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WEBSITE PRIVACY NOTICE AND COOKIE NOTICE

Nest Investments (Holdings) Limited (‘Nest’) respects your privacy and is committed to protecting your personal data. This Website Privacy Notice and Cookie Notice (‘Privacy and Cookie Notice’) will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.


PURPOSE OF THIS PRIVACY AND COOKIE NOTICE  

This Privacy and Cookie Notice aims to give you information on how Nest collects and processes your personal data through your use of this website, including any data you may provide through this website when you fill up the contact form.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy and Cookies Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy and Cookie Notice supplements the other notices and is not intended to override them.

 

CONTROLLER

Nest is the controller and responsible for your personal data (collectively referred to as “Nest”, “we”, “us” or “our” in this Privacy and Cookie Notice).

We have appointed a Compliance Manager (CM) who is responsible for overseeing questions in relation to this Privacy and Cookie Notice. If you have any questions about this Privacy and Cookie Notice, including any requests to exercise your legal rights, please contact the Nest’s Compliance Manager using the details set out below.

 

CONTACT DETAILS  

Email of Compliance Manager: nest@nestco.org

Postal address: WTC-Trust Re Building, 3rd Floor, 359, 28th October Street, CY-3107, Limassol, Cyprus

Telephone number: +357 25 588 811

 

You have the right to make a complaint at any time to the Data Protection Commissioner’s Office, the Republic of Cyprus’ supervisory authority, for data protection issues.

1 Iasonos Street,

1082 Nicosia, Cyprus

Tel.:   +357 22 818 456

Fax:   +357 22 304565

E-mail: commissioner@dataprotection.gov.cy

 

We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commissioner’s Office so please contact us in the first instance.

 

CHANGES TO THE PRIVACY AND COOKIE NOTICE AND YOUR DUTY TO INFORM US OF CHANGES  

Nest reserves the right to update or amend this Privacy and Cookie Notice at any time. As the user, you agree to be bound by such changes, and to its current relevancy as presented on this website at any given time.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

THE DATA WE COLLECT ABOUT YOU  

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, maiden name and last name.
  • Contact Data includes delivery address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

 

HOW IS YOUR PERSONAL DATA COLLECTED?  

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your personal data by filling in forms. This includes personal data you provide when you complete our contact form online.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data. We collect this personal data by using cookies.

 

HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where you provided your consent.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  

Nest needs to know personal data about you to respond to requests you make to us.

 

COOKIES  

What are Cookies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

How do we use cookies?

Nest uses cookies to remember:

  • Your language preference
  • Non-essential cookies

The language cookie collected from Nest website session is an essential cookie and this means that Nest does not need to get the consent of the website visitor to collect this cookie.

  • The language cookie falls in the category of user‑interface customisation for the duration of a session (or slightly longer).

A session cookie means that is a temporary cookie that remains on your device until you leave the website, i.e. lasting only for as long as the session (usually the current visit to the website or a browser session).

With respect to the non-essential cookies collected from our website, Nest does need to get the consent of the website visitor to collect this cookie. Each website visitor will find a consent banner at Nest website and the visitor consent is needed for Nest to collect those cookies.

How to control cookies

You can control and/or delete cookies as you wish – for details, see http://www.aboutcookies.org.uk/

You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.

DISCLOSURES OF YOUR PERSONAL DATA  

We do not and do not intend to share your personal data with any third parties (internal or external).

 

INTERNATIONAL TRANSFERS  

We do not and do not intend to transfer your personal data outside the EEA.

 

DATA SECURITY  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

DATA RETENTION  

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  

We will only retain your personal data for as long as necessary to fulfill the purpose we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

 

YOUR LEGAL RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data and in particular to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • 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. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

 

NO FEE USUALLY REQUIRED  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

WHAT WE MAY NEED FROM YOU  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

TIME LIMIT TO RESPOND  

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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