Jul 01, 2023

Privacy & Cookies

Purpose of this Policy

Aston CM (Guernsey) Limited (collectively “we”, “us” or “our”) are committed to protecting and respecting your privacy. This policy (and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Personal data means information about you from which we can identify you (either on its own, or by piecing it together with other information) (“Personal Data”).

This policy applies to our website astoncm.com (which includes any microsites or subsections of this website which are hosted within our web environment) and to any services, including our online platform, which we make available to you through our website (our website, and services together are referred to in this policy as the “Website”). It also applies to our email communications and links within these communications (together referred to in this policy as “Emails”.

It is important that you read this privacy policy together with any other privacy policy 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 notice supplements the other notices and is not intended to override them

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 01 July 2023.

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.

Data Controller

For the purpose of the General Data Protection Regulation ((EU) 2016/279)(“GDPR”) and all other related data protection legislation, the data controller is Aston CM (Guernsey) Limited, Suite 1, First Floor, Windsor House, Lower Pollet, St Peter Port, Guernsey, GY1 1WF.

You have the right to make a complaint at any time to The Office of the Data Protection Authority (ODPA), the Guernsey supervisory authority for data protection issues (https://www.odpa.gg/). We would however, appreciate the chance to deal with your concerns before you approach the ODPA so please contact us in the first instance.

Information we may collect from you
On our Website and via Email we may collect and process the following data about you:
• Information that you provide by filling in forms on our Website. This may include information provided at the time of registering to use our Website, subscribing to our service, posting material or requesting further services;
• Information that we ask you to provide to us when you report a problem with our Website;
• Information that you provide if we ask you to complete surveys that we use for research purposes, although you do not have to complete these surveys if you do not want to;
• Transaction data, including details of transactions you carry out through our Website and details of the fulfilment of your currency requirements;
• Financial data, including bank account and payment card details;
• Technical data, including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access;
• Usage data, including information about how you use a website, products and services;
• Identity data, including name, job title and company. In addition, we may also keep copies of official identify documents such as passports and/or driving licences;
• Contact data, including email address (billing address, telephone numbers?);
• Marketing data, including marketing preferences indicated by you when registering to use our Website; and
• Demographic data, such as postcode, preferences and interests.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

What we do with the information we gather;

In all circumstances the Personal Data we hold about you will be adequate, relevant and not excessive. Details of your legal rights in relation to your Personal Data can be found on the Information Commissioner’s website https://www.odpa.gg/.

We will only process your Personal Data, in accordance with applicable law, for the following purposes:

Purpose/Activity Type of Data Lawful basis for processing including basis of legitimate interest
To provide services pursuant to our contract with you, including in order to process transactions and prevent fraudulent transactions.

1. Identity
2. Contact
3. Transaction
4. Financial

Performance of a contact with you.

To manage our relationship with you, including notifying you about changes to our terms, privacy policy or service, or asking you to take part in surveys.

1. Identity
2. Contact
3. Marketing Performance of a contract with you.

Necessary to comply with a legal obligation.

Necessary for our legitimate interests (to keep our records updated and understand how customers use our products/services).
To administer and protect our business and this website, including internal record keeping.

1. Identity
2. Contact
3. Transaction
4. Technical
5. Usage Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud).

Necessary to comply with a legal obligation;
To improve our website, products/services, marketing, customer relationships and experiences

2.Usage Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

To contact you for marketing purposes, including making suggestions to you about goods or services that may be of interest to you and providing details of new products, special offers or other information which we think you may find interesting

1. Identity
2. Contact
3. Technical
4. Demographic
5. Marketing Necessary for our legitimate interests (to develop our products/services and grow our business)

Understanding how and when you are interacting with our Website, Emails and digital marketing collateral.

1. Technical
2. Usage

Necessary for our legitimate interests (to understand how customers use our products/services, to develop them, grow our business and inform our marketing strategy).

To search Fraud Prevention Agencies’ records (including information from overseas) and carry out fraud and credit checks (we may pass your details to a third party to carry out these functions).

1. Identity
2. Contact
3. Financial Necessary to comply with a legal obligation.

Necessary for our legitimate interest (to comply with legal and regulatory requirements relating to fraud prevention and anti-money laundering)

We may use your Personal Data, or permit selected third parties to use your Personal Data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by post, telephone or electronic means (e-mail or SMS).

If you are an existing customer, we will only contact you by telephone or electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to you.

If you do not want us to use your Personal Data in this way, or to pass your details on to third parties for marketing purposes, please indicate it on the form on which we collect your Personal Data (the contact registration form). If you wish to change your preferences at any time, please contact us using the contact details set out below.

How is your personal data collected?

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

· Direct interactions, including information provided by filling in forms on our website or corresponding with us by any means.

· Automated technologies or interactions, through which we may automatically collect technical data about your equipment, browsing actions and patters. We collect this data using cookies (see below) and other similar technologies.

