Article 5 of the GDPR States that Personal Data must be processed lawfully fairly and in a transparent manner. In line with the GDPR changes we are updating our Privacy Notice so you can better understand why and how we collect, process and destroy your data. We are committed to protecting and respecting your privacy. This policy (together with the Terms and Conditions and any other documents referred to in it) sets out the legal basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
We may control, process and use your Personal Data, which may include names, postal addresses, email addresses, telephone numbers or any other Personal Data that you provide to us. We may also, in appropriate cases and to the extent permitted by law, control, process and use certain special categories of Personal Data which are more sensitive in nature (e.g. when undertaking “Know Your Customer” (KYC) or anti-money laundering (AML) checks, we may collect information about any criminal conviction offence that you or the directors of any company might have committed).
We will keep your Personal Data for no longer than reasonably necessary. We will retain your personal information in accordance with legal and regulatory requirements as set out in our Data retention policy.
Where we may seek to further process your data other than for the original purpose for which it was collected, the Firm shall only further process such data where the new Processing is compatible with the original purpose.
We take your privacy seriously and take every reasonable measure and precaution to protect and secure your Personal Data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including, without limitation, encryptions.
Owing to the products and services that we offer, such as performance of KYC and other background checks, we sometimes need to process special categories of data which are deemed to be more sensitive in nature. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so. Where we rely on your consent for Processing Special Categories Data, we will obtain your explicit consent through electronic means.
We occasionally process your personal information under the Legitimate Interests’ legal basis. Where this is the case, we have carried out a Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own and that such interests are proportionate and appropriate such as for the purposes of HR, marketing and day-to-day operations.
When sending marketing materials to customers, we may have the option to rely on your consent or legitimate interest. We only use legitimate interests for marketing if we have assessed that the information being sent is beneficial to the customer, and have weighed our interests against your own and there is little to no risk posed, the method and content is non-intrusive, and the material being sent is something you would usually expect to receive.