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 Policy applies to you if you are an individual client, or their authorised person. It applies to you if you are a person associated with a corporate client (such as a director, beneficial owner or authorised signatory). This Policy also applies to prospective clients and persons who have asked to receive our promotional or other material.
In the United Kingdom we are bound by the Data Protection Principles contained in the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
The Data Protection Principles are as follows:
Personal data collected must be:
This Policy will be reviewed periodically to take account of changes to our operations or practices and, further, to make sure it remains appropriate to any changes in law, technology and the business environment. You should check this page from time to time to ensure that you are aware of any changes. Any information held will be governed by our most current Policy.
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).
If you visit our website, contact us about employment, or to enquire about our products and services or are a customer making contact with us via our website or by telephone or email, we may collect, store, use and transfer different kinds of personal data about you. We may collect and process the following data about you:
Where we need to collect data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are attempting or intending to enter into with you (for example, to provide you with our services or open an account for you). In this case we may have to suspend or cancel a service or agreement with you, but we will notify you of this at the time.
We use information held about you in the following ways:
We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by email.
Depending on the products and services concerned and the relevant restrictions on sensitive data, personal information may be disclosed to:
You have a number of legal rights in relation to the personal information that we hold about you. These rights include:
You can find out more information about your rights by contacting the Information Commissioner’s Office, or by searching their website at www.ico.org.uk.
Please note that the application of these rights varies according to the legal basis used to process your data. In certain circumstances we are required to retain copies of information we hold about you by other regulations. In this instance we will not be able to erase or modify the data.
Our security measures are designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorised manner, altered or disclosed. We limit access of information only to those relevant employees or partners that need to know the information in order to enable the carrying out of the Agreement between us. We do not hold or store Credit/Debit card data.
We have procedures in place to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally obliged to do so.
We will not keep your personal information for any longer than is necessary to fulfil the purposes we collected it for or for the purpose of any legal, accounting or regulatory requirements. We will generally retain our clients’ data for a period of up to 7 years after a contract or agreement has ended.
While we will use all reasonable efforts to safeguard our clients’ personal information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data transferred from you, or to you via the internet.
Your use of the Website will signify that you agree to any such changes. Owing to the global nature of the Internet infrastructure, the information you provide may be transferred in transit to countries outside the European Economic Area. We may transfer your personal information outside the European Economic Area (“EEA”) to other of our group companies as well as processors who are engaged on our behalf. To the extent we transfer your information outside the EEA, we will ensure that the transfer is lawful and that there are appropriate security arrangements. In order to transfer personal information to third parties in territories where applicable legislation may not be adequate, we will enter into arrangements with such third parties to ensure appropriate and suitable measures based on standard contractual terms and conditions adopted by the European Commission.
Where we make transfers to third parties in the US, we may in some cases rely on applicable standard contractual clauses, binding corporate rules or any other equivalent applicable arrangements.
We are not responsible for the privacy policies and practices of other websites even if you accessed a third-party website using links from our Website. We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have concerns or questions.
If you have any questions regarding this Policy, wish to access or change your information or have a complaint, or if you have any questions about security on our Website, you may email us at email@example.com
You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO. Should you have any concerns please email the Security Officer at firstname.lastname@example.org in the first instance.
We're here to help and answer any questions you might have. We look forward to hearing from you.
UK: + 44 (0) 204 558 2300
US : + 1 570 710 3641 (customers & sales)