We(Nash & Co Capital Limited)(also referred to as “we”, “us”, or “our”) are a registered company in England (Company no. 04001724).Our registered address is 40 Craven Street, London, England, WC2N 5NG.
The PURPOSE OF THIS NOTICE
This Notice is designed to help you understand what kind of information we collect in connection with our products and services and how we will process and use this information. In the course of providing you with products and services we will collect and process information that is commonly known as personal data.
This Notice describes how we collect, use, share, retain and safeguard personal data.
This Notice sets out your individual rights, we explain these later in the Notice but in summary these rights include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data.
WHAT IS PERSONAL DATA?
Personal data is information relating to an identified or identifiable natural person. Examples include an individual’s name, age, address, date of birth, gender and contact details.
Personal data may contain information which is known as special categories of personal data. This may be information relating to an individual’s health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and bio metric data, or data relating to sexual orientation.
Personal data may also contain data relating to criminal convictions and offenses.
For the purposes of safeguarding and processing criminal conviction and offense data responsibly, this data is treated in the same manner as special categories of personal data, where we are legally required to comply with specific data processing requirements.
PERSONAL DATA WE COLLECT
In order for us to provide you with Information about our activities and or services we will collect and process personal data about you. We will also collect your personal data where you request information about our services, customer events, promotions and campaigns].
We may also need to collect personal data relating to others when providing you with information about our services.In most circumstances, you will provide us with this information. Where you disclose the personal data of others, you must ensure you are entitled to do so.
You may provide us with personal data when signing up to our services, through application forms, when completing contact forms, when we are completing due diligence on you and your personal or business affairs, when you contact us via the telephone, when writing to us directly or we complete forms in conjunction with you.
We will share your personal data within our internal group and with professional advisers and business partners. This is normal practice within our industry where it is necessary to share information and administer our business and administer our business.
Wealso share personal data with authorised third parties. This is necessary where we are required to do so by law, where we need to administer our business or where we need to complete appropriate due diligence on you or your business affairs. Some example third parties follow:
-Credit reference agencies;
-Debt recovery agencies;
Wewill collect your personal data when you visit our website, where wewill collect your unique online electronic identifier; this is commonly known as an IP address.
Wewill also collect electronic personal data when you first visit our website where we will place a small text file that is commonly known as a cookie on your computer. Cookies are used to identify visitors and to simplify accessibility, and to monitor visitor behaviour when viewing website content, navigating our website and when usingfeatures.
We may record your communications with us when contacting our customer care, complaints and other customer focused functions.
Where we collect data directly from you,we are considered to be the controller of that data i.e. we are the data controller. Where we use third parties to process your data, these parties are known as processors of your personal data. Where there are other parties involved in managing your investment, if they referred you onto us, wewill bea joint data controllerof your personal data.
If you believe you are also a data processor please contact us as you may need to include information about this activity]
A data ‘controller’ means the individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data.
A data ‘processor’ means the individual or organisation which processes personal data on behalf of the controller.
As a provider of financial serviceswe will process the following categories of data:
• Personal data such as an individual’s name, address, date of birth, gender and contact details
• Special categories of personal data such asdata relating to medical health to help identify vulnerable individuals or where you or others inform us of a medical condition
• Data relating to criminal convictions and offences such as details on fraud
If you object to the collection, sharing and use of your personal data we may be unable to provide you with our products and services.
For the purposes of meeting the Data Protection Act 2018 territorial scope requirements, the United Kingdom is identified as the namedterritory where the processing of personal data takes place.
If you require more information onour activitiesor further details on how we collect personal data and with whomwe share data with, please contact our(‘data privacy representative’)by emailing email@example.com.
WHY DO WE NEED YOUR PERSONAL DATA?
To keep you informed about our activities and / or services and to meet our regulatory obligations and finally to provide you with any communications which may be relevant to investments that:
a. You have made in respect of our corporate clients
b. Are held in custody by a third party custodian that we have introduced you to
Or to respond to any requests from you about services we provide and to process complaints. Wemay also use your personal data to perform statistical analysis on the data we collect, for business forecasting purposes and to contact you regarding future opportunities, products and services.
