We are very pleased about your interest in our company. Data protection is of particular importance for the management of ICGK Ltd. A use of the internet pages of the ICGK Ltd is possible in principle without any indication of personal data. However, if an affected person wishes to use our company's special services through our website, personal data processing may be required. If the processing of personal data is required and there is no legal basis for such processing, we generally seek the consent of the data subject.
ICGK Ltd, as the controller, has implemented numerous technical and organizational measures to ensure the most complete protection possible for personal data processed via this website. Nevertheless, Internet-based data transmissions can generally have security holes, so that absolute protection can not be guaranteed. For this reason, every person concerned is free to submit personal data to us in alternative ways, for example by telephone.
a) Personal data
Personal data is any information relating to an identified or identifiable natural person (hereinafter the "data subject"). A natural person is considered to be identifiable who, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier or one or more special features, expresses the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person can be identified.
b) The person concerned
Affected person is any identified or identifiable natural person whose personal data is processed by the controller.
Processing means any process or series of operations related to personal data, such as collecting, organizing, storing, adapting or modifying, reading, querying, using, with or without the aid of automated procedures; disclosure by submission, dissemination or other form of provision, reconciliation or association, restriction, erasure or destruction.
d) Restriction of processing
Restriction of the processing is the marking of stored personal data with the aim to limit their future processing.
Profiling is any kind of automated processing of personal data that consists in using that personal information to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation and health to analyze or predict preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.
Pseudonymisation is the processing of personal data in such a way that personal data can no longer be attributed to a specific data subject without the need for additional information, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.
g) Controller or for the processing controller
The controller or the processing controller is the natural or legal person, public authority, body or body that, alone or in concert with others, decides on the purposes and means of processing personal data. Where the purposes and means of such processing are determined by Union law or the law of the Member States, the controller or the specific criteria for his designation may be provided for under Union or national law.
The processor is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
Recipient is a natural or legal person, public authority, agency or other entity to whom Personal Data is disclosed, whether or not it is a third party. However, authorities which may receive personal data under Union or national law in connection with a particular mission are not considered as beneficiaries.
j) Third parties
Third is a natural or legal person, public authority, body or body other than the data subject, the controller, the processor and the persons authorized under the direct responsibility of the controller or the processor to process the personal data.
Consent is any voluntarily given and unambiguously expressed in the form of a statement or other unambiguous confirmatory act by the data subject for the particular case, by which the data subject indicates that they consent to the processing of the personal data concerning him / her is.
2. Name and address of the controller
The person responsible within the meaning of the General Data Protection Regulation, other data protection laws in the Member States of the European Union and other provisions of a data protection character is:
ICGK International Consulting Group Kapur Ltd
24 Holborn Viaduct
London, EC1A 2BN
Tel.: +44 (0)77 32294533
The data subject can prevent the setting of cookies through our website at any time by means of a corresponding setting of the Internet browser used and thus permanently contradict the setting of cookies. Furthermore, already set cookies can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.
4. Collecting general data and information
The ICGK Ltd website collects a series of general data and information each time the website is accessed by an affected person or an automated system. This general data and information is stored in the log files of the server. The (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the internet page from which an accessing system accesses our website (so-called referrers), (4) the sub-web pages which can be accessed via (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information used in the event of attacks on our information technology systems.
When using this general data and information, ICGK Ltd does not draw conclusions about the data subject. Rather, this information is required to (1) correctly deliver the contents of our website, (2) to optimize the content of our website and to advertise it, (3) to ensure the continued functioning of our information technology systems and the technology of our website, and (4) to provide law enforcement authorities with the information necessary for law enforcement in the event of a cyberattack. ICGK Ltd evaluates this anonymously collected data and information on the one hand statistically and further with the aim to increase the data protection and data security in our company in order to ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by an affected person.
5. Contact via the website
Due to legal regulations, the ICGK Ltd website contains information that enables quick electronic contact with our company as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If an affected person contacts the data controller by e-mail or through a contact form, the personal data provided by the data subject will be automatically saved. Such personal data, voluntarily transmitted by an individual to the controller, is stored for the purpose of processing or contacting the data subject. There is no disclosure of this personal data to third parties.
6. Routine deletion and blocking of personal data
The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of the storage or, as the case may be, by the European directives or regulations or by any other legislator in laws or regulations which the controller was provided for.
If the storage purpose is omitted or if a storage period prescribed by the European directives and regulations or any other relevant legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.
