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EisnerAmper Cayman | Privacy Policy Cayman

EisnerAmper Global

Privacy Policy

Scope

The privacy notice explains how EisnerAmper Cayman Ltd. (hereafter referred to as “EAC”) collects, uses, discloses, retains and secures your personal data as part of its business practices. The policy clearly articulates the legal justifications for the processing of your personal data and also lists your data subject rights under the Cayman Islands’ Data Protection Law, 2017 (“DPL”).

Overview

EAC respects your privacy, and you are entitled to have your personal data processed in accordance with the DPL. The key principles EAC applies when processing your personal data are as follows:

  • Lawfulness: EAC will only collect personal data in a fair, lawful and transparent manner.
  • Data minimisation: EAC will limit the collection of personal data to what is directly relevant and necessary for the services provided.
  • Purpose limitation: EAC will only collect personal data for specified, explicit and legitimate purposes.
  • Accuracy: EAC will keep personal data accurate and up to date while there continues to be a customer relationship, and in certain circumstances, after that relationship has ended.
  • Data security and protection: EAC will implement technical and organisational measures to ensure an appropriate level of data security and protection considering the sensitivity of the personal data. Such measures provide for the prevention of any unauthorized or unlawful processing of personal data and against accidental loss or destruction of, or damage to that data.
  • Access and rectification: EAC will process personal data in line with customers’ legal rights.
  • Retention limitation: EAC will retain personal data in a manner consistent with the applicable DPL and DPL Regulations and no longer than is necessary for the purposes for which it has been collected in accordance with its retention policy.
  • Protection for international transfers: EAC will ensure that if personal data is transferred outside the Cayman Islands, it is adequately protected.

What personal data does EAC collect?

EAG collects various personal data which may include the following (this list is not exhaustive):

  • name and address
  • date of birth
  • telephone number
  • email address
  • copy of passport photo/biographical data page
  • financial information included your method of payment such as check or wire transfer to EA

How does EAC use the personal data it collects?

EAC may use your personal data to (this list is not exhaustive):

  • respond to customer inquiries
  • manage the customer relationship
  • send invoices and collect payment for goods or services rendered
  • conduct promotional activities
  • market goods and services
  • handle complaints
  • prevent fraud or other criminal activity
  • record health and safety details if there is an incident at the EAC office

When does EAC disclose your personal data?

EAC may disclose your personal data in the following circumstances (this list is not exhaustive):

  • if EAC uses a third-party service provider for marketing, marketing research or client relationship management
  • if a data subject requests that personal data be disclosed to a third party
  • if there is a legal request or criminal investigation
  • if it is required to seek legal advice from EAC legal counsel
  • any other circumstance where it may be required by law

International transfer of personal data

Your personal data is stored in the Cayman Islands unless it is transferred to another country for contractual purposes. If at any time EAC transfers personal data outside the Cayman Islands, it will ensure that there are adequate safeguards for the rights and freedoms of data subjects as required by the DPL.

The legal basis for processing your personal data

The DPL protection sets out some different reasons for which a company may process personal data, and EAC does so under the following legal conditions:

    • Consent
    • In specific situations, EAC may collect and process personal data with your consent.
    • Contractual obligations
    • In certain circumstances, EAC will need to process certain personal data to comply with contractual obligations for which we have been engaged.
    • Legal compliance
    • If the law requires, EAC may need to process your personal data.
    • Legitimate interest
    • In specific situations, EAC requires your personal data to pursue its legitimate interests in a way which might reasonably be expected as part of running its businesses and which does not materially impact your rights, freedom or interests.
    • For example, EAC may use an email address you have provided to send you information on our services.

How long does EAG retain your personal data?

EAC retains your personal data for as long as a customer relationship exists, and the personal data is necessary to manage that relationship. When there is no longer a customer relationship, EAC will retain certain types of personal data for varying periods depending on legal requirements and business needs. Personal data that is no longer needed will be destroyed. EAC will always hold your personal data for the least amount of time necessary in accordance with its retention policy. For specific retention periods, customers should contact Ben Leung at bleung@eisneramper.ky.

How does EAC secure your personal data?

EAC employs appropriate technical and organizational measures to protect against unauthorized processing, accidental loss or destruction of, or damage to, your personal data in accordance with its Information Technology policies.

What rights do you have in respect to your personal data?

You have a right to be informed how your personal data is processed and this privacy notice fulfills EAC’s obligation in that respect. If you have further questions or concerns not addressed in this notice, you may contact Ben Leung at bleung@eisneramper.ky.

You have a right to request access to your personal data, the right to request rectification/correction of your personal data, the right to request that processing of your personal data be stopped or restricted and the right to require EAC to cease processing your personal data for direct marketing purposes. If you wish to exercise any of these rights, you should contact Ben Leung at bleung@eisneramper.ky.

If you feel that your personal data has not been handled correctly, or you are not satisfied with EAC’s responses to any requests you have made regarding the use of your personal data, you have the right to complain to the Cayman Islands’ Ombudsman. The Ombudsman can be contacted by calling: 1-345-946-6283 or by email at info@ombudsman.ky.