This Privacy Policy for Palace Advisory is issued by Palace Advisory, (together with our Terms of Use and any other documents referred to in it) explains the collection, use, and disclosure of Personal Data (as defined below) by Palace Advisory including through our websites located at the following URL: www.Palace Advisory (“our site”). We have developed this policy because we want you to feel confident about the privacy and security of your Personal Data held by us. Please read the following carefully to understand our practices regarding your Personal Data and how we will treat it. “Personal Data” means any information relating to you that would allow a party t o identify you as an individual or to contact you, including, for example, your full name, address, telephone number, or email address.
Personal Data we collect and how we use it
We collect and use your Personal Data carefully, only to perform our own services and only to the extent necessary for this purpose. We collect and process the following Personal Data about you: Media Inquiries: Title, First Name, Last Name, Media outlet of affiliation, Contact type, Email, Country. Where we have a contract with you, we will also hold any personal contact details contained in that contract, which may include payment information and invoice information. Connexion information (last login date, IP address) and mobile device information (device ID, manufacturer, platform, version). Information about how you use our website, including technical information (such as type of browser and operating system) and log information (your visits to and use of the site). This includes information gathered by the use of cookies in your web browser. If you contact us, we keep a record of that correspondence. Any other information uploaded by you onto our site.
Lawful basis for processing
We are able to lawfully process your personal data where you have explicitly consented to this. We are also permitted to process your personal information where (i) the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you, (ii) where the processing is necessary for compliance with a legal obligation that we have, or (iii) for the purposes of our overriding legitimate interests. Our legitimate interests might be: to prevent fraud, to provide you with a safe, efficient and customised experience on our Website and to provide the services you have requested. We will use your Personal Data: For client and contract management in order to contact you and for electronic signature of contracts. To provide information and services you request. For security or fraud prevention purposes. To provide you with effective customer service. To provide you with a good user experience when you use our site. To improve the content, functionality and usability of our site. To improve our products and services. Where you have consented explicitly, we may contact you with marketing offers. To improve our marketing and promotional efforts.
IP addresses and use of “cookies”
We collect information about your computer, including where available your internet protocol (“IP”) address, operating system and browser type, for system administration. An IP address is a number that is automatically assigned to your computer when you use the internet. We use IP addresses to help diagnose problems with our server, administer our site, analyse trends, track users’ activity within the application, and gather broad demographic information for aggregate use in order for us to improve our site. We do use cookies that are vital for the basic functionality of the website. A cookie is a small data file that our server sends to your browser when you visit the site. Cookies will only be stored to improve the performance of the site in order to retrieve data in the most effective way and notify the user of previous activities. You can delete cookies at any time or you can set your browser to reject or disable cookies. If you are unsure how to do this, follow this link where you will find instructions for many of the most popular web browsers: http://www.allaboutcookies.org/manage-cookies/stop-cookies-installed.html.
Where we store your Personal Data
The Personal Data that we collect from you may be transferred to, and stored at, a destination outside Switzerland and the European Economic Area (“EEA”). Such destination countries may have different levels of privacy protection than in your country of residence. Your Personal Data are processed by staff operating outside Switzerland and the EEA who work for us or for one of our group companies, affiliates or suppliers. These staff are engaged in the provision of support services. By submitting your Personal Data via our site, you agree to any such transfers, storage or other processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy. These steps include imposing contractual obligations on the recipients of your Personal Data to protect that Personal Data, using standard contractual clauses approved by the European Commission. We may alternatively require approved codes of conduct or certification mechanisms to be in place. Please contact our data protection team at the address in the Contact section to obtain more information about our contractual clauses imposed on third party recipients of your Data. We store your Personal Data carefully. We have implemented, and follow, industry standard measures to protect against unauthorized access to, and unlawful interception or processing of, Personal Data. Once we have received your Personal Information, we will use strict procedures and security features to prevent unauthorized access.
Disclosure of Personal Data
We may disclose your Personal Data to any member of our group, which means our subsidiaries, our ultimate holding parent company and its subsidiaries and/or affiliates. Furthermore, we disclose your Personal Data to our business partners (DocuSign and Certisign for electronic signature, Plivo for SMS communication, Microsoft for hosting, Google for web analytics) insofar and for as long as it is necessary to perform our services. We oblige our business partners to assume and apply the same rights and obligations regarding your Personal Data as described in this Privacy Policy. Other than previously specified in this Privacy Policy, we may also disclose your Personal Data to third parties in the following circumstances: If we become part of another organization, such organization will possess the Personal Data collected by us, and it will apply and assume the same rights and obligations regarding your Personal Data as described in this Privacy Policy. If we are under a duty to disclose or share your Personal Data, or part of it, in order to comply with any applicable legal or regulatory obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of us, our customers, or others.
Retention of Personal Data
The time period for which we shall retain and keep Personal Data varies according to various statutes and what the information is used for. In some cases, there are legal requirements to keep data for a minimum period of time. Unless there is a specific legal requirement for us to retain and keep the information, we will retain and keep it only insofar and as long as it is necessary for the purposes for which the data was collected or for which it is to be further processed.
Non-personal information
Non-personal information is information that does not identify you individually. We collect non-personal information from your computer, such as your Web browser, the date and time of your Web site visit, the Web address from which you accessed our site, the number of visitors to the site, the pages viewed, and the length of time on the Web site.
Marketing
We collect data to analyse the website in general, to gain insights into how to improve our services and to target our marketing measures to your identifiable needs. You have the right to ask us not to process your Personal Data for our marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for our own marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your Personal Data. You can also exercise the right at any time by contacting us at the address in the Contact section. If you consent to the use of your Personal Data for marketing purposes, you can change your mind and opt-out of this at any time. You can do this by selecting ‘unsubscribe’ at the bottom of any marketing email you receive from us, or at any time by contacting us at the address in the Contact section.
Your rights
Right of Access
You have the right to access and receive a copy of your Personal Data held by us.
Right to Rectification
You have the right to demand that we correct incorrect information.
Right to Erasure
You have the right to request the erasure of your Personal Data at any time, if you consider that we do not have the right to hold it. We may retain certain information about you as required by law and for legitimate business purposes permitted by law.
Right to Restrict Processing
You can ask us to suspend the processing of your Personal Data in several scenarios, including if you want us to verify the accuracy of the data, and where our use of the data is unlawful but you do not want us to erase it.
Right to Data Portability
You can request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. This right only applies to information which you initially provided consent for us to use, where we used the information to perform a contract with you or where the processing of your Personal Data is carried out by automated means.
Right to Object
You have the right to object to your Personal Data being processed for a particular purpose or to request that we stop using your Personal Data.
Right to Withdraw Consent
Where our processing of your Personal Data is based on your consent, you have the right to withdraw your consent at any time. If you do so we will stop processing your Personal Data unless there is another lawful basis we can rely on, if which case we will inform you of this.
Right to Reject Automated Individual Decision-Making
You can request not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data;
Rights regarding Marketing Communications
The right to ask us to stop or to start sending marking messages at any time. If you want to exercise these rights, you should contact us at the address in the Contact section.
Modifications to this Privacy Policy
We reserve the right to change, alter or otherwise modify this Privacy Policy at any time by posting revisions on this web page. In case of change, you will be alerted.