General Data Protection Regulations (GDPR)
WEBSITE PRIVACY NOTICE – LONGEVITY MANAGEMENT LTD
1. Introduction
When visiting https://www.longevitymgmt.com, Longevity Management Ltd, C54980, The Bastions, Office Number 2, Triq Emvin Cremona, Floriana, FRN 1281, Malta (“Longevity Management”, “we”, us”) may collect and process personal data (“Personal data”) about you.
This privacy notice (“Privacy Notice”) sets out which personal data that Longevity Management Ltd collects on its websites and for which purposes the Personal data is processed.
Throughout this Privacy Notice the term “processing” is used to cover all activities involving your Personal data, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of information.
“Applicable Data Privacy Laws” means data protection laws and regulations implementing the Data Protection Directive 95/46/EC and as of 25 May 2018 the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the “GDPR”).
“Personal data” is defined as any information relating to an identified or identifiable natural person.
From were do we collect personal data
We collect personal data directly from you when using our services.
2. Cookies – why do we collect and process your personal data
Longevity Management Ltd uses cookies and other similar techniques to collect information about you when you visit our website. For more information regarding Longevity Management’s use of cookies, please view our cookie policy https://www.longevitymgmt.com/privacy-policy.
3. Why do we collect and process your personal data
3.1. Answer your Questions and handle Feedback in General
Our website provides functionality for the visitor to communicate with us to ask questions and give feedback regarding our services and business. Where you use such functionality Longevity Management Ltd will process your Personal data for the purposes of answering your questions and handling feedback from you. Personal data processed for these purposes include:
Categories of personal data
First name Last name Email address Feedback and comments made by you
The legal basis for the above processing of your personal data is that the processing is necessary in order to fulfill our legitimate interest to answer questions and handle feedback from you,
article 6.1 f) GDPR. If you do not provide information marked with * on the website form we will not be in a position to provide you with the requested service.
3.2. Create personal Website User Accounts
Our website allow users to set up a personal user account with log-in. If you create a user account Longevity Management Ltd will process your personal data for the purposes of creating and managing your personal user account, create your log-in and provide you with access to your account. Personal data processed for these purposes include:
The legal basis for the above processing of your personal data is that the processing is necessary in order to fulfill our legitimate interest to create and manage your user account and fulfill the user account agreement with you, article 6.1 b) GDPR. If you do not provide information marked with * on the website form we will not be in a position to provide you with the requested service.
3.3. Comply with legal obligations
Longevity Management Ltd processes Personal data in order to comply with legal obligations, such as book-keeping and tax purposes and anti-money laundering laws. Personal data processed for these purposes include:
Categories of personal data
First Name Last name Transaction data Other information as necessary for the purpose
The legal basis for the above processing of your Personal data is that the processing is necessary for Longevity Management Ltd’s compliance with legal obligations, article 6.1 c) GDPR.
3.4. Establish, exercise and defend legal claims
Longevity Management Ltd may process your Personal data for the purposes of establishing, exercising and defending legal claims in the unlikely event of a dispute. Personal data processed for these purposes include:
Categories of personal data
First name Last name Email address Other information as necessary for the purpose
The legal basis for the above processing of your personal data is that the processing is necessary in order to fulfill our legitimate interest to establish, exercise and defend legal claims, article 6.1 f) GDPR.
Categories of personal data
First name Last name Email address
4. For how long do we keep your personal data
Longevity Management Ltd will retain Personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by local law to which Longevity Management Ltd is subject. We are using the following criteria to establish our retention period: (i) as long as we have an ongoing relationship with you (either as an individual or in your capacity as employed by one of our corporate customers, suppliers or co-operations partners); (ii) as required by legal obligations to which Longevity Management Ltd is subject (such as tax and accounting obligations); and (iii) as advisable in light of our legal position (such as applicable statutes of limitations).