7. Rights of the person concerned
a) Right to confirmation
Each data subject has the right, as granted by the European Regulators and Regulators, to require the controller to confirm whether personal data relating to him / her is being processed. If an affected person wishes to make use of this right of confirmation, they can contact an employee of the controller at any time.
b) Right to information
Any person concerned by the processing of personal data shall have the right, granted by the European Di- rective and Regulatory Authority, at any time to obtain from the data controller information free of charge on the personal data stored about him and a copy of that information. Furthermore, the European legislator and regulator has provided the data subject with the following information:
- the processing purposes
- the categories of personal data being processed
- the recipients or categories of recipients to whom the personal data have been disclosed or are still being disclosed, in particular to recipients in third countries or to international organizations
- if possible, the planned duration for which the personal data will be stored or, if that is not possible, the criteria for determining that duration
- the right of rectification or erasure of the personal data concerning them or restriction of processing by the controller or a right to object to such processing
- the existence of a right of appeal to a supervisory authority
- if the personal data are not collected from the data subject: all available information on the source of the data
- the existence of automated decision-making, including profiling, in accordance with Article 22 (1) and (4) of the GDPR and - at least in these cases - meaningful information on the logic involved and the scope and intended impact of such processing on the data subject
In addition, the data subject has a right of access as to whether personal data has been transmitted to a third country or to an international organization. If that is the case, then the data subject has the right to obtain information about the appropriate guarantees in connection with the transfer.
If an interested party wishes to exercise this right to information, they may at any time contact an employee of the controller.
c) Right to rectification
Any person affected by the processing of personal data has the right granted by the European legislator to demand the immediate correction of inaccurate personal data concerning him / her. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing.
If an affected person wishes to exercise this right of rectification, they may, at any time, contact an employee of the controller.
d) Right to cancellation (right to be forgotten)
Any person affected by the processing of personal data shall have the right granted by the European Directives and Regulators to require the controller to immediately delete the personal data concerning him, provided that one of the following reasons is satisfied and the processing is not required:
- The personal data has been collected or otherwise processed for such purposes for which they are no longer necessary.
- The person concerned revokes the consent on which the processing was based on Article 6 (1) (a) of the GDPR or Article 9 (2) (a) of the GDPR and lacks any other legal basis for the processing.
- The data subject submits an objection to the processing pursuant to Art. 21 (1) DS-GVO, and there are no legitimate reasons for the processing, or the data subject appeals pursuant to Art. 21 (2) DS-GVO the processing.
- The personal data were processed unlawfully.
- The deletion of personal data is required to fulfill a legal obligation under Union or national law to which the controller is subject.
- The personal data were collected in relation to information society services offered pursuant to Art. 8 para. 1 DS-GVO.
If one of the above reasons is correct and an affected person wishes to arrange for the deletion of personal data stored by ICGK Ltd, they may at any time contact an employee of the controller. The employee of the ICGK Ltd will arrange that the deletion request be fulfilled immediately.
If the personal data have been made public by ICGK Ltd and if our company is responsible for deleting personal data as the person responsible pursuant to Art. 17 para. 1 DS-GVO, ICGK Ltd shall take appropriate measures, taking into account the available technology and the implementation costs of a technical nature, to inform other data controllers processing the published personal data that the data subject has deleted from all other data controllers any links to such personal data or copies or replications of such personal data as far as the processing is not required. The employee of ICGK Ltd will arrange the necessary in individual cases.
e) Right to restriction of processing
Any person affected by the processing of personal data has the right, granted by the European directive and regulatory authority, to require the controller to restrict the processing if one of the following conditions applies:
- The accuracy of the personal data is contested by the data subject for a period of time that enables the person responsible to verify the accuracy of the personal data.
- The processing is unlawful, the data subject refuses to delete the personal data and instead requests the restriction of the use of personal data.
- The data controller no longer needs the personal data for processing purposes, but the data subject requires them to assert, exercise or defend their rights.
- The person concerned has objection to the processing acc. Art. 21 para. 1 DS-GVO and it is not yet clear whether the legitimate reasons of the person responsible outweigh those of the person concerned.
If one of the above-mentioned conditions is met and an affected person wishes to request the restriction of personal data stored by ICGK Ltd, they can contact an employee of the controller at any time. The employee of ICGK Ltd will initiate the restriction of processing.
f) Data transferability
Any person affected by the processing of personal data shall have the right conferred by the European Directives and Regulations to obtain the personal data concerning him / her provided to a controller by the data subject in a structured, common and machine-readable format. It also has the right to transfer this data to another person responsible without hindrance by the controller to whom the personal data was provided, provided that the processing is based on the consent pursuant to Article 6 (1) (a) of the GDPR or Article 9 (1) (b) 2 (a) of the GDPR or on a contract pursuant to Article 6 (1) (b) of the GDPR and processing by means of automated processes, unless the processing is necessary for the performance of a task of public interest or in the exercise of public authority, which has been assigned to the responsible person.
Furthermore, in exercising their right to data portability under Article 20 (1) of the GDPR, the data subject has the right to obtain that the personal data are transmitted directly from one controller to another, insofar as this is technically feasible and if so this does not affect the rights and freedoms of others.
To assert the right to data portability, the data subject can contact an employee of ICGK Ltd at any time.
g) Right to object
Any person concerned by the processing of personal data shall have the right conferred by the European directive and regulatory authority at any time, for reasons arising from its particular situation, against the processing of personal data relating to it pursuant to Article 6 (1) (e) or f DS-GVO takes an objection. This also applies to profiling based on these provisions.
