SPAIN CHECKS 0284-6 - ID NUMBER 100471 (TO BE DISCONTINUED FROM 25 OCTOBER 2018)

• Supplier hosts the Supplier Data
• Supplier is a Sub-processor of Client Information
• Client Information includes Personal Data
• The Sub-processor is located in Spain
• The Sub-processor is based within the EEA
• The Supplier has not agreed to equivalent GDPR provisions
• This Dataset is being discontinued as the Supplier Data no longer meets GBG’s due diligence standards

This Dataset will be discontinued on 25 October 2018 – please contact your GBG Account Manager to switch to our replacement service.

The Supplier Data that GBG uses to provide the Spain Checks is supplied by GBG’s Spanish Data Supplier. Use of this Supplier Data is subject to the following provisions:

1. DATA PROTECTION AND COMPLIANCE WITH RELEVANT LAWS
1.1. The Supplier Data used to provide this element of the Service is hosted by the Data Supplier. In order to perform the Services, the Data Supplier shall act as Sub-processor of your Client Information (including any Personal Data supplied) for the sole purpose of delivering this element of the Service. The End User authorises GBG to appoint the Data Supplier as Sub-Processor for the purposes specified in this clause 1.1.
1.2. The Data Supplier is based in Spain, which is located within the EEA. On this basis, Personal Data is not transferred outside of the EEA in order to provide End Users with access to this element of the Service.
1.3. The End User acknowledges and accepts that due diligence has indicated that the Supplier Data used to provide this element of the Service has not been collected in accordance with the new GDPR regulations. In addition, the Data Supplier as Sub-processor may not be able to demonstrate sufficient guarantees and appropriate technical and organisational measures, which fully meet the requirements of GDPR.
1.4. As stated in previous communications, this service will be discontinued on 25 October 2018. Until such time GBG shall continue to supply this element of the Service to End Users who wish to receive it to avoid disruption and to enable End Users to continue to meet their regulatory requirements and to perform AML and KYC checks. The End User is solely responsible for any risk or liability which arises as a result of its decision to share Personal Data with the Data Supplier.
1.5. If you would prefer not to use the Supplier Data, please contact your GBG Account Manager who will support you to make the required changes to your Services.