Privacy Policy

Azure Marketing Services B.V. – Privacy and Cookie Policy

Version 1 – 30 January 2023

Azure Marketing Services B.V.  (in this Privacy Policy, “us”, “we” and “our”) is the data controller of your personal data and is subject to the Ordinance No. 84 of 4 September 2010 (the “Ordinance”) which is modelled on Act Implementing the EU General Data Protection Regulation 2016/679 (the “GDPR”), and any other applicable laws and regulations (collectively referred to as the “Applicable Data Protection Laws”).

Our Privacy and Data Compliance Officer’s contact details are:

E–mail address – [email protected]

Address – Fransche Bloemweg 4, Willemstad, Curacao

This Privacy Policy replaces any previous Privacy Policy or equivalent which you may have been provided with prior to the Last Modified Date stated above.

Your rights

Under the Applicable Data Protection Laws you have the following rights:

  • To instruct us to cease processing your personal data if the processing is causing you damage or distress;

  • To gain access to, and copies of, the personal data that we hold about you;

  • To instruct us not to send you marketing communications;

  • To instruct us to restrict our data processing activities;

  • To instruct us to erase your personal data;

  • To obtain from us the personal data we hold about you which you have provided to us, in a practical format specified by you, including for the purpose of you transmitting that personal data to another data controller;

  • To instruct us to correct the personal data we hold about you if it is incorrect.

Please contact our Privacy and Data Compliance Officer through the ways specified above if you wish to make a request and exercise your rights.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

How we collect your data

We collect your personal data in multiple ways, for example:

  • From the material you provide to us when you meet us;

  • When you communicate with us by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;

  • From other affiliated companies of ours;

  • From your agents, advisers and intermediaries;

  • From publicly available sources or from third parties;

  • From the information you share with us through our website (the “Website”).
The categories of personal data we collect

We may collect the following categories of personal data about you:

  • Your name and contact information such as your home or business address, email address and telephone and fax number; Biographical information which may confirm your identity including your date of birth, tax identification number, VAT number, reference letters, CV,  passport number, driver’s license or national identity card details, country of domicile and/or your nationality;

  • Information relating to your financial situation such as income, expenditure, assets and liabilities, sources of wealth, as well as your bank account details;

  • Information relating to your professional situation such as company details, information about the company’s beneficial owners, directors and officers, source of funds and wealth, and any other information in relation to your business operations;

  • An understanding of your goals and objectives in our services;

  • Information to assess whether you may be characterized as a politically exposed person or a person involved in terrorist financing/money laundering;

  • Information that you provide by filling in forms, in particular at the time of the first contact with us;

  • We also collect personal data when you enter a contest or promotion sponsored by us, and when you report a problem with our Website;

  • Records and copies of your correspondence (including e-mail addresses), if you contact us;

  • Details of transactions you carry out, if any, and of the fulfilment of your orders;

  • For the technical purpose; Internet protocol (IP) address, login data, Browser type and version, time zone setting and location, Browser plug-in types and versions, and operating system and platform;

  • Any other information we may be obliged to process in view of legal and regulatory obligations.
The rationale behind the processing of your personal data (other than with your consent), the use of that personal data and whom we share it with:

(i) Performance of a contract with you

We process your personal data in the course of the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.

In this respect, we use your personal data for the following:

  • To prepare a quotation for you with respect to the services we offer;

  • To provide you with the services as agreed with you from time to time;

  • To deal with any complaints or feedback you may have;

  • An understanding of your goals and objectives in our services;

  • For any other purpose for which you provide us with your personal data. In this respect, we may share your personal data with or transfer it to the following:

    • Your agents, advisers, intermediaries, and custodians of your assets who you tell us about;

    • Third parties whom we engage to assist in delivering the services to you, including our affiliated companies;

    • Our professional consultants where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, or IT advisors;

    • Other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you;

    • Our data storage providers.

(ii) Legal obligations

We also process your personal data for our compliance with legal obligations which we are under. In this respect, we will use your personal data for the following:

  • To meet our compliance and regulatory obligations, such as compliance with anti-money laundering and anti-terrorist financing laws;

  • As required by tax authorities or any competent court or legal authority. In this respect, we will share your personal data with the following:

    • Our consultants where it is necessary for us to obtain their advice or assistance;

    • Our auditors where it is necessary as part of their auditing functions;

    • With relevant regulators or law enforcement agencies where we are required to do so.

(iii) Legitimate interests

We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person.

In this respect, we use your personal data for the following:

  • For the administration and management of our business, including recovering money you owe to us, and archiving or statistical analysis;

  • Seeking advice on our rights and obligations, such as where we require our own legal advice;

In this respect we will share your personal data with the following:

  • Our advisers or agents where it is necessary for us to obtain their advice or support;

  • With third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.

We will ensure that appropriate security measures, such as technical and organisational, physical, electronic, and procedural policies and safeguards, are implemented to protect your personal data against unauthorized or unlawful processing and against accidental loss, damage, destruction, alteration or disclosure.

We also limit access to the personal data to employees and third parties on a need to know basis depending on who reasonably needs to process such data in accordance with this Privacy Policy and the purpose for which we have collected your information.

