Privacy Notice

1. Who we are

Geren Corporate is the professional online presence and professional practice of Ali Geren.

For the purposes of applicable data-protection legislation, Ali Geren is the data controller in respect of personal data processed through this website and in connection with enquiries made through it.

2. Scope of this Privacy Notice

This Privacy Notice explains how personal data is collected and used when you visit the Geren Corporate website; contact us through the website, email, telephone or another communication channel; request information about services; arrange a consultation; or otherwise make an initial professional enquiry.

Where a professional engagement is subsequently established, additional personal data may be processed for contractual, regulatory, due-diligence, compliance or other professional purposes. Additional notices or engagement documentation may apply where appropriate.

Newsletter subscriptions. This Privacy Notice also applies when you choose to subscribe to Geren Corporate’s email publications. A subscription is activated only after the email address is confirmed through the confirmation message sent to that address.

3. Personal data we may collect

When you contact us, we may collect information including your name, email address, telephone number, company or organisation, service of interest, the contents of your enquiry and subsequent correspondence.

Where you subscribe to email publications, we process the email address you provide together with limited subscription records such as the date and source of the subscription request, confirmation status and time, unsubscribe status, and delivery records needed to administer the subscription and avoid duplicate delivery.

The website or its hosting infrastructure may also process limited technical information needed to deliver, secure and operate the website, including IP address, browser and device information, browser language, requested pages, referring or source page information, date and time of access, request or trace identifiers and related technical logs.

If an enquiry progresses into a regulated or professional engagement, additional identification, corporate, due-diligence and regulatory information may be required.

Please do not provide sensitive or special-category personal data through the general website contact form unless specifically requested.

4. Information you provide and your responsibilities

You are responsible for taking reasonable care to ensure that personal information you provide to us is accurate, complete and, where appropriate, kept up to date.

Where you provide personal data relating to another person, you should ensure that you are lawfully entitled to provide that information and, where required, that the relevant individual has been appropriately informed.

You should not submit special-category, highly sensitive, confidential or unnecessary personal information through the general website contact form unless we specifically request it or it is reasonably necessary for your enquiry.

You are responsible for using appropriate care when communicating personal or confidential information over the internet and for ensuring that the contact details and communication channels you provide are suitable for correspondence relating to your enquiry.

Nothing in this section limits our obligations under applicable data-protection law, including obligations concerning accuracy, security, transparency and data-subject rights.

5. Why we process your personal data

Personal data may be processed to respond to enquiries and consultation requests; take steps requested by you before entering into a professional engagement; provide agreed services; communicate with clients and prospective clients; maintain appropriate business, security and administrative records; comply with legal and regulatory obligations; establish, exercise or defend legal claims; and protect the security and integrity of the website and professional practice.

Where you specifically subscribe to Geren Corporate publications, your email address and subscription records are processed to confirm and administer the subscription, deliver the requested publications, maintain appropriate delivery and suppression records, and honour unsubscribe requests. This processing is based on your consent, which may be withdrawn at any time by using the unsubscribe facility included in publication emails or by contacting us.

Depending on the circumstances, processing may be based on:

• steps taken at your request before entering into a contract;
• performance of a contract;
• compliance with a legal obligation;
• legitimate interests; or
• consent, where applicable.

6. Regulated and compliance-related processing

Ali Geren is authorised by the Malta Financial Services Authority under Article 5 of the Company Service Providers Act (Chapter 529 of the Laws of Malta) as a Limited Company Service Provider.

Where an enquiry or engagement falls within the applicable Limited Company Service Provider scope, personal data may need to be processed to satisfy applicable regulatory, compliance, identification, due-diligence, record-keeping or reporting obligations.

Such information will be processed only where relevant to the service or legal obligation concerned.

7. Sharing of personal data

Personal data may be disclosed where reasonably necessary to:

• service providers supporting website hosting, communications, IT or professional administration;
• professional advisers;
• competent regulators, supervisory authorities, law-enforcement bodies or other public authorities where disclosure is required or permitted by law; and
• other parties where necessary for an agreed professional engagement.

Personal data is not sold to third parties.

Service providers processing personal data on our behalf are expected to process it only for authorised purposes and subject to appropriate data-protection safeguards.

8. International transfers

Some technology or service providers may process information outside Malta or the European Economic Area.

Where personal data is transferred internationally, appropriate safeguards will be used where required by applicable data-protection legislation.

9. Website services and external providers

The website may use or link to external services such as mapping services, professional social-media platforms and website infrastructure providers.

When you interact with an external service, that provider may process technical or personal information under its own privacy terms.

Detailed information about cookies and similar technologies will be provided separately in POL-003 — Cookies Policy.

Email publication service. Geren Corporate uses Microsoft Azure services, including Azure Communication Services and Azure-hosted storage used by the website, to process subscription records and deliver publication emails. Microsoft acts as a technology service provider for this purpose. Publication emails are sent individually and do not disclose other subscribers’ email addresses. Email engagement tracking is disabled in the website’s publication-sending process.

10. How long we retain information

Personal data will not be retained for longer than necessary for the purpose for which it was collected.

Retention periods are determined by the nature of the enquiry or engagement, whether a professional relationship is established, applicable legal or regulatory requirements, the need to maintain appropriate business records and the establishment, exercise or defence of legal claims.

Where an enquiry does not result in an engagement, information will be deleted or securely archived when it is no longer reasonably required.

Active publication-subscription records are retained while the subscription remains active. Where you unsubscribe, the active subscription is stopped and a limited suppression or delivery record may be retained where reasonably necessary to demonstrate the unsubscribe request, prevent further publication emails and maintain appropriate administrative records.

11. Security

Appropriate technical and organisational measures are used to protect personal data against unauthorised access, disclosure, alteration, accidental loss or unlawful processing.

While such measures are used, transmission of information over the internet carries inherent risks and no internet transmission or electronic storage system can be guaranteed to be completely secure.

Users should exercise appropriate care when deciding what information to transmit electronically and should avoid sending personal, confidential or sensitive information that is not necessary for the relevant enquiry.

12. Your data-protection rights

Depending on the circumstances and applicable law, you may have rights including:

• access to your personal data;
• rectification of inaccurate or incomplete information;
• erasure;
• restriction of processing;
• objection to processing;
• data portability; and
• withdrawal of consent where processing is based on consent.

These rights are subject to applicable legal conditions and exceptions.

Requests relating to your personal data may be sent to support@gerencorporate.mt.

Consent to receive email publications can also be withdrawn at any time through the unsubscribe link included in each publication email.

We may request information reasonably necessary to verify your identity before acting on a request.

13. Right to complain

If you believe your personal data has been processed in breach of applicable data-protection legislation, you may raise the matter with us at support@gerencorporate.mt.

You also have the right to lodge a complaint with the Office of the Information and Data Protection Commissioner (IDPC), Malta.

14. Automated decision-making

The Geren Corporate website does not currently use automated decision-making or profiling that produces legal or similarly significant effects on individuals.

15. External links

This website may contain links to third-party websites or services.

Geren Corporate does not control third-party websites or services and, to the extent permitted by applicable law, is not responsible for their privacy practices, security, content or operation.

Users should review the privacy information and terms of any third-party website or service before providing personal information to it. Once you leave the Geren Corporate website, the privacy practices and terms of the external website or service will apply.

16. Changes to this Privacy Notice

This Privacy Notice may be updated when website functionality, professional services, legal requirements or data-processing arrangements change.

The latest version will be published on this page together with its last-updated date.