5. Disclosure and transfer of Personal data
Group companies
There are no other companies associated with Longevity Management Ltd.
Other recipients
Recipient
Purpose of transfer
Legal basis
Category of personal data
LFS Invest Group of companies
Forward clients’ questions regarding the LFS Invest Group of companies
To fulfill the management contract of running the day to day activities of the LFS Invest Group companies.
Name, Last name and email address
Courts and outside counsels
In order to exercise, establish or defend legal claims
To fulfill ours and yours legitimate interest to have disputes settled by competent courts.
Data processors acting on behalf of Longevity Management Ltd
Moreover, Longevity Management Ltd may disclose Personal data to external parties, such as vendors and service providers processing Personal data under the instructions of Longevity Management Ltd. Where such disclosure entails transfers of Personal data outside the EU/EEA, Longevity Management Ltd will ensure that Standard Contractual Clauses have been entered into between the transferring Longevity Management Ltd entity and the receiving external party. Alternatively, other safe guards will be put in place prior to such transfers.
Appropriate Safe Guards to countries outside the EU/EEA-area
Longevity Management will not transfer your Personal Data outside the EU/EEA.
6. Security
6.1. We will ensure that the access to your data is accurately secured by applying appropriate safeguards, depending on the circumstances taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk. In support of this commitment, we have implemented appropriate technical, physical and
organizational measures to protect your personal data against: unauthorized or accidental destruction, alteration or disclosure; misuse; damage; theft or accidental loss; or unauthorized access.
7. Your rights
7.1. Right of rectification
Longevity Management Ltd will take steps in accordance with Applicable Data Privacy Law to keep your Personal data accurate, complete and up-to-date. If you identify that any Personal data related to you is inadequate, incomplete or incorrect, you are entitled to have the Personal data corrected.
Moreover, you also have the right to request access to the Personal data that we process about you.
7.2. Further rights as of 25th May 2018
As of 25th May 2018, you are also under Applicable Data Privacy Law in addition to rectification entitled to:
(i) Access
You may request confirmation whether or not Personal data is processed and if that is the case access to your Personal data and additional information such as the purposes of the processing. You are also entitled to receive a copy of the Personal data undergoing processing. If the request is made by electronic means the information will be provided in a commonly used electronic format if you do not request otherwise.
(ii) Object to certain processing
You may object to processing of your Personal data processed on the basis of a legitimate interest, on grounds relating to your particular situation and to processing for direct marketing purposes. If you have opted to receive a subscription by email each email will include an easy accessible opt-out function where you may deregister from further communication.
(iii) Erasure
You may have your Personal data erased under certain circumstances such as when your Personal data it is no longer needed for the purposes for which it was collected.
(iv) Restriction of processing
You may ask us to restrict the processing of your Personal data to only comprise storage of your Personal data under certain circumstances such as for example when the processing is unlawful, but you do not want your Personal data erased.
(v) Withdrawal of consent
You have the right to at any time withdraw your consent to processing of Personal data to the extent the processing is based on your consent.
(vi) Data Portability
You may ask to receive a machine-readable copy of the Personal data processed on the basis of your consent or on the basis that the processing is necessary in order to perform an agreement with you, and which Personal data have been provided to Longevity Management Ltd by you (data portability) as ask for the information to be transferred to another data controller (where possible).
7.3. Complaints to the supervisory authority
You acknowledge that you always have the right to lodge complaints pertaining to the processing of your Personal data to the competent data protection authority if so provided under Applicable Data Privacy Law. The data protection authority can be reached here https://idpc.org.mt .
8. Contact information
If you have any questions or concerns regarding the processing of your Personal data or wish to exercise any of your rights, please contact Longevity Management Ltd on the contact details set forth below.
The data controller for Personal data is Longevity Management Ltd, C54980
The Bastions Office Number 2 Triq Envic Cremona Floriana, FRN 1280 Malta
clientsupport@longevitymgmt.com +356 2704 0352