Or in instances where we have either received consent from you or we have assessed that there is a legitimate interest for us to send you marketing communications, you may opt out of receiving this information any time by contacting us. When assessing legitimate interests, we will balance our interests with your rights and only send communications where you would reasonably expect to hear from us.
In some situations,we may request your consent to share your data or to transfer your data outside the European Economic Area.
Where we require consent, your rights and what you are consenting to will be clearly communicated to you. Where you provide consent, you can withdraw this at any time by contacting our data privacy representative
We will retain your personal data at the end of any contractual agreement until instructed otherwise at which point we we immediately follow such instruction. We will retain special category and criminal conviction data for a period of 7 years.
Where you have complained about the services you have received we will retain your data until instructed otherwise at which point we we immediately follow such instruction.
Where you have contacted us for details of our services and products, we will retain your personal data for until instructed otherwise at which point we immediately follow such instruction. Where you or law enforcement agencies inform us on any active investigation or potential criminal prosecution, we will comply with legal requirements when retaining this data.
The retaining of data is necessary where required for contractual, legal or regulatory purposes or for our legitimate business interests for statistical analysis (profiling) and product development and marketing purposes.
Sometimes we may need to retain your data for longer, for example if we are representing you or defending ourselves in a legal dispute or as required by law or where evidence exists that a future complaint may occur.
Please contact firstname.lastname@example.org if you object to the use of, or you have any questions relating to the use of, your data, the retention of your personal data
Individuals are provided with legal rights governing the use of their personal data. These grant individuals the right to understand what personal data relating to them is held, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing. Individuals can also request the deletion of their personal data.
These rights are known as Individual Rights under the Data Protection Act 2018. The following list details these rights:
– The right to be informed about the personal data being processed;
– The right of access to your personal data;
– The right to object to the processing of your personal data;
– The right to restrict the processing of your personal data;
– The right to rectification of your personal data;
– The right to erasure of your personal data;
– The right to data portability (to receive an electronic copy of your personal data);
– Rights relating to automated decision making including profiling.
Individuals can exercise their Individual Rights at any time. As mandated by law we will not charge a fee to process these requests, however if your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee.
In exercising your Individual Rights, you should understand that in some situations we may unable to fully meet your request, for example if you make a request for us to delete all your personal data, we may be required to retain some data for taxation, prevention of crime and for regulatory and other statutory purposes.
You should understand that when exercising your rights, a substantial public or vital interest may take precedent over any request you make. In addition, where these interests apply, we are required by law to grant access to this data for law enforcement, legal and/or health related matters.
The flow of data within the investment banking sector is complex and we ask you to keep this in mind when exercising your ‘rights of access’ to your information. Where we may be reliant on other organisations to help satisfy your request this may impact on timescales.
If you require further information on your Individual Rights or you wish to exercise your Individual Rights, please contact our data privacy representative by emailing email@example.com or by writing to Nash & Co Capital Limited, 40 Craven St, London WC2N 5NG.
PROTECTING YOUR DATA
We will take all appropriate technical and organisational steps to protect the confidentiality, integrity, availability and authenticity of your data, including when sharing your data within our group of companies and authorised third parties.
DATA PROTECTION OFFICER/DATA PRIVACY REPRESENTATIVE
To comply with our legal obligations and to ensure data privacy and protection has appropriate focus within our organisation, we have a Data Protection Officer who reports to our senior management team. The Data Protection Officer’s contact details are as follows: (firstname.lastname@example.org).
To ensure data privacy and protection has appropriate focus within our organisation we have a Data Privacy Representative who reports to our senior management team. The Data Privacy Representative’s contact details are as follows: email@example.com
If you are dissatisfied with any aspect of the way in which we process your personal data please contact data privacy representative. You also have the right to complain to the UK’s data protection supervisory authority, the Information Commissioner’s Office(ICO). The ICO may be contacted via its website which is https://ico.org.uk/concerns/, by live chat or by calling their helpline on 0303 123 1113.
HOW TO CONTACT US
If you have any questions regarding this Notice, the use of your data and your Individual Rights please contact our data privacy representative at Nash & Co Capital Limited, 40 Craven St, London WC2N 5NG or by emailing firstname.lastname@example.org or by telephoning 020 3889 9600.