IP addresses and cookies

What exactly are cookies?

In order to collect the information as described in this privacy policy, we may use cookies and similar technology on our Website and Emails.

A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive, mobile phone or other device.

You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. However, some of the services and features offered through websites may not function properly if your cookies are disabled.

Cookies can be first-party or third-party cookies:

First party cookies – cookies that the website you are visiting or link you are clicking places on your computer.

Third party cookies – cookies placed on your computer through the website but by third parties, such as, Google.

The cookies placed on our Website
We use the following cookies on our Website:
Strictly necessary cookies – These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have asked for cannot be provided. They are deleted when you close the browser. These are first party cookies.

Performance cookies – These cookies collect information in an anonymous form about how visitors use our Website. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it and the approximate regions that they are visiting from. These are first party cookies.

Functionality cookies – These cookies allow the Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. These are first party cookies.

Targeting or advertising cookies – These cookies allow us and our advertisers to deliver information that is more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of advertising campaigns. They remember that you have visited our Website and may help us in compiling your profile. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.

Social Media cookies – These cookies allow you to connect with social media networks such as LinkedIn and YouTube. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.

IP Tracking cookies – Our company uses third parties to provide information about visitors to our websites. When you visit our websites we will record your IP address. This address will be matched against public and proprietary IP address databases to provide us with information about your visit. This information may identify the organisation to whom the IP address is registered but not individuals. In some limited cases i.e. single person companies, it may be possible to identify personal data from publicly available ICANN data.

Post-Click Tracking Cookies – These cookies are used to report on the pages of astoncm.com that have been viewed by visitors to the site who have followed links placed within email correspondence. This analysis helps us to analyse engagement with content that is viewed by the contacts in our database and therefore allows us to improve it in the future. Since these cookies are paired to individual email addresses, it will be possible for us to identify the activities of the individual who the email address is registered to.

Document Tracking Cookies – Some documents we send clients uses cookies to track engagement with our documents. These cookies are also paired to individual email addresses and therefore make it possible for us to identify the activities of the individual who the email address is registered to.

We may combine information from these types of cookies and technologies with information about you from any other source.

Cookie consent and opting out

We assume that you are happy for us to place cookies on your device. However, you may refuse to accept most cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our Website.

In order to opt out of IP Tracking cookies, Post-Click Tracking Cookies or Document Tracking Cookies you will need to email contact@astoncm.com.

Data security and international transfers

The internet is global, so your Personal Data may be transferred in transit outside of the European Economic Area (“EEA”). However, we have taken the steps outlined below to try and protect the security of your Personal Data and comply with our legal obligations in relation to the transfer of your Personal Data to non-EEA countries.

We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this privacy policy. We have policies, rules and technical measures in place to protect the Personal Data that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of any data transmitted to our Website; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorised access.

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.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Disclosure of your Personal Data

There are circumstances where we wish to disclose or are compelled to disclose your Personal Data to third parties. This will only take place in accordance with applicable law and for the purposes listed above. These scenarios include disclosure:

To our professional advisors;

In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets (including by disclosing your Personal Data to potential investors as part of a pre-marketing roadshow);

If we or substantially all of our assets are acquired by a third party, in which case Personal Data held by us about our customers will be one of the transferred assets;

If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or to protect the rights, property, or safety of Aston CM (Guernsey) Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction;

To our outsourced service providers or suppliers to facilitate the provision of our services, for example, the disclosure to our data centre provider for the safe keeping of your Personal Data, or to our webhosting provider through which your Personal Data may be collected;

To third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;

To public authorities where we are required by law to do so; and

To any other third party where you have provided your consent.

Retention of Personal Data

Your Personal Data will be retained for as long is reasonably necessary for the purposes listed above or as required by applicable local law. Please contact us for further details of applicable retention periods.

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.

We may keep an anonymised form of your Personal Data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

Your rights
You have the right 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
You also have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your Personal Data) if we intend to use your Personal Data for such purposes or if we intend to disclose your Personal Data to any third party for such purposes. You can exercise your right to prevent such processing by contacting us at contact@astoncm.com.

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.

Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page. It is your responsibility to check this page for any changes. Such changes will be binding from the date that they are posted.

Intellectual property rights

All intellectual property rights in our Website, any advertising material issued by or on behalf of Aston CM (Guernsey) Limited, all information, materials, prices or charts, business methods, databases or settlement specifications relevant to the provision of our Website or otherwise used or arising in connection with our Website will remain our property and you will have no rights to distribute, republish, copy, reproduce, sell, sub-license or otherwise transfer or disseminate any of the foregoing unless otherwise agreed by us in writing.

Telephone conversations
We digitally record all telephone conversations with our clients.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed, by email, to contact@astoncm.com or, by post, to Aston CM (Guernsey) Limited, Suite 1, First Floor, Windsor House, Lower Pollet, St Peter Port, Guernsey, GY1 1WF.

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

“Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:

(I)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.”