Furore Holding & Consult SRL (FHC) is committed to respecting and protecting all information entrusted to us in the course of our business. This includes individuals’ privacy as well as client confidentiality. This Policy describes FHC’s methods regarding the collection, use, disclosure, an d safeguarding of Confidential and Personal Information for business related purposes. This Policy applies to all FHC office locations and lines of business insofar as they are undertaking or supporting the delivery of services to clients. FHC collects Confidential or Personal Information for the purposes of delivering services to clients, managing the infrastructure to support those services and complying with legal and compliance obligations.

The volume and type of Confidential or Personal Information collected depends on what is required or relevant for delivering services to clients. FHC aims to collect only the minimum amount of Confidential and Personal Information for delivering services. Unless otherwise agreed, it is the responsibility of clients to ensure the lawfulness and fairness of any disclosure of Confidential and Personal Information to FHC (including ensuring the lawfulness and fairness of any processing of that Confidential and Personal Information by FHC). This includes obtaining any necessary consents from the Data Subject.

The obligation to provide any relevant notices (e.g. to a Data Subject) or information concerning FHC’s collection or use of Confidential or Personal Information rests on the client or third party. FHC also relies on clients and third parties to provide accurate, complete and consistent Confidential or Personal Information. FHC may also collect Personal Information from publicly available sources, including, but not limited to, public internet websites and databases, public or government sources and news or open source reporting.

FHC uses Confidential and Personal Information only for providing services to clients, managing the infrastructure to support those services and complying with legal and compliance obligations. FHC acts on the instructions of clients when using Confidential and Personal Information. These instructions can be given orally or in writing and their form and detail depends on both the services and the wishes of or requirements on the client. Unless otherwise agreed, FHC may use certain Confidential and Personal Information for statistical benchmarking, industry intelligence and research purposes. Before doing so, FHC will take reasonable measures to anonymize or aggregate the information.

Although not a common feature for delivering services, FHC complies with any requirements or restrictions from clients on the use of Personal Information to profile or make automated decisions on individuals. Where FHC provides the client with the facility to access and delete Confidential and Personal Information processed on the client’s behalf, the client is responsible for deleting the Confidential and Personal Information when no longer required. In other cases, FHC will delete Confidential and Personal Information at the end of any retention period agreed with the client, or in accordance with the client’s instructions. FHC may retain copies of Confidential and Personal Information to comply with legal requirements or for compliance or record-keeping purposes, in which case FHC will retain such Confidential and Personal Information for as long as required by those legal requirements or to fulfill those purposes.

In relation to Confidential and Personal Information held in backups or archives, FHC operates a programmed destruction cycle and selective deletion is not feasible. FHC continues to safeguard the information throughout and in accordance with this Policy. Confidential and Personal Information is shared within FHC with those individuals and departments who need to know. Disclosure depends on the nature of the information and the services being delivered.

FHC only discloses Confidential or Personal Information to outside organizations in the course of or for the purposes of delivering services to clients. FHC may also disclose to third parties where required to by law or for compliance purposes. Such recipients may include other FHC group entities and/or affiliates, FHCs insurers and professional advisers, other advisers, or other third parties as instructed by clients, or organizations that provide FHC with various outsourced business functions and technology.

When FHC discloses Confidential or Personal Information to a third party, the third party is authorized to use and further disclose the related Confidential or Personal Information only as necessary to provide their services to FHC or as required by law. FHC shall take appropriate actions to ensure that a third party protects Confidential and Personal Information that FHC discloses to it. This includes the use of appropriate contracts (NDAs) and information security measures.

If permitted by law and regulation, FHC shall inform the relevant client or third party where it proposes to disclose Confidential or Personal Information as required by law or to respond to a government request. FHC and its clients and business partners operate across many countries and the subject matter of services provided to a client may be located in one or more jurisdictions.

In order to deliver the services, FHC may receive or transfer Confidential and Personal Information within a country or across borders. Where FHC needs to transfer Personal Information internationally, it does so in accordance with any agreement from and as permitted by the client or in compliance with applicable privacy laws. In the event that a person other than a client wishes to exercise any rights (such as of access or correction) under applicable privacy laws as regards Personal Information, FHC will promptly notify the client so that the client can respond.

If FHC receives a complaint about the collection, use or sharing of Personal Information or a request from a regulatory authority responsible for compliance with privacy laws, FHC will, to the extent permitted by law, promptly notify the client so that the client can respond. FHC collects, uses, maintains, shares (internally and externally) and destroys Personal Information in a manner that appropriately limits the risk of loss, theft, misuse, or unauthorized access. All FHC personnel are contractually required to safeguard Confidential and Personal Information. In addition, certain personnel may be subject to additional professional obligations on compliance with laws and confidentiality.

Where there has been a serious loss, misuse or other breach to the integrity and confidentiality of Personal Information likely to cause serious harm, FHC shall comply with the requirement to notify the client either as agreed with the client or under applicable laws. FHC raises awareness of the matters in this Policy and puts measures in place to ensure the reliability of personnel who access Confidential and Personal Information.