Your use of the Site will be subject to these terms and by using the Site you agree to be bound by them. The services we offer to clients are provided subject to our General Terms and Conditions.
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, including the Data Protection Law. 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.
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:
We collect your personal data from you in a number of different ways, including the following:
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.
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.
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:
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.
In order to monitor and analyse our business we, or a third party acting for us, may use information in your client and account records to assess client satisfaction and for market research. If you do not wish to be contacted to participate in client satisfaction or marketing surveys, you can opt out by asking us and our third parties to stop contacting you by writing to us or by opting out by SMS or email as specified in the relevant communication. This request will not affect the running of your existing account or the services you request from us, in respect of which we will still process your personal data.
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 may also provide you with promotional update communications by email, secure message, phone or SMS about our products/services.
If you are an existing client, we will only contact you by e-mail, secure message via the website or SMS with information 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 are a new client we will contact you by email, secure message via the website and SMS only if you have consented to this.
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, contact us in writing at any time to object to marketing or opt out to receiving marketing by SMS or email as specified in the relevant marketing communication at any time. Opting out from such communications will not prevent us from communicating with you as necessary to manage your account.
You acknowledge that we may disclose your personal data to:
If we transfer your data to a service provider outside of the EEA, we ensure that appropriate controls are in place to protect your data in accordance with applicable data protection laws, such as:
For a copy of the details of the transfers of, or access to, personal data outside of the EEA and the safeguards that we have in place when transferring, or allowing access to, your personal data outside of the European Economic Area, (and for a copy of the safeguards, where applicable) please contact us via email at email@example.com.
We may disclose aggregate statistics about visitors to the Site and clients in order to describe our services to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information.
In the event that we undergo re-organisation or are sold to a third party, you agree that any personal data we hold about you may be disclosed under appropriate confidentiality terms to our advisers and any prospective purchasers’ advisers, and will be transferred to that re-organised entity or the new owners.
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.
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.
We will also carry out suitability checks regarding your choice of investment account. Parameters will include your financial circumstances and investment time horizon. These checks may indicate that an account is unsuitable for you. If our automated processes indicate that a portfolio may be unsuitable then you will be contacted by a member of the Client Service or Advisory team to discuss your choices and allow you to provide further information which may result in the decision changing.
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.
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:
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.
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.
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.
The following is a list of personal data which is collected for the purposes of opening an account with us:
All of the above are legally required.
This list is correct as of 23rd January 2020 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:
The above list is correct as of 23rd January 2020 and may be subject to change.