Updated: March 2019
When you visit and use the Site, we may, through the Site, automatically collect and log information about you, including web usage data. This information informs us about how visitors use and navigate our Site. We may also collect information that you provide to us. This includes information provided by filling in forms or otherwise communicating with us. We may collect personal information, including your name, e-mail address, address, phone number, and other information. We may collect personal information from you by various means, including asking questions on this Site and permitting you to communicate directly with us via e-mail.
You have the ability to accept or decline cookies by modifying the settings in your browser. Details of how this can be achieved can be found in your browser’s Tools menu. However you may find that some parts of the Site will not function properly if you decline cookies.
We may use various other web tools such as web beacons or other technologies that are sent to and stored on a user’s hard drive to help us monitor, customize and enhance a user’s experience on the Site.
How We Use and Share Information Collected
We and our affiliates may use and store the personal information collected for the purpose for which it was provided, for marketing, research or other business purposes, and to improve the content and efficiency of the Site. These purposes include: verifying your identity as part of our client on-boarding process; detecting and preventing fraud and money laundering; managing and administering clients’ accounts holdings; and providing our clients with information, products or services they may request from us.
We are entitled to use your personal data in these ways in order to perform a contract with you, or because we have legal and regulatory obligations that we have to discharge, including fraud prevention, or when we may need to establish, exercise or defend our legal rights or for the purpose of legal proceedings. The use of your personal data may also be necessary to effectively managing our client relationships.
We may also use and share the information you provide with our affiliates and partners for other business purposes. We may use third party service providers in connection with our Site and make personal information available to them to the extent necessary for them to provide services to us. We may use and share with others aggregated and/or anonymous information that we have collected based on web usage data or statistical information that we have compiled about our users. We may disclose personal information to comply with valid legal process such as a search warrant, subpoena, or court order, if we find that a user’s actions violate our policies, or to protect our rights and property, or to our affiliates or successors to the relevant portions of our business.
If you do not want us to use or share your personal information with others, please do not submit information to us.
Security, Storage and Transfer of Personal Information
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our servers we believe to be secure behind firewalls.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask that you NOT share your password with anyone.
While we have measures in place to help prevent unauthorized access and maintain data security, no transmission of data over the Internet is guaranteed to be completely secure and we cannot guarantee the security of any information you provide to us. Any transmission of personal information is at your own risk.
We may process personal information in, and transfer personal information to, countries that may not guarantee the same level of protection for personal information as the country in which you reside.
Personal information will also be processed by staff that work for us and operate outside the European Economic Area. This includes staff engaged in, among other things, the provision of administration and support services. All such staff are subject to appropriate confidentiality and security obligations.
We are not responsible for circumvention of any privacy settings or security measures contained on the Site. The Site may contain links to websites maintained by third parties. Please be aware that we are not responsible for the privacy practices of these other websites. We will only transfer personal information to third party service providers if they put in place measures in respect of information security that we believe to be adequate.
Reviewing Your Information and Rights in Relation to Personal Information
You have certain rights in relation to your personal information, including the right to be informed about the collection and use of your personal information, as outlined in this Notice.
These include, where certain conditions are met:
- the right to request access to the personal information we hold about you;
- the right to have inaccurate information about you amended or updated;
- the right to object to processing of personal information about you;
- the right to withdraw consent at any time (where relevant);
- the right to have personal information about you erased or to restrict processing in certain limited situations;
- the right to data portability and to request the transmission of personal information about you to another organization;
- the right to object to automated decision making that materially impacts you, direct marketing, and processing for research or statistical purposes; and
- the right to lodge complaints with applicable data supervisory authorities.
You may make requests in respect of your personal information, including to review and update the personal information we have collected about you, by contacting us. You should notify us if any of your personal information changes or if they become aware of any inaccuracies in the personal information we hold about them. To protect your privacy and security, we may take reasonable steps to verify your identity before we disclose or make any corrections to such information. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.