurate; and
  • The right to receive the Personal Data that you have provided to us in an appropriate format with a view to transferring that Personal Data to a separate service provider.
  • The right to file a complaint with the UK Information Commissioner’s Office (ICO) or your local data protection regulator, if you are unhappy with the way we are using your Personal Data. The contact number for the ICO is 0303 123 1113 or you can access their

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contacting us" section below".

8. Contacting us

We are here to help and encourage you to contact us first to resolve your complaint.

Please contact us at Compliance@cpaglobal.com with any questions or comments.

It is very important to us that your experience using cpaglobal.com is positive. We respect your rights to privacy and the fair and just processing of your Personal Data.