SaBa Privacy Statement

---

SaBa is the trade name of SaBa Yonetim Danismanlik Ltd. Sti. References in this statement to “we”, “us” or “SaBa” are references to SaBa Yonetim Danismanlik Ltd. Sti and our business allies established in the Netherlands and the United Kingdom. Our business allies in the Netherlands and United Kingdom will be communicated to our clients and their consent shall be obtained before sharing any private customer data.

SaBa is strongly committed to protecting private data. This privacy statement describes why and how we collect and use private data and provides information about individuals’ rights. It applies to private data provided to us, both by individuals themselves or by others. We may use private data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.

Private data is any information relating to an identified or identifiable living person or an entity. When “you” or “your” are used in this statement, we are referring to the relevant individual or entity who is the subject of the private data. SaBa processes private data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.

When collecting and using private data, our policy is to be transparent about why and how we process private data.  

We take the security of all the data we hold very seriously. We adhere to internationally recognised security standards. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

We will only share private data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place as appropriate to protect the data and to comply with our data protection, confidentiality and security standards.

We have business alliance agreements with other professional service providers, we use third parties located in other countries to help us run our business. As a result, private data may be transferred outside the countries where we and our clients are located. This includes countries outside the European Union and the countries that do not have laws that provide specific protection for private data. 

We have taken steps to ensure all private data is provided with adequate protection and that all transfers of private data are done lawfully.

On certain client engagements, we may engage or otherwise work with other providers to help us provide professional services to our clients. We use other professional advisers, for example, law firms, tax advisory firms and trust organizations as necessary to establish, exercise or defend our client’s legal rights and obtain advice in connection with the running of their international business. Private data may be shared with these advisers as necessary in connection with the services they have been engaged to provide upon our client’s consent. 

Where we need to process private data to provide professional services to our clients, we may share private data in our deliverables (such as the reports we create). 

We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.

This privacy statement was last updated on 11 June 2021. 

We are generally controllers for the private data we process. If you have any questions about this privacy statement or how and why we process private data, please contact us at

info@sabafs.com 

Individuals and entities have certain rights over their private data and controllers are responsible for fulfilling these rights. 

Individuals’ or entities’ rights may include the right of access to private data, to rectification of private data, to erasure of private data / right to be forgotten, to restrict processing of private data, to object to processing of private data, to data portability, the right to withdraw consent at any time (where processing is based on consent) and the right to lodge a complaint with a supervisory authority. 

You have the right to obtain confirmation as to whether we process private data about you, receive a copy of your private data held by us as a controller and obtain certain other information about how and why we process your private data (similar to the information provided in this privacy statement). This right may be exercised by emailing us at info@sabafs.com. 

We aim to respond to any requests for information promptly, and in any event within the legally required time limits. 

You have the right to request for your private data to be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete private data completed.

To update private data submitted to us, you may email us at info@sabafs.com or, where appropriate, contact us via our corporate telephone numbers.

When practically possible, once we are informed that any private data processed by us is no longer accurate, we will make updates as appropriate based on your updated information. 

You have the right to obtain deletion of your private data in the following cases:

· the private data are no longer necessary in relation to the purposes for which they were collected and processed;

· our legal grounds for processing is consent, you withdraw consent and we have no other lawful basis for the processing;

· our legal grounds for processing is that the processing is necessary for legitimate interests pursued by us or a third party, you object to our processing and we do not have overriding legitimate grounds;

· you object to our processing for direct marketing purposes;

· your private data have been unlawfully processed; or

· your private data must be erased to comply with a legal obligation to which we are subject.

To request deletion of your private data, please email us at info@sabafs.com. 

You have the right to restrict our processing of your private data in the following cases:

· for a period enabling us to verify the accuracy of your private data where you have contested the accuracy of the private data;

· your private data have been unlawfully processed and you request restriction of processing instead of deletion;

· your private data are no longer necessary in relation to the purposes for which they were collected and processed but the private data are required by you to establish, exercise or defend legal claims; or

· for a period enabling us to verify whether the legitimate grounds relied on by us override your interests where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us.

To restrict our processing of your private data, please email us at info@sabafs.com. 

You have the right to object to our processing of your private data in the following cases:

· our legal grounds for processing is that the processing is necessary for a legitimate interest pursued by us or a third party; or

· our processing is for direct marketing purposes.

To object to our processing of your private data, please email us at info@sabafs.com. 

You have a right to receive your private data provided by you to us and have the right to send the data to another organisation (or ask us to do so if technically feasible) where our lawful basis for processing the private data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.

To exercise your right to data portability, please email us at info@sabafs.com. 

Where we process private data based on consent, individuals or entities have a right to withdraw consent at any time. Where we rely on your consent for our processing of your private data, to withdraw your consent please email us at info@sabafs.com or, to stop receiving an email from a SaBa marketing list, please click on the unsubscribe link in the relevant email. 

Please see the relevant “Use of private data” sections of this privacy statement for further details about our processing of private data based on consent. 

We hope that you won’t ever need to, but if you do want to complain about our use of private data, please send an email with the details of your complaint to info@sabafs.com. We will look into and respond to any complaints we receive.

You also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred.