Our processing of personal data of our users is limited to those data that are necessary for the provision of a functional website as well as our contents and services. The processing of personal data of our customers and interested parties only takes place for the purposes agreed with them or if there is another legal basis (within the meaning of the GDPR). We only collect personal data that is required for the implementation and processing of our tasks and services or that you have voluntarily provided to us. We manage your personal data with due care. Furthermore, we protect your personal data from misuse.
Privacy
1. Responsible person and data protection officer
The responsible person according to the General Data Protection Regulation (GDPR) is Numeri GmbH, Zollstrasse 16, 9494 Schaan, Liechtenstein, e-mail: mail@numeri.li, tel: +423 340 33 77.
You can reach our data protection officer at the following e-mail address: datenschutz@numeri.li or by mail at the following address: Zollstrasse 16, 9494 Schaan, Liechtenstein.
2. Data processing regarding clients (purposes, categories, legal basis)
We process our clients’ personal data for the following purposes: preparation of offers for our services, providing our professional services, administration of our business relationships, documentation, exercising and defending our legal rights, complying with our legal and regulatory obligations such as the due diligence act (DDA) and any other purposes expressly and individually agreed upon.
We process for these purposes in particular identity and contact data (name, home address, company, business address, telephone number, e-mail-address, copy of identification and/or passport etc.), biographical data (nationality, date of birth, current and past professional or entrepreneurial activities), tax reporting data, further relevant information for the fulfillment of our advisory and representation activities (e.g. contracts and agreements, bank documents, corporate documents etc.) information on the asset situation and the origin of assets, correspondence.
The personal data mentioned above is gathered and processed based on the following legal basis:
- on the basis of your consent (Article 6 (1)(a) of the GDPR or Article 9 of the GDPR);
- for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract (Article 6(1)(b) of the GDPR) such as, in particular, to prepare offers for our activities, to carry out our advisory and representation activities on your behalf and to manage our business relationship with you;
- for the compliance with a legal obligation (Article 6 (1)(c) of the GDPR), such as, in particular, compliance with our obligations under the due diligence act;
- to carry out a task in the public interest or in the exercise of official authority (Article 6 (1)(e) of the GDPR); or
- for the purposes of the legitimate interests pursued by the data controller or a third party (Article 6(1)(f) of the GDPR).
Legitimate interests may include interal administration, evaluations, marketing, direct marketing and defending against unjustified claims.
3. Recipients and sources of personal data
For providing our services in fulfillment of our contractual obligations it may be necessary to share personal data with third parties (insurances, service providers we use and to whom we make data available etc.) or authorities. We only transfer personal data in accordance with applicable law (GDPR, Liechtenstein Data protection act), in particular for fulfilling our contractual obligations or based on your prior consent.
Some of the recipients of your personal data mentioned above are located outside your country or even outside the European Economic Area or process your personal data there. The level of data protection in other countries may not correspond to that in Liechtenstein. However, as a matter of principle, we only transfer your personal data to countries for which the EU-Commission has decided that they have an adequate level of data protection. In addition to the data transfer to these countries, it may also be necessary in individual cases to transfer your personal data to countries for which the EU-Commission has not issued an adequacy decision. Such a transfer may not ensure a level of data protection that complies with the GDPR. Authorities in these countries may be able to access your data more easily. However, we will only transfer your personal data to these countries if you have explicitly consented to such transfer, the transfer is necessary for the performance of a contract with you or for the implementation of pre-contractual measures, the transfer is necessary for important reasons of public interest or the transfer is necessary for the establishment, exercise or defense of legal claims. For more detailed information on this, please contact us (see point 1.).
Furthermore, we may also receive personal data about you from third parties in the course of our activities. Such third parties are mainly courts and authorities.
4. Storage periods
Personal data will be processed and stored for the duration of the business relationship within the framework of the statutory provisions. Once the business relationship has been terminated, these data are retained for 10 years on the basis of statutory provisions (PGR, DDA, Liechtenstein Civil Code [Allgemeines bürgerliches Gesetzbuch – ABGB]). Longer retention periods will be enforced only on the basis of statutory or contractual requirements to retain data or for the purpose of maintaining evidence within any applicable statutory limitation periods.
5. Data processing regarding job applicants
On receipt of your application we process personal data such as your name, title, address, telephone number, date of birth, education, work experience, salary expectations and any data and images that are contained in the accompanying letter, CV, letter of motivation, certificates and other documents and records that you send to us, for the purpose of personnel selection.
