TERMS OF USE

For Economic Substance related Web Forms

Last updated 02 Jan 2020


Thank you for choosing to use our web-based forms to submit relevant information to your Corporate Service Provider related to Economic Substance filings and compliance. Our company, Economic Substance Solutions Ltd. (“Company”, “we”, “us”, or “our”) is committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at compliance@economicsubstance.co.

When you use our online forms, you trust us with your personal information. We take your privacy very seriously. In this policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this policy that you do not agree with, please discontinue use of our services or contact us at compliance@econoicsubstance.co. 


This privacy policy applies to all information collected through our online forms and and/or any related services, email provider, data processing/storage provider, web hosting, or other related IT services. (we refer to them collectively in this privacy policy as the "Services").  

Please read this policy carefully as it will help you make informed decisions about sharing your personal information with us.   


TABLE OF CONTENTS  

  1. WHAT INFORMATION DO WE COLLECT?

  2. WILL YOUR INFORMATION BE SHARED WITH ANYONE?    

  3. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?     

  4. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?    

  5. HOW LONG DO WE KEEP YOUR INFORMATION?    

  6. DO WE COLLECT INFORMATION FROM MINORS?  

  7. WHAT ARE YOUR PRIVACY RIGHTS?

  8. CONTROLS FOR DO-NOT-TRACK FEATURES 

  9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 

  10. DO WE MAKE UPDATES TO THIS POLICY?

  11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

  12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?


1. WHAT INFORMATION DO WE COLLECT?  


Personal information you disclose to us 

In Short: We collect personal information that you provide to us such as name, address, contact information, corporate and filing information as it relates to Economic Substance Compliance for your offshore entity.

We collect personal information that you voluntarily provide to us when filling out forms or otherwise use to contact us.

The personal information that we collect depends on the context of your interactions with us and the, the choices you make and the products and features you use. The personal information we collect can include the following:

Information automatically collected 

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you use out online forms.

We automatically collect certain information when you submit or update an electronic form. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our and other technical information. This information is primarily needed to maintain the security and operation of our platform, to identify your form submission if it needs revisions, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.


2. WILL YOUR INFORMATION BE SHARED WITH ANYONE?  

In Short:  We are a data processor and serve in the function to process and transmit information to your corporate service provider.  We only share information with your with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.   

We may process or share data based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose. 

  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests. 

  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract. 

  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). 

More specifically, we may need to process your data or share your personal information in the following situations:

  • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: email handling, payment processing, data analysis, web hosting, customer service and coordinated communications with your corporate services provider and your the information provided from your entity. We may allow selected third parties to use tracking technology on this form, which will enable them to collect data about how you interact with the platform over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.     

  • Affiliates. We will share this information with your corporate service provider to facilitate information exchange so that they may submit the required filings related to Economic Substance.

     

3. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?  

In Short:  We may use cookies and other tracking technologies to collect and store your information.  

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.  

    

4. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?  

In Short:  We may transfer, store, and process your information in countries other than your own.  

Our servers are located in the United States and Ireland. If you are accessing our web form from outside these areas, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above), in and other countries.

If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

5. HOW LONG DO WE KEEP YOUR INFORMATION?  

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.   

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 2 years to facilitate filing your initial economic substance filings and pre-populating the following years form for the following year’s filing.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. 

6. DO WE COLLECT INFORMATION FROM MINORS?  

In Short:  We do not knowingly collect data from or market to children under 18 years of age.  

We do not knowingly solicit data from or market to children under 18 years of age. By using our platform, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the platform. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at compliance@economicsubstance.co


7. WHAT ARE YOUR PRIVACY RIGHTS?  

In Short:  You may review, change, or terminate your account at any time.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Form and Account Information  

If you would at any time like to review or change the information in your form or terminate your account, you can by clicking on the link provided in the thank you email send post submission.  Note, the date of your economic substance filing with the regulatory authorities, modifying your form will not automatically modify the information your corporate service provider previously submitted: 

Upon your request to terminate your account, we will deactivate or delete all information related to your account and information from our active databases. However, some information may be retained in our files provide to the corporate service provider, to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Opting out of emails: You can unsubscribe from our email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account.


8. CONTROLS FOR DO-NOT-TRACK FEATURES  

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.  


9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?  

In Short:  Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.   

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. 

10. DO WE MAKE UPDATES TO THIS POLICY?  

In Short:  Yes, we will update this policy as necessary to stay compliant with relevant laws.  

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?  

If you have questions or comments about this policy, you may email us at compliance@economicsubstance.co


12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact us at complinace@economicsubstance.co. We will respond to your request within 90 days.  Alternatively, you may click on the link that was emailed to you upon form submission to review and update the information you provided and that we collected and transmitted.

 
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