VERFIDES PRIVACY NOTICE
This Privacy Notice explains how we collect, use and share your personal data, and your rights in relation to the personal data we hold. This Privacy Notice is effective from 25 May 2018.
This Privacy Notice supersedes any previous Privacy Notice or equivalent which you may have seen prior to this Privacy Notice.
Who we are
By ‘we’ we mean Verfides of 5th Floor, 86 Jermyn Street, SW1Y 6AW, London, United Kingdom, or any other member of the Verfides Group. We are the ‘data controller’ for the information in this notice. This means we are responsible for deciding how we can use your information.
What information do we collect?
Personal data we collect about you may include the following:
- your name and contact information such as your home and business address, job title, email address, telephone number and skype contact details
- biographical information which may confirm your identity including your date of birth, tax identification number, your passport number or national identity card details, country of residence, domicile or your nationality/citizenship
- Personal financial details such as income, expenditure, assets, liabilities, sources of wealth and funds, as well as your bank account details or details about other financial products you hold
- information about your business interests, employment, education and family or personal circumstances
We collect information about you from different places, including:
- directly from you
- from a third party acting on your behalf (e.g. an Intermediary or Authorised Person)
- from other Verfides Group companies
- from publicly available sources (such as the internet)
We only collect your information in line with relevant regulations and laws as these may relate to any services you receive from us or have received in the past.
You are responsible for making sure you give us accurate and up-to-date information. If you provide information for another person, you will need to tell them how to find this Privacy Notice and make sure they agree to us using their information for the purposes set out in it.
How do we use your information?
We will use it to provide any services you have requested as well as for the following purposes:
- to confirm your identity and address
- to prepare a proposal for you regarding the services we offer
- to provide you with the services as set out in our Letter of Engagement and Terms of Business
- to improve our services
- to disclose it to third parties where necessary in order for us to provide you with requested services (such as banks, agents, local tax authorities etc.)
- to offer you other services we believe may benefit you unless you ask us not to
- for any other purpose for which you provide us with your personal data.
We will only use your information where we are allowed to by law, for example when carrying out an agreement with you, fulfilling legal obligations or, where you agree to it, because we have a legitimate business interest in doing so.
We may use automated systems to carry out fraud, terrorist financing and money laundering checks.
We may send you marketing communications about services we provide as well as newsletters which may be of interest to you.
We may communicate this to you by post, telephone, email or other digital channels.
If you wish to withdraw your consent to receiving these communications at any time, please contact us by email to firstname.lastname@example.org or by post to Data Protection Officer, Verfides, 5th Floor, 86 Jermyn Street, London, SW1Y 6AW or Data Protection Officer, Verfides (Ireland) Limited, 68 Fitzwilliam Square Dublin 2, D02 W328 Ireland.
Who can we share your information with?
We only share your information with others in connection with the services you have asked us to provide or otherwise with your specific consent. In this respect we may share your information with regulators, insurers, banks, auditors, brokers, advisers and agents as well as data storage companies, credit referencing and fraud prevention agencies and with debt collection agencies where it is necessary to recover money you owe us.
How long will we keep your information?
We will keep your information for as long as you have a relationship with us and, after the relationship ends, we will keep it where we may need it for our legitimate purposes. For example, to help us respond to queries or complaints, fighting fraud and financial crime and responding to requests from regulators relevant to the provision of services to you.
In most cases we will retain your personal data for a period of seven years after the termination of our contractual or other relationship with you, in order that we can comply with specific legal obligations.
Transferring your information overseas
Your information may be transferred or stored in countries outside the European Economic Area, including some that might not have laws that provide the same level of protection of personal information. When we do this, we will ensure your data has an appropriate level of protection.
You have a number of rights relating to the information we hold about you, including to see what information we hold about you, to ask us to share it with another party, to ask us to update incorrect or incomplete details and to object to or restrict our processing of your data.
A subject access request should be submitted to email@example.com
If you are not satisfied with how we are processing your personal data, you can make a complaint in the UK to the Information Commissioner’s Office (‘ICO’) (see: https://ico.org.uk/concerns/) and in the Republic of Ireland to the Data Protection Commissioner (see: https://www.dataprotection.ie/docs/Making-a-Complaint-to-the-Data-Protection-Commissioner/r/18.htm)
Changes to our privacy notice
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to firstname.lastname@example.org or by post to Data Protection Officer, Verfides, 5th Floor, 86 Jermyn Street, London, SW1Y 6AW or Data Protection Officer, Verfides (Ireland) Limited, 68 Fitzwilliam Square Dublin 2, D02 W328 Ireland.