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Privacy Policy

We are committed to protecting the privacy and security of your personal information.

PURPOSE OF THIS POLICY

This policy describes how we collect and use personal information about you, in accordance with the General Data Protection Regulation (“GDPR”) and any other national laws, regulations and secondary legislation, as amended or updated from time to time, in the relevant jurisdiction to which the processing relates (“Data Protection Legislation”).

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

USE OF INFORMATION

Toro Gold is a private gold exploration, development and production company focused on West Africa. Our website at: https://www.torogold.com/ is operated by Toro Gold Ltd (“Toro Gold”, “we”, “us”, “our” and “ours”). We are a limited liability company incorporated in Guernsey with registration number: 50076. Our registered office is at: Trafalgar Court 2nd Floor, East Wing Admiral Park, St Peter Port, Guernsey, GY1 3EL.

For the purpose of the Data Protection Legislation and this policy, we are the “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy policy.

HOW WE MAY COLLECT YOUR PERSONAL INFORMATION

We obtain information about you when you use our website, for example: (i) when you contact us by email, telephone, post or social media; and (ii) as you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns by using cookies and other similar technologies. Please see our Cookie Policy for further details.

THE KIND OF INFORMATION WE HOLD ABOUT YOU

The personal information we collect might include your personal details (such as your name and/or address), email address, information about any enquiries you make to us, IP address, and information regarding what website pages are accessed and when.

HOW WE WILL USE INFORMATION ABOUT YOU

We may process your personal data for purposes necessary for the performance of any contract with you and to comply with our legal obligations.

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Situations in which we will use your personal information

We may use your information in order to:

  • ensure that content from our site is presented in the most effective manner for you and for your computer;
  • provide you with information or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
  • carry out our obligations arising from any agreements entered into between you and us;
  • allow you to participate in interactive features of our service, when you choose to do so; and
  • notify you about changes to our services.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

If you refuse to provide us with certain information when requested, we may not be able to perform any relevant contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.

We may also process your personal information without your knowledge or consent, in accordance with this policy, where we are legally required or permitted to do so.

Data Retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration:

  • our business requirements;
  • the purposes for which we originally collected the personal data;
  • the lawful grounds on which we based our processing;
  • the types of personal data we have collected;
  • the amount and categories of your personal data; and
  • whether the purpose of the processing could reasonably be fulfilled by other means.

Change of purpose

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal information where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

DATA SHARING

Why might you share my personal information with third parties?

We will share your personal information with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services.

All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal information. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Transferring information outside of the EU

Your personal information may be stored and processed in any country where we have operations. Toro Gold is based outside the European Economic Area (“EEA”) in Guernsey and your personal data will be transferred to and processed in Guernsey. For the purpose of the GDPR, Guernsey is deemed to provide an adequate level of protection for personal data.

Whenever we otherwise transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us using the details below if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Security

We have put in place commercially reasonable and appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Your Rights

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information. This enables you to receive details of the personal information we hold about you and to check that we are processing it lawfully.
  • Request correction of the personal information that we hold about you.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to exercise any of the above rights, you can contact us, using the contact details below.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

RIGHT TO WITHDRAW CONSENT  

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us); you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us using the contact details below.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

POLICY CHANGES

Any changes to this policy will be posted here. This policy was last updated on 4 June 2018.

CONTACT US

If you have any questions regarding this policy, if you would like to speak to us about the manner in which we process your personal data, or to otherwise exercise your rights in respect of your personal data which we process, please contact us via email: info@torogold.com or by clicking here: Contact us

If you are not satisfied with our response or believe we are not lawfully processing your data you can also complain to a supervisory authority at any time.