IMCI Group Website (GDPR) General Data Protection Regulation Policy

Welcome to IMCI Group’s privacy policy (partners, cooperation partners, associates and clients).

We at IMCI Group respect your privacy and we are committed to protecting your personal data. This privacy policy will inform you as to how IMCI Group looks after your personal data in order to protect your privacy.


This privacy notice aims to give you information on how any personal data IMCI Group collects from you or that you provide to us will be processed by us.

The General Data Protection Regulation (GDPR) is a legal framework that sets guidelines for the collection and processing of personal information of individuals within the European Union (EU). The GDPR sets out the principles for data management and the rights of the individual, while also imposing fines that can be revenue-based. The General Data Protection Regulation covers all companies that deal with data of EU citizens, so it is a critical regulation for corporate compliance officers at banks, insurers, and other financial companies. GDPR came into effect across the EU on May 25, 2018.

Read more: General Data Protection Regulation (GDPR) Definition | Investopedia


IMCI Group is the controller and responsible for your personal data (collectively referred to as: “The Company” in this privacy notice).

We have appointed a data protection office (DPO) which is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

3. CONTACT DETAILS of the data protection office

Our full details are:
The name of the Company is IMCI Group International Gmbh / LLC
The address is Hardturmstrasse 161 – 8005 Zurich /Switzerland
The contact is Pedro Gard Brito and Modesto N Peña Gorrin,


The data protection law in the UK and Europe has changed on 25 May 2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.


This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.


Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect data in the following main exchange and formats

CV’s, corporate presentations, TAF (Transaction application files for project financing, online and with offline file), Financial Services operations, business correspondence by letter and emails.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• First name, last name, title.
• HQ’s and billing address, email address and telephone numbers.
• Bank account details.
• Details about payments to and from you and other details of products and services you have purchased from us.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.


We have several methods to collect data from and about you including:

• Email or phone: You may give us your Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Enquire about our services;
• Engage us to provide services to you;
• Give us some feedback;
• Applying for joining our organization

Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as set out below:
(a) analytics providers;
(b) search information providers based inside the EU.


We will use your personal data in the following circumstances, under the law’s supervision:
• Perform the contract we are about to enter into;
• Evaluate a service request;
• Evaluate a cooperation request;
• In our or your legitimate interests, and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by sending us an e-mail on the above e-mail address.


IMCI Group will use your personal data in the following cases:

  • To register you as a new client, partner, cooperation partner or associate, for which we ask for Identity and contacts in order to elaborate a contract with you (can be NCNDA, Partner, Associate or JV Agreement contract);
  • To process and deliver your instruction to us including, during the performance of a contract with you, or necessary for our legitimate interests
  • To manage our relationship with you which will include:
  • Notifying you about changes to our terms or privacy policy
  • Asking you to leave a review or take a survey
  • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), or to comply with a legal obligation;
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • To make suggestions and recommendations to you about goods or services that may be of interest to you


We may use your email to send you information which we consider may be of interest to you.

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.


We will get your express opt-in consent before we share your personal data with any company for marketing purposes.


You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase.


We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


We may have to share your personal data with certain third parties for the purposes of a contract or service providing.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Your data is managed by a restricted few number of officers at IMCI Group

In addition, they will limit access to your personal data to employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality (NCNDA Contract).

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Said procedures are ruled in all NCNDA’s and cooperation contracts signed with IMCI Group.



We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our clients for six years after they cease being clients.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.


We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).

This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.


A. General
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

B. Your legal rights
You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.


In all legal binding contracts, NCNDA’s and TAF (Transaction Application File), IMCI Group is referring to the IMCI Group General Data Protection Regulation (GDPR), which are visible on the website and which are always distributed with all related contractual and relevant documentation.

Partners and cooperation partners will appear with a picture and name on our collaterals and website.

All related stakeholders have the right to decline our policies. By doing so, any cooperation or business partnership fails inmediately.

IMCI Group further uses on its email signature, a link to the imci website.

Our main form, TAF (Transaction application file), online and on paper, presents a sentence claiming that by signing this form, the clent is accepting to give us the right to use their personal data according to this policy.

All contracts will have also a sentence that gives us rights to use the personal data, until expressly written otherwise.


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