PRIVACY POLICY / PERSONAL DATA

The Website publishes information relating to AML MONACO ADVISORY and also makes it possible to contact the Firm.

AML MONACO ADVISORY respects the personal data and privacy of users of the Website. Indeed, the Firm attaches great importance to the protection of personal data entrusted to it, through its Website.

Access to the Website “ www.amlmonaco-advisory.mc” and/or using of the Website implies automatic and unconditional acceptance of the conditions of use of the Website by the internet user  (individual / legal person / legal entity) hereinafter individually referred to as the “User” or collectively the “Users” as well as the protection of personal data and privacy policy of AML MONACO ADVISORY.

The purpose of such a policy is to inform the Internet users of the Website in all fairness and transparency, about the methods of collecting and processing their personal data, the use of cookies on the Website, as well as their rights relating thereto.

The Data processing manager: identity and contact information
The Data processing manager: Mrs. Arève MARDIROSSIAN-LECROQ
Park Palace D – 25/27 avenue de la Costa 98000 Monaco
Email: contact@amlmonaco-advisory.mc

Collection of personal data
The personal data is voluntarily and freely transmitted by Website Users during their connection and navigation, via the use of an electronic mailbox in “Contact Us” section, which is collected and processed by AML MONACO ADVISORY in the context of the management of its Website.

Data minimization
In accordance with article 10-1 of the Monegasque Law and article 5 of the GDPR, AML MONACO ADVISORY applies the principle of data minimization. This means that the Firm takes care to collect only adequate, relevant and necessary information with regard to the purpose for which it is collected and for which it is processed.

Data related to navigation on the Site

• “Contact us” form

The personal information collected via the “Contact Us” form on the Website can be used to identify the Internet user or enter into a business relationship, and the User agrees by providing his personal information to be contacted by the Firm.

• Email

The Website User who will use electronic mailboxes in the “Contact Us” form, at email addresses, is free to communicate any personal information to the Firm and accepts that this data will be collected and processed by the latter in accordance with this Online Data Privacy Policy. The use of such data for other purposes can only take place if the User gives his consent, or if required by law or professional standards.

• Hypertext links to other websites

The Website may offer hypertext links to websites edited and / or managed by third parties.

AML MONACO ADVISORY has no control over such external resources, is not responsible for their availability or their content, which the User expressly acknowledges and accepts.

• Cookies

Cookies are text files generated by the server of the Website consulted by the User, and deposited / saved on the computer (hard drive) or the connected device thereof, in most cases temporarily, by his internet browser.

The content of a cookie generally consists of the server name, an expiration date and a unique encrypted code. Cookies are used, in particular to recognize the internet browser, identify internet sessions and make statistical analyzes; they do not store the email address or the name of the User.

The Website displays an informative banner indicating the collection of cookies - the consent of the User is required - the browser settings are possible in the event of the User’s decision to block all cookies. In this case, it will not be possible for AML MONACO ADVISORY to follow the User’s computer or connected device for the purposes of marketing activity.

The internet user can restrict the use of cookies for their browser or on a mobile device, by going to the official web page of the browser or the manufacturer of the device or by consulting the documentation provided, then following the instructions that are given to him.

The Website uses third-party cookies such as:

• The visit statistics cookies which allow to analyze the traffic of the Website and to measure its audience (Google Analytics); the User’s IP address is transmitted to Google, which uses it to prepare usage reports for the Firm, but Google may also share this information with other Google services.
• Social media cookies which allow to share the content of the Website on these media (LinkedIn)

The companies Google Inc. and LinkedIn Corporation, members of the EU-US Privacy Shield, are currently recognized by the European Union as ensuring an adequate level of personal Data protection:(see https://www.privacyshield.gov/welcome).
For more information please visit: The Google Analytics service: https://support.google.com/analytics/answer/6004245

Purpose and legal basis for processing personal data

On the basis of the explicit consent of the User as well as on the basis of the legitimate interest of the Firm in view of the User’s expectations, AML MONACO ADVISORY processes the data collected and provided by the Users when they connect to the Website and when they browse.

Email addresses and, as the case may be, any other information communicated by the User, with his consent, are processed for the following purposes:

• Manage his request when he contacts the Firm via a “Contact Us” electronic mailbox on the Website;
• Ensure the proper functioning of the Website and the security of User data.

The storage of such personal data is exclusively limited to the Firm.

Data recipient

The collection, processing and / or use of the User’s personal data is exclusively reserved for the Firm (members of its dedicated staff): they allow the User to be contacted by email or by phone depending on the request which is sent to him by the contact form, for commercial management purpose (contracts, invoices, calls, emails as part of the services the User); they may be reserved for third parties to the Firm, authorized and defined on the basis of the consent of the User and the legitimate interest of the Firm.

Data transfer outside Monaco

Data may be transferred to third countries outside Monaco on the basis of the User’s consent to the processing. The data collected through third party cookies is stored by the American companies Google Inc. or LinkedIn Corporation.

Protection of personal data

AML MONACO ADVISORY has declared the Website to the Personal Information Commission (“CCIN”) relating to automated processing with the aim of “Website management”.

The protection of personal data in the Principality of Monaco is governed by Law No. 1.165 of December 23, 1993, consolidated by Law No. 1.454 dated on October 30, 2017, hereinafter “Law No. 1.165”. However, the Principality, notwithstanding the fact that it is a third country, is also impacted by the new European framework relating to the processing and circulation of personal data - the General Data Protection Regulation 2016/679 applicable since May 25, 2018 (“GDPR”) - especially when goods or services are offered to people residing in the European Union (the “EU”).

The Firm thus respects the aforementioned national legislation, as does the European GDPR regulation.

Personal information is not transferred to third parties and is not used without the knowledge of the User.
The User is required to comply with the provisions of the Monaco Law. He must in particular refrain from any collection, any misuse and, in general, any act likely to infringe the privacy or reputation of people, image and copyright.

Data retention period
Personal data is kept for the duration necessary for the operations for which the User has consented it to being processed, and this, in compliance with the regulations in force.

User rights and conditions of exercise

In accordance with the regulations in force on the protection of personal data, the User has the right:

•   Of access and rectification: request of the User, his personal data will be communicated to him free of charge, the Cabinet reserving the right to request proof of identity beforehand. If the information held by the Firm is inaccurate, the User has the right to request its rectification. The User has also the right to data portability, which means that he can recover part of his data in an open format that can be read by “machine” / connected device;
•   Of opposition to the processing: the User has the right to oppose, for legitimate reasons, the processing of his personal data, and if necessary a right to portability;
•   Other rights: the deletion of personal data, the limitation of their processing in certain circumstances and / or the obtaining of a copy of the personal data held by the Firm in an electronic format. However, the withdrawal of consent or limitation does not affect the lawfulness of the processing that took place before this withdrawal or limitation.

The User can exercise their rights by email sent to “contact@amlmonaco-advisory.mc” or by letter, sent to the Firm post or on site at their head office to the Manager.

Right of claim

The User can also file a complaint with the competent Data Protection Authority, either as the case may be:

• The CCIN (Commission for the Control of Personal Information), in accordance with Law No. 1.165 dated on December 23, 1993, consolidated, and if applicable,
• The relevant authority responsible for the protection of personal data in accordance with Regulation (EU) 2016/679 dated on April 27, 2016 (GDPR).

Without prejudice to the aforementioned administrative appeal, the User also has the right to appeal to the courts.

Please read our “Legal Notices” available on our Website.