Privacy Policy

1. Data Controller

The data controller responsible for the processing of your personal data through this website is:

Rocamar

Activité au Nom Personnel (ANP) registered in the Principality of Monaco17, avenue Albert II, Monacoc/° The Office & Co

Rocamar is subject to the data protection laws of the Principality of Monaco, in particular Loi n° 1.565 du 3 décembre 2024 relative à la protection des données à caractère personnel (the “Monaco Data Protection Law”). Where our services are directed at individuals in the European Union or the United Kingdom, the provisions of the EU General Data Protection Regulation (GDPR) and the UK GDPR may also apply.

2. Scope of This Policy

This Privacy Policy explains how Rocamar collects, uses, stores, and protects personal data obtained through our website (www.rocamar.co), through direct communications with prospective and existing clients, and through our professional advisory activities. It applies to all visitors to our website, individuals who contact us, and clients who engage our services.

3. Personal Data We Collect

3.1 Data You Provide Directly

When you contact us, request information about our services, or engage us as a client, we may collect:

•Your name, professional title, and company affiliation

•Your email address, telephone number, and postal address

•The content of any correspondence or enquiry you send us

•Billing and invoicing information necessary for the provision of our services

•Any other information you voluntarily provide in the course of our advisory relationship

3.2 Data Collected Automatically

When you visit our website, certain technical data may be collected automatically, including:

•Your IP address and approximate geographic location

•Browser type, operating system, and device information

•Pages visited, time spent on pages, and navigation patterns

•Referring website or source

•Data collected through cookies and similar technologies (see Section 8 below)

3.3 Sensitive Data

Rocamar does not intentionally collect sensitive personal data (such as data revealing racial or ethnic origin, political opinions, religious beliefs, health information, or sexual orientation). Should such data be incidentally provided in the course of an advisory engagement, it will be treated with the highest level of confidentiality and processed only to the extent strictly necessary.

4. Legal Basis for Processing

In accordance with Monaco’s Loi n° 1.565 and, where applicable, the GDPR, we process your personal data on one or more of the following legal bases:

a)Consent: where you have given clear consent for us to process your personal data for a specific purpose, such as subscribing to receive our publications or market intelligence reports.

b)Contractual necessity: where processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract (e.g., responding to an enquiry about our advisory services).

c)Legitimate interests: where processing is necessary for our legitimate business interests, provided these are not overridden by your rights and freedoms. This includes improving our website, conducting business development, and maintaining our professional network.

d)Legal obligation: where processing is required to comply with applicable laws and regulatory requirements in the Principality of Monaco.

5. How We Use Your Personal Data

We use the personal data we collect for the following purposes:

•To respond to your enquiries and provide the advisory services you have requested

•To manage our contractual relationship with you, including invoicing and administration

•To send you information about our services, publications, or events where you have consented to receive such communications or where we have a legitimate interest in doing so

•To improve our website and the quality of our services

•To comply with our legal and regulatory obligations under Monaco law

6. Data Sharing and Disclosure

Rocamar does not sell, rent, or trade your personal data to third parties. We may share your data in the following limited circumstances:

•Service providers: We may share data with trusted third-party service providers who assist us in operating our website, managing our business, or delivering our services (e.g., website hosting, email services, accounting). These providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.

•Legal requirements: We may disclose your data where required by law, regulation, or judicial order applicable in the Principality of Monaco.

•Professional introductions: In the course of our advisory services, and only with your prior agreement, we may share your professional contact details with vetted professionals within our network (e.g., lawyers, accountants, sector specialists) to facilitate introductions relevant to your engagement.Our website is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to present our services and communicate with you. Your data may be stored through Wix.com’s data storage, databases, and general applications. Wix.com stores your data on secure servers. For more information, please review Wix.com’s Privacy Policy at www.wix.com/about/privacy.

7. International Data Transfers

As Rocamar operates from Monaco, which is not a member of the European Union, the transfer of personal data may involve cross-border transfers. Where your data is transferred outside Monaco or to countries that do not benefit from an adequacy decision, we ensure that appropriate safeguards are in place, such as standard contractual clauses or other mechanisms recognised under Loi n° 1.565 and, where applicable, the GDPR.Monaco’s Loi n° 1.565 has been designed to align with European data protection standards and Convention 108+ of the Council of Europe. The Principality is actively pursuing an adequacy decision from the European Commission.

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance your browsing experience and to analyse website traffic. Cookies are small text files placed on your device when you visit our website.

8.1 Types of Cookies We Use

•Essential cookies: These are necessary for the website to function and cannot be switched off. They are usually set in response to actions you take, such as setting your privacy preferences or filling in forms.

•Analytics cookies: These allow us to count visits and traffic sources so we can measure and improve website performance. They help us understand which pages are the most and least visited.

•Functional cookies: These enable enhanced functionality and personalisation, such as remembering your language preferences.

8.2 Managing Cookies

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of our website. You may also manage cookie consent through the cookie banner displayed when you first visit our website.

9. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Specifically:

•Client data: retained for the duration of the advisory engagement and for up to ten (10) years thereafter, in accordance with Monaco’s commercial record-keeping obligations.

•Enquiry data: retained for up to two (2) years from the date of your last communication with us, unless a contractual relationship is established.

•Analytics and cookie data: retained in accordance with the retention periods specified by our analytics providers.When personal data is no longer required, it will be securely deleted or anonymised.

10. Your Rights

Under Loi n° 1.565 and, where applicable, the GDPR and UK GDPR, you have the following rights with respect to your personal data:

•Right of access: You may request confirmation of whether we process your personal data and, if so, obtain a copy of such data.

•Right to rectification: You may request correction of inaccurate or incomplete personal data.

•Right to erasure: You may request deletion of your personal data, subject to applicable legal retention obligations.

•Right to restriction of processing: You may request that we restrict the processing of your data in certain circumstances.

•Right to data portability: You may request to receive your personal data in a structured, commonly used, and machine-readable format.

•Right to object: You may object to the processing of your personal data where such processing is based on our legitimate interests.

•Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact us at contact@rocamar.co or by post at the address indicated in Section 1 above. We will respond to your request within the timeframe prescribed by applicable law.

11. Supervisory Authority

If you believe that your personal data has been processed in violation of applicable data protection law, you have the right to lodge a complaint with the competent supervisory authority. For processing carried out in Monaco, the relevant authority is the:

Autorité de Protection des Données Personnelles (APDP)

Website: www.apdp.mc

For individuals in the European Union or the United Kingdom, you may also contact your local data protection authority.

12. Data Security

Rocamar implements appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures are regularly reviewed and updated in line with our obligations under Loi n° 1.565.

While we take all reasonable precautions, no method of transmission over the Internet or method of electronic storage is entirely secure. We cannot guarantee absolute security of data transmitted to our website.

13. Children’s Privacy

Our website and services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected data from a child, we will take steps to delete such data promptly.

14. Third-Party Links

Our website may contain links to third-party websites. Rocamar is not responsible for the privacy practices or the content of such websites. We encourage you to review the privacy policies of any third-party website you visit.

15. Changes to This Privacy Policy

Rocamar reserves the right to modify this Privacy Policy at any time. Any changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically. Material changes will be communicated through our website. Your continued use of our website following the posting of changes constitutes your acknowledgement of such changes.

16. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your rights, or have concerns about how your personal data is being processed, please contact us:

Rocamar17, avenue Albert II, Monaco c/° The Office & Co

Email: contact@rocamar.co

Website: www.rocamar.co