Information that identifies or can be used to identify a living individual is known as “personal data.” All organisations processing personal data must do so fairly, lawfully and in accordance with applicable data protection laws. This includes the obligation for us to tell you how we will use your personal data. We treat all of our legal obligations seriously and take all steps necessary to ensure compliance when storing and processing your personal data.
2.0 Personal Data We May Collect from You
We may collect and process the following personal data about you received directly from you or from your interactions with us for compliance with a legal obligation:
- contact details (such as your name, email address, postal address and telephone number) that you provide by completing forms on the Site, including if you register as a user of the Site, subscribe to any service, upload or submit any material via the Site, request any information;
- your date of birth, country of residence, employment status and source of investment funds.
- your financial circumstances;
- in connection with an account sign-in facility, your log-in and password details;
- details of any transactions made by you through the Site;
- information from surveys that we may, from time to time, run on the Site for research purposes, if you choose to respond to or participate in them;
- technical information that may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and/or
- information about your visit to the Site, which may include the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.
We collect your personal data from you in a number of different ways, including the following:
- if you provide it when interacting and communicating with us (for example when registering for our services);
- if you enter into an agreement for the provision of our services;
- if you make account deposits; and
- when you visit our Site (for example by cookies, your IP address and other browser-generated information).
We record all service calls for quality and training purposes, to enable us to deal effectively with queries and complaints and, in the case of calls where clients place transactions or investment advice is communicated, in order to comply with our regulatory obligations.
You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services. This is because if you have chosen to open an account with us or commissioned investment advice, it is a statutory requirement for us to obtain, and a contractual requirement for you to provide, certain information so that we can verify your identity in order to meet our obligations under the Money Laundering Regulations 2007 and other applicable legislation for the purposes of crime prevention. You are obliged to provide this information in order for us to provide the service and, if you fail to provide it, we will be unable to provide the service in compliance with our legal obligations.
We do not collect, nor do we process “special categories of personal data”. Special category data is personal data which is more sensitive and would include: race; ethnic origin; politics; religion’ trade union membership; genetics; biometrics; health; sex life or sexual orientation for example.
3.0 Cookies and Other Technologies
When you interact with the Site, we try to make that experience simple and meaningful. Our cookies distinguish you from other users of our Site. This helps us provide you with a good experience when you browse our Site and allows us to improve our Site.
4.0 How Do We Use Your Personal Data?
We use your personal data as is necessary and required to do so by law, or on a contractual basis and in our legitimate interest (where such interests are not overridden by your interests or fundamental rights and freedoms) to the extent it is necessary for the proper operation of the Site, our services, our systems, to protect us/our clients, or for the enforcement of our Terms and Conditions.
We may also use your personal data collected from you for the following purposes:
- processing applications made by you, managing your accounts, providing our services, contacting you and servicing our relationship with you;
- administration and accounting, billing and auditing and other legal purposes;
- to carry out checks on you, such as identification verification checks and anti-money laundering checks, for the purposes of meeting our obligations under the Money Laundering Regulations 2007 and any other applicable legislation, for the purposes of crime prevention;
- security and payment verification;
- dealing with any queries, complaints or problems reported by you;
- audit the downloading of data from the Site;
- enabling you to participate in our promotions and competitions;
- enabling you to participate in the interactive features of the Site and ensuring content from our Site is presented in the most effective manner for you and your computer or device;
- notifying you about changes to our service and/or the terms on which the services are provided;
- generating statistics on our users, such as the popularity of certain of our services and about the “traffic” visiting our websites. Before doing this your personal data is anonymised and you are not personally identifiable; and
We may also use your personal data to provide you with information about our goods or services we feel may interest you only if you have given your consent to receiving marketing material from us at the point we collected your information.
5.0 Our Promotional Updates and Communications
Where permitted in our legitimate interest where required by law (as applicable), we will use your personal information for marketing analysis.
With your prior consent we will provide you with promotional update communications by email.
If you are an existing client, we will only contact you by e-mail about goods and services similar to those which were the subject of a previous agreement with you and if you have not opted out of receiving such communications.
If you do not want us to use your data in this way, you can record your preference when you initially provide us with your details. Opting out from such communications will not prevent us from communicating with you as necessary to manage your account.
6.0 Who Is Your Personal Data Shared With?
You acknowledge that we may disclose your personal data to:
- third parties which we use to carry out the checks that we need to carry out on you, such as identification verification and anti-money laundering;
- the custodian for the purpose of managing your accounts and providing our services;
We may disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or cyber crime or to protect the Site or the rights, property or personal safety of any person.
7.0 Automated Decisions
As part of our account-opening process we will carry out automated checks using your personal data, such as your name, postal address, date of birth, telephone numbers and employment status. These checks include identification verification checks and financial crime checks and involve our obtaining information from identity verification agencies and any records held by financial crime prevention agencies, the Electoral Register and providers of utility services.
We need to carry out these checks in order to meet our legal obligations under the Money Laundering Regulations 2007 and any other applicable legislation.
8.0 External links
The Site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
9.0 Security and Safeguarding Your Personal Data
We place great importance on the security of all personal information associated with our users and clients. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.
You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the Site whilst it is in transit over the internet and any such submission is at your own risk.
You can also help to protect your personal data, by following the guidelines below:
- choose a password that you will be able to remember but that would be hard for someone to guess. It is required to contain both upper and lower case letters, a number and a symbol. We recommend that you change it regularly and if you need to write it down, always keep it in a safe place;
- make sure that no-one can see the details you are entering when you log-in;
- if other people have access to your computer, remember to close your browser each time you log-off and end your session and, if possible, clear any history of the websites you have visited and that your browser may have saved or “cached”; and
- never disclose your account details to anyone.
10.0 Data Retention and Storage of your Personal Data
Your personal information which we collect is sent to and stored on secure servers currently located in the Republic of Ireland and/or the Netherlands. Such storage is necessary in order to process the information. Personal information submitted may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above (see Information Sharing), which may be situated outside the European Economic Area (EEA) and may be processed by staff operating outside the EEA. The countries concerned may not have similar data protection laws to the EEA. Where we transfer your personal information we will take all reasonable steps to ensure that your privacy rights continue to be protected. By using the Site, you agree to this storing, processing and/or transfer.
11.0 Your rights
You have the following rights (unless exemptions apply), which can be exercised by contacting our Data Protection Officer at firstname.lastname@example.org at any time.
- to ask us not to process your personal data for marketing purposes;
- to access personal information held about you and to obtain a copy of it;
- to prevent any processing of a record of personal data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual;
- to obtain the rectification or completion of records of personal data which are inaccurate or incomplete;
- to restrict or object to the processing of your personal data and to request its erasure. We will not be able to erase personal data where we have a legal obligation to retain such data for example the results of identity verification checks;
- in certain circumstances, to receive your personal data, which you have provided to us, in a structured, commonly-used and machine readable format and the right to transmit that data to another data controller without hindrance, or to have that personal data transmitted to another data controller, where technically feasible; and
- to lodge a complaint about the way in which your personal data is being shared with a supervisory authority.
Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time by contacting us at email@example.com.
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority. The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
12.0 Contacting Us
The following is a list of personal data which is collected for the purposes of opening an account with us:
- Phone number
- Email address
- Date of Birth
- Country of residence
- Employment status
All of the above are legally required. This list is correct as of 21st December 2022 and may be subject to change.
The following is a list of processors of personal information which we have engaged to provide services to clients:
- Identity checks and Anti Money Laundering – Experian and Equifax
The above list is correct as of 21st December 2022 and may be subject to change.