We process your personal data in the scope of our recruitment process on the basis of Section 1173a Article 28a of the Liechtenstein Civil Code (Allgemeines bürgerliches Gesetzbuch – ABGB) and of Article 6(1)(b) of the GDPR. If an applicant wishes their information to be retained in a pool of applicants for the purpose of potential subsequent cooperation, we require consent for this in accordance with Article 6(1)(a) of the GDPR.
Your data will not be transferred to third parties without your consent.
If you are not hired, we will retain your data for up to six months for the purposes of documentation in any eventual legal proceedings before erasing it.
6. Your rights (rights of the persons affected)
You have the right to request information about the personal data we process about you. In particular, you have the right to request information about the purpose of the processing, the categories of personal data, the categories of recipients to whom the personal data have been or will be disclosed, the planned storage period, the data source where the personal data are not collected through us, the existence of a right of rectification or erasure of personal data concerning you or to restriction of processing by us or a right to object to such processing, the existence of a right to lodge a complaint with a supervisory authority, and information on whether we apply automated decision-making technologies including profiling.
You also have the right to have inaccurate personal data concerning you corrected, to have incomplete personal data completed or to have your personal data deleted, provided that certain conditions are met (e.g. unlawful processing). Furthermore, you have the right to restrict processing under the legal conditions.
Additionally, you have the right to withdraw a previously granted consent to use your personal data at any time without affecting the lawfulness of processing based on consent before its withdrawal. A withdrawal notice can be sent by informal letter to our address (Numeri GmbH, Zollstrasse 16, 9494 Schaan, Liechtenstein) or by e-mail to mail@numeri.li.
Furthermore, pursuant to Art. 21 GDPR, you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1)(f) GDPR. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing.
Furthermore, you have in principle the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format or to request the transfer to another controller.
If you believe that the processing of your personal data contradicts the applicable data protection laws you have the possibility to lodge a complaint with us (mail@numeri.li) and/or the data protection office (www.datenschutzstelle.li).
The contact details of the data protection office are as follows:
Städtle 38
Postfach 684
FL-9490 Vaduz
Tel.: +423 236 60 90
E-Mail: info.dss@llv.li
7. Automated decision-making (Art. 22 GDPR)
There is no automated decision making with personal data. If such technologies are applied in a specific case affected individuals will be informed by us in accordance with legal provisions.
8. Website, electronic communication
We do not perform any web analysis on our website and do not use any web analysis tools (e.g. Google Analytics). The user and visitor data will not be evaluated or analyzed.
For optimizing this website regarding system-performance, usability and provision of useful information on our services the website provider gathers and stores information automatically in so-called server-log-files. This information includes IP-addresses, browser and language settings, operating system, referrer URL, internet service provider and date and time and is transmitted to us automatically. The data will not be merged with personal data sources. We reserve the right to subsequently assess the data if concrete indications for illegal use arise.
Our website uses Google Maps (provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to display an interactive map and to create directions. Thereby IP addresses and location data of users can be processed if you agree to that (usually this agreement is given within the framework of your device settings). The data may be processed in the USA.
If you send us an e-mail or a message via another telecommunication channel your data will only be stored and used for dealing with your request and related questions. The legal basis for using data for dealing with your requests is Article 6(1)(b) GDPR. We will delete your e-mail address after completion of your request.
9. Necessity of the data (Article 13(2)(e) of the GDPR)
Provision of the data listed above is mandatory in order to allow us to offer our clients the services they require and fulfil our statutory obligations. In addition to possible statutory reporting obligations to the responsible supervisory authorities, failure to provide data will result in the non-establishment or termination of the business relationship.
10. Data Security
Your personal data is protected by the implementation of technical and organizational measures. Those measures include in particular protection against unauthorized, illegal or accidental access, processing, loss, use or manipulation.
Notwithstanding our efforts to continually maintain an appropriately high standard in due diligence we cannot completely eliminate the risk that other persons might see and use information that you send us by e-mail or other electronic communication.
Therefore, please note that we cannot accept liability of any kind for disclosure of information caused by third party mistakes in data transmission and / or unauthorized access by third parties (e.g. hacker attacks).
11. Up-to-dateness and validity of this privacy statement
This privacy statement is up-to-date and valid as of August 2023. Legislative developments and developments in our website and offers may bring upon the necessity to change this privacy statement.