Sabre is a privately-owned global business that is committed to complying with the applicable data privacy and security requirements in the jurisdictions in which it operates. Sabre complies with internationally recognized standards of privacy protection, and with various privacy laws globally including, but not limited to, the GDPR.
Sabre provides due diligence, compliance, investigative and other risk consultancy services to clients (collectively, “services”). In this respect, these services may act as data processor or as a separate data controller depending on the service being provided and the amount of control Sabre has over the purpose(s) and means of the data processing.
To the extent that Sabre is deemed to be a data controller under Data Privacy Laws, this Policy fulfils our obligation to provide certain information to third parties whose personal data we process in this capacity as required by Article 14 of the GDPR and the Policy requirements set out in any other Data Privacy Laws for processing personal data which has been obtained indirectly.
Who is Collecting Data?
Data will be collected by Sabre.
Data We Collect
Sabre collects the following categories of personal data:
Contact data: We may collect information about data subjects such as name and contact details (email, phone number, etc.) in order to communicate and facilitate the provision of our services with our clients or potential clients. For example, contact details of individuals who work for or on behalf of the clients in order to carry out the clients’ engagement with Sabre.
Services data: Personal data may be provided to us by clients to the extent required to perform the services. Sabre may also acquire personal data from a third party as required to perform services requested by our clients.
Marketing information: We may collect information to respond to inquiries regarding our services or to provide you with information, reports, or updates.
Website visitor information: when you visit our website, we may collect information about your visit such as your IP address and the pages you visited and, when you use our services, we may collect information on how you use those services.
Clients and other third parties who provide personal information to Sabre must do so in compliance with applicable data privacy regulations.
Processing of Personal Data
We collect personal data to offer and administer our services.
The data you provide to us will be processed in accordance with the purposes specified in this Policy, namely:
- To perform the services requested by clients and individuals pursuant to a letter of engagement, statement of work, or similar (where the processing is necessary for our legitimate business interests in conducting and managing our business).
- To provide the products or perform the services requested by clients and individuals using our website or web applications (where the processing is necessary for our legitimate business interests in conducting and managing our business).
- For complying with obligations provided by laws, current regulations and European legislation (e.g. tax regulations) (where processing is based on a legal obligation) or legislation in other jurisdictions that may be applicable.
- For legitimate business purposes to advise you through e-mail, phone call, or post, in the framework of our ordinary commercial relationship, about other products or services similar to the products or services we have provided to you and that we think will be of interest to you (where the processing is necessary for our legitimate business interests).
- For marketing purposes. For example, we may use your information to further discuss your interest in the services and to send you information regarding Sabre such as information about events or services. You can withdraw your consent or opt out of receiving our marketing communications at any time. You can manage your receipt of marketing and non-transactional communications by clicking on the «unsubscribe» link located on the bottom of Sabre’s marketing emails.
- For improving Sabre’s communications with you. Emails sent to you by Sabre may include standard tracking, including open and click activities. Sabre may collect information about your activity as you interact with our email messages and related content.
- For security purposes. For example, we may use your data to protect Sabre and its third parties against security breaches and to prevent fraud and violation of Sabre’s applicable agreements (where the processing is necessary for our legitimate business interests).
Whenever we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will 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 have the right to object to this processing if you wish.
Personal data and the performance of client services
Our clients engage us on a wide range of matters to help them mitigate risk, for example to conduct due diligence on a potential partner, supplier or acquisition target. In some cases, the client’s engagement of Sabre is to fulfil a requirement of EU or member state law or regulation, e.g. the EU Anti-Money Laundering Regulations and the UK Bribery Act 2010. We believe that Sabre has a legitimate interest in processing data to support its clients in these objectives provided that the privacy rights of any affected individuals are not unduly affected.
The personal data we process in the performance of services for and on behalf of our clients includes but is not limited to any information relating to a living individual in which the individual is identified or identifiable, for example, the individual’s name, contact information, education information, work history, directorships, financial information, as well as, where necessary, data concerning criminal convictions and offences and some special categories of information as defined by article 9 of the GDPR or sensitive personal data, as defined by laws of other jurisdictions, for example the Dubai International Financial Centre’s Data Protection Law.
In connection with our services we collect various types of personal data from a variety of different sources, including from: our clients’ public sources such as public records and registers, social media sites, the internet and other third party sources such as industry or country experts
How data is processed
Personal data is processed both manually and electronically in accordance with the above-mentioned purposes and in compliance with current regulations. We permit only authorized Sabre employees and third-party providers to have access to your information. Such employees and third-party providers are appropriately designated and trained to process data only according to the instructions we provide them.
Storage of Personal Data
Sabre will retain personal data for a reasonable period, considering legitimate business needs to capture and retain such information. Information will also be retained for a period necessary to comply with state, local, federal regulations, or country specific regulations and requirements, and in accordance with Sabre’s Records Retention Policy.
Disclosure/Sharing of Personal Data
We only share your personal data with your consent or in accordance with this Policy. We will not otherwise share, sell or distribute any of the information you provide to us except as described in this Policy.
We share personal data among Sabre-controlled affiliates and subsidiaries who act for Sabre for the purposes set out in this Policy.
Sabre may share your information with external third parties, such as vendors, consultants, legal advisors, auditors and other service providers who are performing, advising or assisting with certain services on behalf of Sabre. Such third parties have access to personal data solely for the purposes of performing the services specified in the applicable contract, and not for any other purpose. Sabre requires these third parties to undertake security measures consistent with the protections specified in this Policy.
Sabre may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
If Sabre’s business enters into a joint venture with or is merged with another business entity, your information may be disclosed to our new business partners.
Cross – Border Transfers of Personal Data
Personal information may be transferred, accessed and stored globally as necessary for the uses stated above in accordance with this Policy, and in compliance with local law and regulations.
Data concerning EU data subjects may be transferred to or processed in locations outside of the EU only where one of the following safeguards is in effect:
- Transfers to certain countries which the EU Commission has determined ensures an adequate level of protection (including via participation in the EU-U.S. Privacy Shield)
- Transfers pursuant to standard contractual clauses or contract terms ensuring adequate data protection
- Where required, Sabre will have entered into European Union Model Clause Agreements which allows for the processing of your personal information and for transfers of your personal information.
You have the following rights concerning your data processed by Sabre:
Access: You have the right to access personal information that Sabre holds about you.
Rectification: You have the right to ask us to rectify information Sabre holds about you if it is inaccurate or not complete.
Erasure: You can request that Sabre erase your personal data. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.
Restrict Processing: You have the right to ask Sabre to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future.
Object to processing: Where processing is based on legitimate interests, you have the right to object to Sabre processing your data. Sabre will discontinue processing your data, unless we can demonstrate compelling legitimate grounds for the processing. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.
Portability: Where processing is based on consent or performance of a contract, you have the right to data portability. Sabre must allow you to obtain and reuse your personal data for your own purposes in a safe and secure way without this effecting the usability of your data. This right only applies to personal data that you have provided to Sabre as the Data Controller.
Automated Decision Making
Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved.
Sabre does not make automated decisions using personal data. If automated decisions are to be made, affected persons will be given an opportunity to express their views on the automated decision in question and object to it.
Providing Information to Sabre
If you choose not to provide certain personal information, it may be an impediment to the exchange of information necessary for the execution of the contract or provision of services, and we may not be able to provide you with some services and you may not be able to participate in some of the activities on our website.
Third Party Websites or Other Services