(Latest update 09 February 2022)
This Client Privacy Policy governs the collection, disclosure and use of personal data relating to potential and existing clients and users (hereafter referred to as “you”) of CTP goods and services. This Privacy Policy describes:
We are required to preserve your privacy and will only process the personal data that you supply to us in accordance with the applicable data protection legislation.
Please read this policy carefully, as it sets out the personal data concerning you that we collect and the way in which it is processed.
By continuing to use our products and services (including our websites and all our other applications), you confirm that you have read, understood and accept this Client Privacy Policy in its entirety. If you do not accept this Client Privacy Policy in its entirety, you must not use our products and services. Please return to this page regularly to read the latest updates to this Client Privacy Policy, because we reserve the right to amend or update it at any time.
If you have any questions about how we collect, store and use your personal data, please contact us:
The personal data that we collect
We may be required to collect the following types of personal data concerning you:
If you use our websites, we may also be required to collect information about you or your computer while you browse in order to enable you to use the available services, and we we may collect anonymous information about you or your computer for analytics purposes with a view to continually improving our products and services, as explained in the legal notices on our website and in our notice about cookies.
How do we use your personal data?
The personal data concerning you that we collect is used to:
We also process your personal data when we are required to do so by law, and for the exercise or defence of legal claims.
We may contact you at any time for research purposes or to inform you of our special offers and other services, in accordance with your contact preferences. If necessary, we will have to obtain your consent to do so. If you no longer wish to receive communications from us, please follow the instructions to “opt out” or “unsubscribe” included in all our communications of this type.
If we are considering using your personal data for any other purpose, we will inform you of how we intend to use it once it has been collected.
We will only process your personal data for the specific purposes listed above or for any other purposes specifically authorised by law. Your personal data will only be processed within the limits of the specific purposes described above.
Our legal base for processing your personal data
We will only process your personal data if you have given your consent (which you may subsequently withdraw if consent is required by law), in order to sign an agreement with you, if the said processing is required for our legitimate interests or the legitimate interests of another party (such as for the purposes of market surveys), or to promote our goods and services if you are already a client or user of these.
How long is your personal data kept for?
We will only keep personal data if it is required for a specific purpose. We are required by law to keep certain files for a specified minimum period, such as personal data relating to the purchase of a product or service from the CTP. We will keep your personal data for as long as necessary to provide the services, products and information you request, or in accordance with the applicable law and our data retention policy, which we apply under the GDPR. We will also keep and use this personal data if necessary to meet our legal obligations, settle claims, and assert our commitments. Information that is no longer necessary for a valid commercial purpose and that we are not required to keep under an applicable law will be systematically destroyed via secure means.
Who do we share your personal data with?
We do not share personal data.
We will ensure that any transfer of your personal data by us is secure and/or encrypted in order to keep the data safe.
How do we protect your information?
We use reasonable and adequate administrative, technical and organisational measures to protect personal data against loss and theft, against any unauthorised use, access or disclosure, and against modification or destruction. Some parts of our websites may be password‐protected. If you use our websites and have a password, you can help to protect your privacy by ensuring that you do not share your password with anyone.
Your options in respect of how we use your information
You have the following rights in accordance with governing data protection laws:
These rights may not apply in certain cases, especially when we are obliged to comply with legal requirements, when this would breach the rights of any person other than the person requesting access, or (in the case of your right to request to your personal data) when the request is manifestly unfounded or excessive.
If you wish to exercise you right to access, correct, amend or delete your personal data, please contact us at one of the addresses provided in the “Contact us” section below. We may be required to ask you for specific information in order to confirm your identity.
We respond to all requests that we receive from natural persons wishing to exercise their data protection rights, in accordance with the applicable data protection laws.
Updates to this Privacy Policy
We may be required to update this Privacy Policy at any time in response to changes in legislation or technical or commercial developments. When we update our Privacy Policy we take appropriate steps to inform you, in a manner consistent with the extent of the changes we make. We will request your consent for any significant changes to the Privacy Policy if and when this is required by applicable data protection laws.
You can view the date on which this Privacy Policy was updated by checking the “latest update” date shown at the top of this policy.
Contact us
If you have any questions or issues relating to our use of your personal data, please contact us at one of the following addresses: