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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 Statura Ltd of 17 Grosvenor Street, Mayfair, London, W1K 4QG, United Kingdom, or any other member of the Statura 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. Please read below to learn how we collect, protect, use and share your data.
What information do we collect?
"Personal Information" (sometimes called "personal data") is information which can be used to identify you as an individual or (in some jurisdictions) which relates to an identifiable individual, as provided by applicable law
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 Statura 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
as we reasonably believe necessary or appropriate: (a) under applicable law, including laws outside your country/territory of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country/territory of residence; (d) to enforce our Terms of Business; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or those of other Statura Group companies, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain
for any other purpose for which you provide us with your personal data, provided that we first notify you in order to obtain your consent.
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.
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.
To the extent that any information (including aggregated and de-identified information about Visa Checkout users) is not Personal Information under applicable law, we may share it with third parties for lawful purposes.
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.
For more information about your rights in the United Kingdom you can visit https://ico.org.uk/for-the-public/.
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/).
You can choose not to avail yourself of our services by terminating our Letter of Engagement and Terms of Business. Even though our engagement is terminated, we still may retain and use your Personal Information to comply with legal requirements, prevent fraud, resolve disputes, and take other actions as permitted by the law. We will cease to retain Personal Information as required by applicable law.
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, Statura Ltd, 17 Grosvenor Street, Mayfair, London, W1K 4QG, United Kingdom.
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