ICGK Ltd will no longer process the personal data in the event of an objection, unless we can prove compelling legitimate reasons for the processing that outweigh the interests, rights and freedoms of the data subject, or the processing is the assertion, exercise or defense of legal claims.
If ICGK Ltd processes personal data in order to operate direct mail, the data subject has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to the profiling, as far as it is associated with such direct mail. If the data subject objects to ICGK Ltd for the purposes of direct advertising, ICGK Ltd will no longer process the personal data for these purposes.
In addition, the data subject has the right, for reasons arising from his or her particular situation, against the processing of personal data relating to him or her, which is performed by ICGK Ltd for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) DS. GMOs are invited to submit an objection unless such processing is necessary to fulfill a task of public interest.
In order to exercise the right to object, the data subject can directly contact an employee of ICGK Ltd. The data subject is also free, in the context of the use of information society services, notwithstanding Directive 2002/58 / EC, to exercise his right of opposition by means of automated procedures using technical specifications.
h) Automated decisions on a case-by-case basis, including profiling
Any person concerned by the processing of personal data shall have the right, as granted by the European legislature and the legislature, not to be subject to a decision based solely on automated processing, including profiling, which has a legal effect on it or, in a similar manner, significantly affects it; unless the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is permitted by Union or Member State legislation to which the controller is subject, and that legislation provides for appropriate measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject; or (3) with the express consent of the data subject.
If the decision (1) is required for the conclusion or performance of a contract between the data subject and the controller or (2) it takes place with the express consent of the data subject, ICGK Ltd shall take appropriate measures to safeguard the rights and freedoms and the authorized persons Interests of the data subject, including at least the right to obtain the intervention of a person by the controller, to express his / her own position and to contest the decision.
If the data subject wishes to claim automated decision-making rights, they can contact an employee of the controller at any time.
i) Right to revoke a data protection consent
Any person affected by the processing of personal data has the right, granted by the European directive and regulatory authority, to revoke consent to the processing of personal data at any time.
If the data subject wishes to assert their right to withdraw consent, they may, at any time, contact an employee of the controller.
8. Data protection in applications and in the application process
The controller collects and processes the personal data of applicants for the purpose of processing the application process. The processing can also be done electronically. This is particularly the case if an applicant submits corresponding application documents to the controller by electronic means, for example by e-mail or via a web form available on the website. If the controller concludes a contract of employment with an applicant, the data transmitted will be stored for the purposes of the employment relationship in accordance with the law. If no employment contract is concluded with the candidate by the controller, the application documents will be automatically deleted two months after the announcement of the rejection decision, unless deletion precludes other legitimate interests of the controller. Other legitimate interest in this sense, for example, a burden of proof in a procedure under the General Equal Treatment Act (AGG).
9. Legal basis of processing
Art. 6 I lit. A DS-GMO serves our company as the legal basis for processing operations where we obtain consent for a particular processing purpose. If the processing of personal data is necessary to fulfill a contract of which the data subject is a party, as is the case, for example, in processing operations necessary for the supply of goods or the provision of any other service or consideration, processing shall be based on Art. 6 I lit. b DS-GMO. The same applies to processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries regarding our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c DS-GMO. In rare cases, the processing of personal data may be required to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our premises were injured and his or her name, age, health insurance or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d DS-GMO are based. Ultimately, processing operations could be based on Art. 6 I lit. f DS-GMOs are based. On this legal basis, processing operations that are not covered by any of the above legal bases are required if processing is necessary to safeguard the legitimate interests of our company or a third party, unless the interests, fundamental rights and fundamental freedoms of the person concerned prevail. Such processing operations are particularly allowed to us because they have been specifically mentioned by the European legislator. In that regard, it considered that a legitimate interest could be assumed if the data subject is a customer of the controller (recital 47, second sentence, DS-BER).
10. Eligible processing interests that are being pursued by the controller or a third party
Is the processing of personal data based on Article 6 I lit. f DS-GMO is our legitimate interest in conducting our business for the benefit of all of our employees and our shareholders.
11. Duration for which the personal data are stored
The criterion for the duration of the storage of personal data is the respective statutory retention period. After the deadline, the corresponding data will be routinely deleted, if they are no longer required to fulfill the contract or to initiate a contract.
12. Statutory or contractual provisions for the provision of personal data; Necessity for the conclusion of the contract; Obligation of the data subject to provide the personal data; possible consequences of non-provision
We clarify that the provision of personal information is in part required by law (such as tax regulations) or may result from contractual arrangements (such as details of the contractor). Occasionally it may be necessary for a contract to be concluded that an affected person provides us with personal data that must subsequently be processed by us. For example, the data subject is required to provide us with personal information when our company enters into a contract with her. Failure to provide the personal data would mean that the contract with the person concerned could not be closed. Prior to any personal data being provided by the person concerned, the person concerned must contact an employee. Our employee will inform the individual on a case-by-case basis whether the provision of the personal data is required by law or contract or is required for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of the non-provision of the personal data.
13. Existence of automated decision-making
As a responsible company we refrain from automatic decision-making or profiling.