A. INFORMATION WE COLLECT
CST may collect and process the following types of information:
1. Contact Information
When you contact us to make an enquiry, we will collect and use your name and contact information (“Contact Information”), including your email address and your contact number, to respond to your enquiry. Similarly, when you register for our events, we will collect and use your Contract Information. We will also use Contact Information to further communicate with you for purposes related to the provision of our services to you as our client (or prospective client).
2. Client Information
In addition to Contact Information, CST collects and processes personal information about our clients (“Client Information”), including but not limited to the following:
a) Personal and financial information about you which you provide to us during your onboarding as our client, including but not limited to your national identification number, passport number, age, date of birth, gender, marital status, occupation, nationality, residency, residential address, income, assets, wealth;
b) Personal and financial information about your family members which you provide to us during your onboarding as our client, including but not limited to their national identification number, passport number, age, date of birth, gender, marital status, occupation, nationality, residency, residential address, income, assets, wealth;
c) Internal notes, records, and information about you through your interactions with us as our client;
d) Information about you, which is available publicly, e.g., online, or social media; and
e) Information about you obtained from third parties including banks, credit agencies, regulatory bodies, or other client(s) through whom you were referred to us.
3) Other Information
To better serve you, CST collects, and processes other information related to you, including:
b) Anonymous aggregate user and tracking information from log analysis software and other aggregate tracking technologies: This information gives us insights on how our site visitors use our site. This data is anonymous and does not contain any personally identifiable information. We use this information to ensure that our website, e-mails, and marketing efforts continue to appeal to our site visitors.
B. HOW WE USE YOUR INFORMATION
1) General Purposes
Generally, CST may use, record, systemize, store, update, modify, retrieve, share, disclose,
delete, or otherwise process your information for the following purposes, using manual or
a) Provide services, including services agreed under contact, customer, content, product services, technical support, and responses to you;
b) Deliver notifications, emails, text messages, alerts, and other communications to you about our services and of our third-party partners as agreed by you;
c) Customize and personalize content, customer, and product services to you;
d) Send marketing communications and informational newsletters that you have requested, opted-in to or otherwise agreed to receive;
e) Improve the quality of your experience and/or our provision of services to you, including sending surveys to you;
f) Keep your account information updated to ensure accuracy of information;
g) Allow our third-party contractors or service providers to perform functions or services on our behalf;
h) Comply with legal and regulatory requirements and company’s policies and procedures
as may be applicable from time to time; and
i) Any other reasonable purposes related to the above.
2) For Legitimate Interests
In addition to and without prejudice to the general purposes described above, CST may, in the legitimate interest of the company, use and/or disclose any information about you or your use of our site without your prior permission if CST has a good faith belief that such action is necessary to:
a) protect and defend the rights, property or safety of CST or its partners, employees, affiliates, other users of the site, or the public;
c) respond to claims that any content violates the rights of third parties or is otherwise unlawful.
3) Use of Aggregated Information
CST may use aggregated information which is not personally identifiable for purposes including
a) Monitor in aggregate the effectiveness of our online and offline advertising and marketing campaigns;
b) Monitor in aggregate how visitors are using CST site;
c) Ensure that CST site and e-mails continue to provide relevant content that is interesting
and useful to our visitors;
d) Uncover and diagnose problems with CST site and servers; and
e) Day-to-day system administration needs.
C. WHY WE PROCESS YOUR INFORMATION
The lawful bases for our processing your personal information are:
a) Legitimate Interests: We have legitimate interests to process your personal data to enable us to provide you with our services and those legitimate interests are fairly balanced with your rights and freedoms;
b) Contract: our processing of your personal data is necessary to allow us to perform contracts for your benefit; and
c) Consent: where our processing of personal data is not because of our legitimate interest or by way of performance of our contract, we may do so with your consent.
D. WHO WE SHARE YOUR INFORMATION WITH
1) Overseas Offices
CST may share or transfer your information within the organization as may be required to its offices located in (i) Sydney, Australia; (ii) Los Angeles, US; and/or (iii) London, UK, subject to the local applicable data protection laws. The CST representative(s) providing the service(s) to you may share your information with the respective office(s) as may be deemed appropriate by the representative(s). Should you have any concerns, please inform the representative(s) directly.
2) Partners and Third-party Contractors
CST controls access to all information that CST has collected from you or about you. CST may share your information with our partners and third-party contractors in the course of providing our services. Our partners and third-party service contractors will be responsible for the information in their possession and that information will be subject to any privacy terms or policies that the partner or third party has in place.
