GBO International Financial Services – Privacy & Cookies Policy
Last Updated: June 1, 2018
For the Terms of Service, please visit https://www.gbo-intl.com/terms-of-service.
Who We Are and How to Contact Us
GBO International Financial Services Ltd. (hereinafter: “GBO”, “We” or “Us”) is a service provider company. We offer B2B assistance in setting up International Businesses, eCommerce, Online businesses and more.
GBO offers assistance with external processes such as company formation and opening bank accounts, as well as locating company nominee services and payment services (hereinafter: “Services“). Please note that We do not offer services to binary options industries and We are not a bank and/or a payment provider.
GBO is a data controller. This means that GBO determines what data is collected, how this data is used and how the data is protected.
Our registered office address is: 65 Yigal Alon Street, Tel Aviv, Israel 6744316.
If you need any clarifications about how We process personal data, or would like to exercise your data subject rights, please email Us at: firstname.lastname@example.org.
Alternatively, you can contact Us at our global HQ in Tel Aviv, Israel using the following postal address or telephone numbers:
GDPR Compliance Manager
65 Yigal Alon Street, Tel Aviv, Israel 6744316.
Companies and Websites Within Scope
Collection of Personal Data
We collect personal data from you for one or more of the following purposes:
- To provide you with information that you have requested or which We think may be relevant to a subject in which you have demonstrated an interest;
- To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of Services;
- To fulfil a contract that We have entered into with you or with the entity that you represent;
- To ensure the security and safe operation of our websites and underlying business infrastructure, and
- To manage any communication between you and GBO.
The table below provides more detail about the data that We collect for each of these purposes, the lawful basis for doing so, and the period for which We will retain each type of data.
Lawful Basis for the Processing of Personal Data
The table below describes the various forms of personal data We collect and the lawful basis for processing this data. We have processes in place to make sure that only those people in our organization who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties and, where this happens, this is also described below.
GBO does not collect any “Special Categories of Personal Data” which is defined as follows: personal data, revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; data concerning health or sex life and sexual orientation; genetic data or biometric data; information about criminal convictions and offences.
The Services are not intended for children below 18 and GBO does not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register with the Service.
You can ask Us to stop sending you marketing messages or modify your email preferences at any time through any of the following methods:
- by following the opt-out links on any marketing message sent to you; or
- by contacting Us at any time using the contact details motioned above.
|Purpose of collection||Information category||Data collected||Purpose for collection||Lawful basis for processing||Data shared with?||Retention period|
|1. To provide you with information||Subject matter information||Personal name, company name, geographic location, email address, business sector.||To provide appropriate online or email information about products and Services that you have requested||Contractual fulfilment||Internally only||Maximum 8 years from the date the information is collected.
6 months if a marketing email is left unopened
|To provide further, related, online or email information and ongoing news updates in relation to the identified area of interest||Legitimate interest||Internally only|
|Telephone number||To provide appropriate telephone information about products and Services that you have requested and to follow-up to ensure requested information meets needs and identify further requirements||Contractual fulfilment and Legitimate interest||Internally only|
|Personal contact information as provided through website forms or at trade shows or any other means.||General mailing list subscription||Consent||Internally only|
|2.Transactional information||Transaction details||Personal name, company name, physical address, email address, telephone number, bank account details (for credit accounts), ID number of certification and all other details and personal data that is require in order to fulfill our contractual agreements||To process our Services as mentioned in the contractual agreement between Us||Contractual performance||Internally only||Maximum 8 years from the date of the performance of the contract.
6 months from the date the data subject has input personal information but has not proceeded with a transaction.
7 years for VAT records from the performance of the contract
|For accounting and taxation purposes
|Statutory obligation||Internally and other third parties as mention in the contract between Us.|
|Documentation should any contractual legal claim arise||Legitimate Interest||Internally and other third parties as mention in the contract between Us.|
|3. Security||Security information||Technical information, as described above, as well as any other information that may be required for this purpose||To protect our websites and infrastructure from cyber-attacks or other threats and to report and deal with any illegal acts||Legitimate interest||Internally, forensic and other organizations with whom We might contract for this purpose||Relevant statutes of limitation|
|4.Communications||Contact information||Personal name, company name, contact details, identification details||To communicate with you about any issue that you raise with Us or which follows from an interaction between Us||Legitimate interest||Internally and, as necessary, with professional advisers||Relevant statutes of limitation|
Storage of Personal Data
GBO is an Israel-domiciled organization whose primary offices are in Israel.
- The majority of our websites and web applications are hosted in Israel or in the European Union.
- Our customer relationship management, marketing and accounting systems are in Israel.
- We use a Cloud Service Providers (CSPs) as part of our processing environment. Unless We specifically state otherwise, We are, in respect of all these CSPs, the data controller.
- Unless We specifically state otherwise all of the CSPs that We use are Israeli located processing facilities.
- We operate a data retention policy in respect of all data, whether paper-based or digital and those aspects of it which relate to personal data are contained in the table above.
GBO has appropriate security controls in place to protect personal data. Risk assessment, including assessing risks to the rights and freedoms of data subjects, is at the heart of our Information security management system (ISMS). We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.
We have put in place procedures to deal with any actual or suspected Personal Data breach. For your information, We are obligated to inform you and the supervisory authority within the European Union regarding breach of your data or a risk of breach of your data within 72 hours of discovering the breach.
Your Rights Relating to Your Personal Data
As a data subject whose personal information We hold, you have certain rights. If you wish to exercise any of these rights, please contact Us using the details provided above. In order to process your request, We will ask you to provide two valid forms of identification for verification purposes. If you are within the European Union, your rights are as follows:
- The right of access: You may request a copy of the personal data We hold about you, free of charge. Once We have verified your identity and, if relevant, the authority of any third-party requestor, We will provide access to the personal data We hold about you as well as the following information:
- The purposes of the processing;
- The categories of personal data concerned;
- The recipients to whom the personal data has been disclosed;
- The retention period or envisioned retention period for that personal data, and
- When personal data has been collected from a third party, the source of the personal data.
If there are exceptional circumstances, regulatory, legal based or other, and We refuse to provide the information you requested, We will explain the reasons for the refusal. If requests are frivolous or vexatious, We reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), We will inform you promptly.
- The right to rectification: When you believe We hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing of your personal data to make sure that incorrect/incomplete information is not processed until it is corrected.
- The right to erasure (the ‘right to be forgotten’): Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that We delete your personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
- The right to restrict processing: You may ask Us to stop processing your personal data. We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
- The accuracy of the personal data is contested;
- Processing of the personal data is unlawful;
- We no longer need the personal data for processing, but the personal data is required for part of a legal process, and
- The right to object has been exercised and processing is restricted pending a decision on the status of the processing.
- The right to data portability: You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.
- The right to object: You have the right to object to our processing of your personal data where:
- Processing is based on legitimate interest;
- Processing is for the purpose of direct marketing;
- Processing is for the purposes of scientific or historic research;
- Processing involves automated decision-making and profiling.
- Withdraw consent: This right only exists where We are relying on consent to process your personal data. If you withdraw your consent, We may not be able to provide you with access to the certain specific functionalities of our website and Services. We will advise you if this is the case at the time you withdraw your consent.
We may also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if We combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, We treat the combined data as Personal Data which will be used in accordance with this Privacy & Cookies Policy.
Changes to This Policy
We will reply to your complaint as soon as We can.
Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to Us about our handling of your personal data, you are entitled to escalate your complaint to a supervisory authority within the European Union.