This Policy describes how Questro International (henceforth “Questro”, “Firm”, “We”, “Us”, or “Our”) collects, uses and shares personal information that you provide to us and the personal information we collect in the course of operating our business and our website.
In this Policy, when we refer to Questro we mean Questro International Holding BV and our international offices and other companies or entities that are associated with us and operate their businesses under the Questro brand.
This policy is effective as from 25th May 2018, however, we may revise this Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.
Personal information or data is any information that can be used to identify you or that we can link to you and which we have in our possession or control.
Legitimate Interest means the interest of our business in conducting and managing our affairs to enable us to provide transfer pricing services. Legitimate business purposes may include some or all of the following:
- Where the processing of information enables us to enhance, modify, personalise or otherwise improve our services or communications for the benefit of our clients;
- To identify and prevent fraud;
- To maintain a list of individuals and email addresses that have opted out and do not wish to receive marketing communications from us;
- To better understand how people interact with our website;
- To provide communications that we think will be of interest to you;
- To determine the effectiveness of promotional campaigns and advertising.
Whenever we process data for the purposes of our legitimate business purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights and balance our legitimate business rights against your personal data rights.
2. SOURCES OF DATA
We may collect and process personal information from the following sources:
a) Information that you provide
We will process personal information that you provide to us, including when you email us or contact us through various channels as follows:
- Signing up via our website: when you sign up for newsletters, webinars, events or respond to our direct communications, the personal information you provide may include your full name, title, employer and employment position, telephone number, email address and content, date and time of your email correspondence and other information about your employer or your business.
- Provision of transfer pricing services to clients: if you are a client of Questro you will provide us with personal information when you or the company you represent becomes a client. If you are not a client we may collect or receive your personal information because you are involved in one of our client’s matters. This may include identity data necessary for our client take on processes, contact data, financial data etc.
- Recruitment: when you apply for a position with us you may provide us with your full name, date of birth, nationality, education and qualification details, your gender, your CV, photograph, passport details, marital status, home address and home telephone number, mobile telephone number and other details set out in your application.
b) Information that we collect
We may also collect information about when you use our services or when we otherwise interact or correspond with you. We use various technologies to collect and store information when you visit our websites. We may, for example, collect information about the type of device you use to access the websites, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our websites, the web pages and the search terms you enter on our websites.
c) Information we obtain from 3rd parties
- If you apply for a position with us we may collect personal information relating to past employment, qualifications and education, opinions from third parties about you, past employment history and other details about you, which will be provided to us by a third party that provides background screening services to us.
- We might also receive information from third parties such as your employer, other parties relevant to the services we are providing (e.g. counterparties in transactions) and others such as regulators and authorities. That information could include your name, contact details, employment details and other information relevant to the transfer pricing services that we are providing to our client.
3. HOW WE USE THIS INFORMATION
We may do the following with your personal information:
- Use it to provide transfer pricing services to the relevant client;
- Use it to engage in marketing and business development activity in relation to our transfer pricing services. This may include sending you newsletters, transfer pricing updates, marketing communications and other information that may be of interest to you;
- Where you have applied for a position with us, to review and process your job application;
- To comply with transfer pricing and regulatory obligations that we have to discharge;
- Use it to establish, exercise or defend our transfer pricing opinion under challenge or legal proceedings;
- Record and monitor your use of our websites or our other online services for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports;
- Use it for our legitimate business interests, such as undertaking business research and analysis, managing the operation of our websites and our business;
- Use it to look into any complaints or queries you may have; and
- Use it to prevent and respond to actual or potential fraud or illegal activities.
Also, we may collate, process and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.
4. GROUND FOR USE
We rely on the following grounds to process your personal information, namely:
- Consent - we may need your consent to use your personal information. You can withdraw your consent by contacting us (see below).
- Performance of a contract - we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you.
- Legitimate interest - we may use your personal information for our legitimate interests, some examples of which are given above.
- Compliance with law or regulation - we may use your personal information as necessary to comply with applicable laws, regulations and other rules.
- How long we hold your personal information for will vary and will depend on:
- The purpose for which we are using your personal information. We will need to keep the information for as long as is necessary for the relevant purpose; and
- Legal obligations. Laws or regulations may set a minimum period for which we have to keep your personal information.
We will ensure that the personal information that we hold is subject to appropriate security measures and access restrictions.
5. SHARING DATA
We may share personal information with our international offices and the various companies and entities that make up our Questro network. As a result, your personal information may be transferred to locations outside Europe as well as within it for the purposes described above.
We may also share your personal information outside the Firm. This may include:
- Third-party agents, suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers.
- Third parties relevant to the transfer pricing services that we provide.
- To the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal information in order to comply with any legal obligation.
Where we transfer your personal information outside Europe, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. In all cases, any transfer of your personal information will be compliant with applicable data protection laws.
6. YOUR RIGHTS
You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below.
These rights include:
- Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you. Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information.
- Requesting that we correct your personal information if it is inaccurate or incomplete.
- Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it.
- Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
- In some circumstances, receiving some personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit that information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.
- Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
- Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us.
If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us. You can do this by writing to us at: