Most Recently Revised: 12.22.2020
This privacy notice (the “Notice”) describes how we collect and use personal data about you in accordance with applicable privacy and data protection laws.
Our Commitment to Your Privacy: We have a standing policy of protecting the confidentiality and security of information we collect about our clients. We do not share personal information about you outside of our affiliates, except for the specific purposes described below, in accordance with all applicable laws. This Notice describes the personal information we may gather and the circumstances under which we may share it.
Personal data, or personal information, includes information such as your name, address, email address, telephone number(s) and date of birth, from which you can be directly or indirectly personally identified, and includes information such as identification, tax references and account numbers. This personal information may relate to your finances, employment, avocations or other personal characteristics, as well as transactions and interactions with or through us or with others.
Personal information we collect: We collect personal information about you in connection with providing our services to you. This information may include your name, date of birth, address and other contact details, national identification or social security number, identity documents such as passports and other “know your client” documents and may also include other information such as your:
Educational, nationality and professional background information;
Transaction history; and
How We Gather Personal Information: We obtain personal information directly from you, when you apply for, access and use our and our business associates’ financial products and services - whether in person, by telephone or electronically. We may verify this personal information or collect additional personal information from third parties, including consumer reporting agencies or other public sources. We may also obtain some of your information indirectly, from a variety of sources, such as your joint account holder(s), and / or our service providers, such as vendors providing anti-money laundering and sanctions checking databases.
Why We Collect and How We Use Personal Information: We limit the collection and use of personal information to the minimum we require to deliver superior service to you. Such service includes advising you about our products, services and other opportunities, maintaining your accounts with us, processing transactions requested by you or other persons authorized by you, and administering our business. We also collect your personal information in order to comply with statutory and obligations and other tax and regulatory requirements to which we may be subject, including anti-money laundering requirements.
Your personal data may be processed by us, or our affiliates, agents, employees, delegates or sub- contractors, for the following purposes:
for the purposes of performing the contract you have entered into with us, including to facilitate the opening of your account with us, the management and administration of your holdings with us or any related account on an ongoing basis which are necessary for the performance of your contract with us;
for compliance with our legal obligations, including anti-money laundering checks, compliance with applicable tax and regulatory reporting obligations and related actions which we consider appropriate to meet any legal obligations imposed on us,
to pursue our legitimate interests in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis;
where our use is for a legitimate purpose of our group, including:
for day to day operational and business purposes, including board and group reporting and management purposes;
taking advice from our external legal and other advisors;
to help us improve our services and systems, and to improve your experience on our web and online services;
to undertake market research, statistical and product development analyses;
marketing purposes; and
to monitor and record calls for quality, business analysis, training and related purposes;
where necessary to establish, exercise or defend our legal rights or for the purpose of legal proceedings; and
for such other purposes as were notified to you at the time you provide the information to us.
How We Protect Personal Information: Our employees, agents, contractors and representatives acting on our behalf are required to protect the confidentiality of personal information and to comply with our established policies. We limit access to your personal information to only those employees, agents and contractors who are authorized to access your data when there is an appropriate reason to do so, such as to administer or offer our products or services. We also maintain physical, electronic and procedural safeguards to protect your personal information, including measures preventing your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed, and which comply with all applicable laws and regulations. Employees who violate our company policies relating to data protection procedure will be subject to disciplinary process.
How Long We Retain Personal Information. We will only retain your personal information for as long as necessary to fulfil the purpose for which it was collected, or for additional periods where legal/regulatory obligations mandate that we retain your personal information or where it is necessary for the purposes of our other legitimate interests. The applicable retention period will depend on various factors, such as any legal or regulatory requirements to maintain records to which we or our service providers are subject.
Disclosure of Personal Information: We may disclose your personal information to certain recipients, as detailed below:
Other affiliates: We may share your personal information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. If you are a new client and are not resident in the European Union, we can begin sharing your personal information with our affiliates for direct marketing purposes 30 days from the date of this Notice. We may also disclose personal information about your transactions and experiences with us to our affiliates for their everyday business purposes. We do not share your personal information with non-affiliates for them to market their own services to you. For example, we do not sell customer lists and we will not sell your name to a catalogue company or telemarketer. Moreover, it is our policy to require all third parties that are to receive any personal information to sign confidentiality agreements.
Transfers to service providers: We may disclose personal information to other companies or third party service providers (i) to enable them to provide business services for us, such as performing computer related or data maintenance or processing services for us, (ii) to facilitate the processing of transactions requested by you, (iii) to assist us in offering our or other companies’ products and services to you, or (iv) for reporting purposes. When such third party processors process personal data on our behalf, we enter into agreements with them to ensure that they process your personal data in accordance with applicable law. You can ask for further information in relation to these third party service providers by contacting us.
Disclosures to third parties: We may share your personal data with other third parties such as governmental agencies and regulators (e.g., tax authorities), law enforcement, social insurance carriers and to external advisors acting as controllers (e.g., attorneys, accountants, auditors or other professional advisors) or to any (or any proposed) assignee, transferee, or successor in title to the whole or any relevant part of our business, and their respective officers, employees, agents and advisers. Such transfers are made in order to comply with our legal obligations, including the prevention of fraud or other financial crime, and for our legitimate interests or those of a third party to ensure the effective operation of our business. You can ask for further information in relation to these third parties by contacting us.