CST is not responsible for the use (or misuse) of your information by any of our partners or third-party service providers.
When our services are available via the platforms of our partners, those partners may have access to your information. CST is not responsible for the content, security, privacy policies and practices of other platforms. We recommend that you check the policy of each platform you visit and make sure that you are comfortable with the terms of such policies before providing any personal information.
3) Services provided on our behalf by a Third-party
If CST offers or supplies a service to you that is provided on our behalf by a third-party service provider, we may have to pass your information to them in order to deliver the service. CST may also use third parties to provide services on our behalf which may include processing your information. In any case, CST will not pass your information to anyone who is not subject to adequate privacy commitments in our contract with them.
4) Prospective Acquiror or Parties Related to a Transaction
In the event of merger, acquisition, takeover, bankruptcy, liquidation, transfer of the business or assets, CST may disclose, share, transfer your information to the prospective acquiror and/or other relevant third-parties. We will make sure that any such transfer is done in a secure way.
You acknowledge that such transfers may occur, and that any acquiror of CST or any of its assets may continue to use your personally identifiable information as set forth in this policy.
E. HOW LONG WE RETAIN YOUR INFORMATION
CST will retain your information only for as long as necessary for the purposes set out in this policy, i.e., for as long as your account is active, or as needed to provide the services to you. In addition, we will also retain and use your information to the extent necessary to comply with our legal obligations, e.g., for record retention purpose required by local regulations and laws, to resolve disputes, enforce our agreements.
You may close your account if you no longer want us to use your information to provide the services to you. Please note that CST may continue to retain log files for internal record, analysis, and regulatory purposes even after you close your account.
F. HOW WE KEEP YOUR INFORMATION SAFE AND SECURE
CST has appropriate organizational safeguards and security measures in place to protect your information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed.
Your information is stored in secured third-party applications, e.g., requiring 2-factor authentication. Access to information is also controlled and restricted to our staff accessing through our client portal.
CST requires any third party who is contracted to process your information on our behalf to have security measures in place to protect your information and to treat such data in accordance with the applicable laws.
G. WHAT RIGHTS YOUR HAVE OVER YOUR DATA
You have several rights under applicable laws. This includes, under certain circumstances, the right to:
a) Request access to your information: You have the right to request access to your information which we have in our possession;
b) Request correction of your information: You can see, edit, or delete some of your own information in the App at any time. In some circumstances, you may request to correct or update your information we have in our possession;
c) Request erasure of your information: You have the right to request deletion of your information we have in our possession, subject to other record retention obligations we may have;
d) Request restriction of processing of your information: In some circumstances, you may request to restrict the processing of your information to certain limited usage;
e) Request the transfer of your information: in some circumstances, you may request that the information which you have provided to us is provided to you, so you can transfer it to another data controller;
f) Object to processing of your information: You have the right to object to the processing of your information which is processed on the grounds of legitimate interest;
g) Request human intervention for automated decision making: In the event of any automated decision making about you based on your information, you may request human intervention in the decision making. For the avoidance of doubt, CST does not use any automated decision making.
If you wish to exercise any of these rights, please click email@example.com.
H. ADDITIONAL INFORMATION
Cookies and similar technologies are used by CST to provide our services to you and in order to collect data from your device. These technologies allow us to:
a) Recognize you and your device;
b) Allow our services to interact with a third-party social network or platform (where you have chosen to allow such interaction); and
c) Allow us to understand how you interact with CST site.
2) Do Not Track
We currently do not participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your information.
3) Children and Minors
CST site is not intended for use by individuals under 18 years of age. Users under the age of 18 should get the permission of a parent or guardian to use the CST site. CST does not knowingly collect or maintain personal information from children or minors under the age of 18 at our site, except for the limited circumstances described below.
For residents of the EU, UK, and Switzerland, where processing of personal information is based on consent, we will not knowingly engage in that processing for users under the age of consent established by applicable laws, if we learn that we are engaged in that processing with such users, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records.
4) Changes to the Policy
CST may amend or update this policy from time to time. If we believe that the changes are material, we will let you know by doing one (or more) of the following:
a) Posting the changes on or through the services;
b) Sending you an email or message about the changes; and/or
c) Posting an update in the version notes on CST site.
We encourage you to check back regularly and review any updates.
5) Contact Information
If you have any questions, send an email to our Data Protection officer at firstname.lastname@example.org.