Introduction

 

This policy explains how we process your personal data as a data controller.

 

What are your rights?

You have the following rights, although these rights may be limited in some circumstances:

 

• You can ask us to send a copy of your data to you or someone else

• You can ask us to restrict, stop processing, or delete your data

• You can object to our processing of your data

• You can object to use of your personal data for direct marketing

• You can ask us to correct inaccuracies

 

If we rely on consent to process data, or send direct marketing, you can withdraw consent by email to the address below.

 

Your Personal Data and How We Use It

 

Your personal data

On-boarding and anti-money laundering data including, but not limited to:

 

• Name, job title, your relationship with your business or company, contact address, telephone and email.

• Passport, driving licence or other ID, proof of address (such as a bill).

• Financial information, including about the source of your funds.

• Company structure

 

How long we keep it

6 years after our business relationship with you ends

 

How we use it

We use this information to on-board you as a client and comply with KYC or anti-money laundering regulation.

 

Legal basis for this processing

 

• Compliance with the law.

• Entering or performing contracts with you.

 

More information

You are required to provide this information in order to use our services.

 

Sources

We generally collect this data from you, however we may also use third parties to verify this information.
Third party identity verification services, currently limited to Smartsearch (using Dow Jones, Equifax and Experian) and Thirdfort (using Experian, Onfido, LexisNexis, emailage, Truelayer and Comply Advantage).

 

Recipients

We may share this information with relevant authorities as legally required.

 

Your personal data

 

Website analytics, including the following information (which may be associated with a unique identifier):

 

• browser type and settings, IP address, approximate location, access logs, device type and settings, operating system, and other information provided by your browser;

• the use you make of our website, including which pages you visit, which links you click, the websites you have come from, how long you spend on our website and how you interact with it.

 

How long we keep it

After 26 months underlying data is deleted but we may retain some anonymous, aggregated statistics generated from that data.

 

How we use it

Where we have your consent, we use a third party service (Google Analytics) to collect information about visitors to our website, to understand how many people visit the website, where they come from, and how they interact with it, and to help us improve the website.

 

Legal basis for this processing

 

• Consent

 

More information

You can find out more about how Google uses data by clicking here.

 

Sources

We use Google’s services to collect this data from you when you visit our website.

 

Recipients

Google in the USA collects and processes this information on our behalf.

 

Your personal data

Service and enquiry information including:

 

• Information you send us as part of enquiries;

• Any personal information you provide to us in order for us to provide our services to you.

 

How long we keep it

For as long as we are dealing with your enquiries or providing services to you, and for 7 years thereafter.

 

How we use it

We process this information: (a) to respond to your enquiries; (b) to provide our services; (c) to understand how our clients use our services in order to improve them; and (d) to market our services (such as by writing to about new services).

 

Legal basis for this processing

 

• (a), (c) and (d): Our legitimate interests of marketing and improving our services.

• (b): entering or performing contracts with you.

 

More information

You may be required to provide us with certain information in order for us to provide our services to you.

 

Sources

We collect this data from you.

 

Recipients

We may use third party email marketing systems, such as Mailchimp, to send you information about our services.

 

Where explicit retention periods are not described above, we hold data for as long as necessary bearing in mind the purpose for which it was collected. At the end of the retention period, we assess whether it is necessary to continue to retain information to achieve the purposes for which it was collected. To determine appropriate retention periods, we consider the amount, nature, and sensitivity of the data, the potential risk of unauthorised access, and legal requirements.

 

Cookies, Analytics, and Similar Technologies

 

Cookies, pixels and other technologies store and access data on your device to help websites and apps work.  This table explains their purpose, how long they last, and who else can access their data.  We get your consent to use them unless they’re essential for our sites, apps or services. Most browsers allow control over cookies, for more information: Google Chrome | Microsoft Edge | Mozilla Firefox | Microsoft Internet Explorer | Opera | Apple Safari.

 

Cookie/data

_ga, _gat, _gid

 

Duration

Up to 24 months

 

Purpose

To collect information about how visitors interact with our website & generate reports based to identify problems, understand how visitors use our website, and improve it.

 

Access

We use Google Analytics to set these cookies.

You can find out more about how Google uses data by clicking here.

You can opt-out here: Google Analytics.

 

Storage, Transfers, and Disclosure

 

Storage & Transfers

Save where indicated otherwise in this policy, your personal data is securely stored in the UK. Where we use data processors outside the UK and European Economic Area, and transfer personal data to a country which does not provide an adequate level of protection, we use contracts which give personal data the same protection it has in Europe and the UK. For more information drop us a line using the contact details at the end of this policy.

 

Disclosure

Other than as set out above, we may disclose your personal data:

 

• Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).

• With members of our corporate group, suppliers and subcontractors, as necessary for the purposes set out in this policy.

• If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.

Contact Us

 

Write to us at: [email protected].

If we can’t resolve your issue, you can also get in touch with the Information Commissioner’s Office: https://ico.org.uk/concerns (or if you live in a European country other than the UK, you can submit a complaint to the supervisory authority in your country).