Client Privacy Notice

1. Information Collection and Use

1.1 Order form information

By filling in an order form, SFM will collect the following personal information from you:

• Contact Information, such as name, email address, mailing address, phone number.
• Billing Information, such as credit card number and billing address.
• Information about your business, such as company name, address, business type.

We may collect the personal information of third parties when you add the names of shareholders or beneficiaries on our order forms. Collection of third party personally identifiable information may be necessary to process and register your order for certain products or services. We will not use this information for any other commercial purpose. These third parties may contact us at gdpr@sfm.com to request that we remove this information from our database.

We will use this information to:

• Fulfill your order ;
• send you an order confirmation;
• assess the needs of your business to determine suitable products;
• send you requested a product or information;
• respond to customer service requests;
• send you communications;
• conduct due diligence; and
• respond to your questions and concerns.

In addition to the information collected through user-populated fields, the order form filled in on this website will record the information pertaining to your browsing session, your IP address and the time of the ordering

1.2 Service processing information collection

Once you became a client of SFM, we will collect such information as may be necessary, for the purpose of processing the order correctly and to comply with applicable legal requirements in terms of due diligence.

This includes the following information:

• additional information or clarification as necessary to complete, correct or, at your request, modify the service order;
• due diligence information as may be necessary to know our clients and to comply with the rules of the jurisdiction where SFM is required to perform its services. Such information may also be obtained from public sources.
• Instructions as you may from time to time provide for the proper performance of the services

1.3 Other information collection

Once you performed a payment to SFM, the payment information must be retained for 10 years for accounting or auditing obligations as per the Swiss Obligation code if you are a client of SFM Corporate Services SA, or 10 years as per the UAE law if you are a client of SFM Company Formation DMCC

2. Processing of data

2.1 Nature of the processing

SFM will process Client personal data intended to form part of a filing system. In addition to the collection, the processing includes the recording, organisation, structuring, storage, retrieval, consultation, use, disclosure by transmission, and suppression of such personal data. The data processed by SFM will include the particulars of the individual related to the service order, such as:
a) The full legal name(s),
b) the nationality,
c) the date of birth,
d) the domicile and residential addresses,
e) passport numbers and passport validity dates
f) contact details such as an email & a phone number

Those details, as well as the supporting documents evidencing them, are maintained in an electronic form in SFM’s secured databases, and in a paper form.

Such information is used to prepare corporate documents, identify our clients, and periodically perform compliance verifications, such as verifying that SFM is not servicing a party under international sanctions.

2.2 Data update and maintenance

We will retain your information for as long as your account is active or as needed to provide you services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. If SFM has provided services to you, personal data may be stored up to 10 years (but in any case, no less than 5 years) after the termination of the services, depending on the legal rules of the service jurisdiction. If you request that we delete your personal information, we will notify you if we are unable to do so and why

During the SFM service term, you must help SFM maintaining your personal information up to date. If your personal information change, you will have to correct, update, amend them. If you have a Corporate Service Officer assigned, please contact him/her in priority.

It is important to note that some of your particulars could be registrable particulars, and in case of changes, timely notice must be given in order to file an update of the modified registrable particulars within a legal deadline. Failure to do so may expose your company to incur heavy late filing penalties, and you may be fined.

2.3 Recipients of personal data

The recipients of your personal data may include:

• SFM affiliated companies acting as subcontractors or service auxiliaries,
• the registered agents in the jurisdictions relevant to the service(s),
• other third service providers, including banks, whom you have expressly requested to be introduced to,
• the public companies registry where a company must be registered to legally exist, and
• the legal authorities of a relevant jurisdiction, such as money laundering reporting authorities

SFM will not share personal data permitting the identification of a specific person with any third party for marketing purpose or any purposes other than i) the performance of the services you have requested, ii) the compliance with our legal obligations or duties, iii) the protection of our legitimate interests.
Where an affiliated company of SFM or a registered agent may act as the processor of personal data on behalf of SFM, we shall remain the controller of such personal data.

3. Personal data not obtained from a data subject

In the course of the service processing, SFM may not entertain contacts directly with every person whose personal data may be required.
If you are our point of contact, and other individuals are connected to your order, they are very likely to be data subject whose personal data must be processed as a result of this connection.
In that prospect, you must secure proper consent from any data subject whose personal data you supply to SFM, and you will be asked to confirm that their consent to the processing of their personal data was obtained in a regular way.

4. Changes to our Client privacy notice

We shall keep our privacy notice under regular review and updates may be placed on this page. This client privacy notice was last updated on 24/05/2018.

5. Contact Us

Data controller

SFM Corporate Services Ltd, Dubai branch
Office 604 & 605, OPAL Tower,
Burj Khalifa Street, Business Bay,
Dubai, UAE

+9714 246 9700

For general information:
info@sfm.com

For privacy matters:
gdpr@sfm.com