Other disclosures: We may share your personal data if the disclosure is required by law or regulation, or court or administrative order having force of law, or is required to be made to any of our regulators.
You may contact us on +1 212 293 4040 at any time to limit our sharing of your personal information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. If you are resident in the US, US state laws may give you additional rights to limit sharing. In any case where we share your personal data with a third party data controller (including, as appropriate, counterparties to transactions on your account), the use by that third party of the personal data will be subject to the third party’s own privacy policies.
Our Website: When you visit our website, you are accepting the website terms and conditions, as well as the terms of this Notice. We are not responsible for the content or privacy practices of any websites that may link to or be linked from our website. Any external links to other websites are clearly identified as such.
Additional Information for Residents of the European Economic Area (EEA): To the extent that you are resident in the European Union, we will also comply with the following additional requirements under the General Data Protection Regulation (GDPR) when processing your personal information:
We process personal information in the United States and will, from time to time, send some of your personal data to recipients based in other countries that are located outside the EEA. Your PII may be transferred, stored and/or otherwise processed in a country other than the one in which your PII is collected. As these countries are not within the EEA, this may mean that such countries are not deemed to provide an adequate level of protection for your personal information. When transferring your PII to the US or other countries, we have implemented procedures designed to ensure that appropriate safeguards based on risk are in place to protect the PII regardless of where it is being transferred.
To the extent your personal information is transferred to countries outside of the EEA, such transfers will only be made in accordance with applicable data privacy laws. For further information about the safeguards/derogations used, please contact: firstname.lastname@example.org.
You have certain rights under the GDPR in respect of the personal information we hold and which you may exercise. These rights are:
to request access to your personal information;
to request rectification of inaccurate or incomplete personal information;
to request erasure of your personal information;
to restrict the processing of your personal information;
to object to our use of your personal information;
where relevant, to request the portability of your personal information;
where you have given consent to the processing of your personal information, to withdraw your consent; and
to lodge a complaint with the competent supervisory authority.
Your rights will in each case be subject to the restrictions set out in applicable data protection laws, including the General Data Protection Regulation. Further information on these rights, and the circumstances in which they may arise in connection with our processing of your personal data, can be obtained by contacting us. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us. If you have any grievance, issue or problem in respect of our handling or processing of your personal data in any way, you have the right to lodge a complaint with your local data protection supervisory authority, details of which can be found at https://edpb.europa.eu/about-edpb/board/members_en
We may use your personal information to contact you with marketing or promotional materials via our website, but only where you have given us permission to do so. You may opt out of receiving any, or all, of these communications from us by contacting us at any time at email@example.com.
Automated Decision Making
We do not use automated processing, including profiling, to make decisions that will have either legal or material effects on the individuals from whom we collect and process personal information.
Additional Information for Residents of California: To the extent that you are resident of California, we will also comply with the following additional requirements under the California Consumer Protection Act (CCPA) when processing your personal information:
You have certain rights under the CCPA in respect of the personal information we hold and which you may exercise. These rights are:
Request that we disclose, free of charge, the categories and specifics of the PII we collect about California residents, the sources from which the PII was collected (and/or, if applicable, sell or otherwise disclose to a third party), and the business purpose for collecting PII to request rectification of inaccurate or incomplete personal information;
Choose to opt-out of the sale of personal information. Currently, however, we do not sell personal information; and
Request that we delete the PII we have collected. Following our verification of the request, we will comply with the request and delete any or all the PII in our possession that we collected from the California resident and/or any or all such PII in the possession of our service providers, unless otherwise restricted by law or regulation.
Your rights will in each case be subject to the restrictions set out in the CCPA. Further information on these rights, and the circumstances in which they may arise in connection with our processing of your personal data, can be obtained by contacting us.
Non-Discrimination for Exercising Your Rights.
We follow the requirements of California Civil Code §1798.125 and will not discriminate against any consumer who exercises the rights set forth in this privacy notice.
Verifying Your Identity
If you choose to contact us with a request, you will need to provide us with identifying information that matches the PII we currently have about you.
You have the right to appoint an authorized agent to exercise your rights on your behalf. If you would like to do so, please contact firstname.lastname@example.org.
For consumers with disabilities who need to access this policy in an alternative format, please contact email@example.com.
Updates to Personal Information: We will use reasonable efforts to keep your personal information up to date. However, you will need to notify us without undue delay in the event of any change in your personal circumstances, or if you believe any of the information we hold about you is inaccurate or incorrect, so that we can keep the personal information up to date.
This privacy notice was last revised and posted on December 22, 2020.
Further Information: We reserve the right to change this Notice at any time. We will not explicitly notify you of any changes. Instead, you are advised to review this Notice periodically for any changes. Changes to this Notice are effective when they are posted on our website.
Contact Us: In order to make a query, raise a concern, avail of your data protection rights or for any other reason related to this privacy notice, please contact us using the below contact details:
Telephone +1 (212) 293-4040 (for CCPA related inquiries, please call +1 (877) 313-0155)
Address 499 Park Ave, 17th Fl New York, NY 1022