Marketing Information

We may send you marketing information about similar services we provide, as well as other information in the form of e-mails and invitations to events which we believe might be of interest to you in accordance with your marketing consent.

We may communicate this to you in a number of ways including by telephone or email.

Transfer and processing of your personal data outside the European Union

When sharing your personal data with third parties as set out in this Privacy Policy, it may be transferred outside the European Union. In these circumstances, your personal data will only be transferred on one of the following bases:

  • The country that we send the personal data to is approved by the European Commission as providing an adequate level of protection for personal data;

  • The country that we send the personal data to is approved by the European Commission as providing an adequate level of protection for personal data;

  • When you have explicitly consented to the same.
Retention of your data

We will keep your personal data for as long as we have a business relationship with you. Once our business relationship with you has ended, we may keep your personal data for the longest of the following periods:

  • Any retention period set out in our retention policy which is in line with regulatory requirements relating to retention; or

  • The end of the period in which any legal action or investigations might arise in respect of the services provided.

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 authorised use and whether we can achieve those purposes through other means, and the applicable legal requirements. We may keep your data for longer if we cannot delete it for legal, regulatory or technical reasons. If we do, we will make sure that your privacy is protected and that your personal data are only used for those purposes.


Cookies are small pieces of data, stored in text files, that are stored in your browser when you visit websites. They are widely used to “remember” you and your preferences, either for a single visit (through a “session cookie”) or for multiple repeat visits (using a “persistent cookie”). They are essential to keep certain parts of our site running correctly and securely. They are also used to personalise your online experience to make it more relevant to you and also to provide usage data back to us. They can also be used to present you with more tailored advertising content. For them to work as required, some personal information must be used from you when you use our site. You can choose whether to accept or reject some or all types of cookies and control this through your device’s browser settings and we also make you aware of this by showing you our cookie banner when you visit our site.

How we use cookies

We use cookies for several different purposes. Some cookies are necessary for technical reasons; some enable a personalised experience for both visitors and registered users; and some allow the display of advertising from selected third party networks. Some of these cookies may be set when a page is loaded, or when a user takes a particular action on one of our services. For more information on the choices you have about the cookies we use, please see the information provided below about controlling cookies.

Types of cookies

By using the Website without restricting the cookies in your browser, the types of cookies we may use are outlined below:

Necessary and Functionality Cookies: These cookies are essential for you to navigate the site correctly and log in to the secure areas. They also enable us to deliver content specific to your device. These cookies allow our Website to remember choices you have made, such as your username or region. They help us keep you logged into your account as you navigate around our Website. We also use them to personalise your experience by, for example, showing more relevant onsite content. Without these cookies you may not be able to access your account so they are vital to keep the site functioning as intended.

Analytical and performance cookies: These cookies collect information about visitor activity on the Website so that we can monitor performance. We use these details to improve how our services function and to understand how users interact with our services. For example, how many people visit certain pages, the number of people who see specific content. Without these cookies you will still be able to access the site without an effect on your online experience.

Security cookies: We use these cookies to help identify and prevent potential security risks.

Targeting Cookies: These cookies may used to deliver adverts and content that are more relevant to you as well as to limit the number of times you see a particular advertisement and to measure the effectiveness of advertising campaigns, if applicable.

The cookies remember that you have visited a website, and we may share this information with other organisations for advertising purposes. We also use them to test and improve our products and services by, for example, testing out product experiences. Without these cookies you will still be able to access the site but may not receive the most relevant content.

Tracking Cookies: We use cookies placed by third parties to collect personal information about your browsing activity, which they then group with data about what other people with similar interests in similar demographic groups are looking at. The resulting information is used to show you online adverts based on those interests (this is known as ‘online behavioural advertising’). You will still be presented with advertising but it is unlikely to be relevant to you. Without these cookies you will still be able to login and play on the site without any effect on your experience.

Controlling my cookies

You may wish to restrict the use of cookies or completely prevent them from being set. All modern browsers allow you to see what cookies you have, and to clear them individually or in their entirety by changing your cookie settings. Cookie settings are typically found in the ‘options’ or ‘preferences’ menu of your browser, otherwise you should use the ‘Help’ option in your browser for more details. You may also find the links below helpful:

If you disable cookies, please be aware that some of the features of our services may not function correctly.

Changes to Our Privacy Policy

We may modify our privacy policy from time to time and although we may attempt to notify you, you are expected to periodically review the most up-to-date version found at our Website so you are aware of these binding changes.

When we amend our privacy policy, the “Last Modified Date” will be changed, therefore you agree that you will review this privacy policy from time to time and refresh the page when doing so. If the “Last Modified Date” has not been changed from the last time you have revised our privacy policy, then it is unchanged. On the other hand, if the date has changed, then there have been changes, and you agree to re-review our privacy policy, and you agree to the new ones.

No Rights of Third Parties

This privacy policy does not create rights enforceable by third parties or require disclosure of any personal data relating to users of the Website.

No Error Free Performance

We do not guarantee error-free performance under this privacy policy and we shall not be liable for any incidental, consequential or punitive damages relating to this privacy policy.