Your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Fraser Finance Ltd., Fraser Finance LLP, Fraser & Company GmbH, and Fraser Partners S.A. (“Fraser”, “we” or “us”), and sets out our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data relating to current, prospective and former clients and their personnel. This Privacy Notice is being provided in accordance with the requirements of data privacy laws, including the EU General Data Protection Regulation 2016/679 (“GDPR”) and the UK Data Protection Act 2018 (collectively, “Data Protection Law”).
The types of personal data we may collect and use
The categories of personal data we may collect include names, title, residential addresses or other contact details, signature, nationality, tax identification number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, source of funds details or other sensitive information, such as certain special categories of data contained in the relevant materials or documents.
How we collect personal data
We may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; (ii) information that we obtain through or in connection with the provision of products and services; (iii) through our websites; and (iii) recording and monitoring of telephone conversations and electronic communications with you.
We also may receive your personal information from third parties or other sources, such as our affiliates, publicly accessible databases or registers, tax authorities, governmental bodies, supervisory bodies and regulators, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.
Using your personal data: the legal basis and purposes
We may process your personal data for the purposes of administering the relationship between you and us (including communications), direct marketing of our products and services, monitoring and analysing our activities, the administration and maintenance of databases storing personal data, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities and regulators with competent jurisdiction over our business). Your personal data will be processed in accordance with Data Protection Law and may be processed with your consent, upon your instruction, or for any of the purposes set out herein, including where we or a third-party consider there to be any other lawful purpose to do so.
Where personal data is required to satisfy a statutory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in us being unable to provide services to you. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.
How we may share your personal data
We may disclose information about you to our affiliates or third parties for the purpose of providing services to us (e.g. accountants, professional advisors, IT and communications providers), for our everyday business purposes, such as to enable that we can provide our services to you, or to respond to court orders and legal and regulatory investigations. We will also release information about you if you direct us to do so.
We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us as described below (see “Who to contact about this Privacy Notice”). We may also disclose information about your transactions and experiences with us to our affiliates for their everyday business purposes.
Monitoring of communications
We may record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given in connection with the delivery of our services to you; (ii) ensuring compliance with our legal and regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.
Retention periods and security measures
We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to Data Protection Law. How long we will hold your personal data will be determined by: (a) the purpose for which we are using it – we will need to keep the data for as long as it is necessary for that purpose; and (b) legal and regulatory obligations – laws or regulation may set a minimum period for which we have to keep your personal data. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.
To protect your personal information from unauthorized access and use, we apply organizational and technical security measures in accordance with Data Protection Law. These measures include computer safeguards and secured files and buildings. We will notify you of any material personal data breaches affecting you in accordance with the requirements of Data Protection Law.
Because of the international nature of Fraser, personal data may be transferred to countries outside the EEA or outside the United Kingdom (“Third Countries”), such as to jurisdictions where we conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the Data Protection Law in the EEA or in the United Kingdom. In such cases, we will process personal data (or procure that it be processed) in the Third Countries in accordance with the requirements of the Data Protection Law, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf in such Third Countries. You can obtain more details of the protection given to your personal data when it is transferred to a Third Country (including a copy of the contractual undertakings which we have entered into with recipients of your personal data) by contacting us as described below.
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Your rights under Data Protection Law
You have certain rights under GDPR in relation to our processing of your personal data and these are, generally: (i) the right to request access to your personal data; (ii) the right to request rectification of your personal data; (iii) the right to request erasure of your personal data (the “right to be forgotten”); (iv) the right to restrict our processing or use of personal data; (v) the right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of direct marketing activities); (vi) where relevant, the right to request the portability; (vii) where your consent to processing has been obtained, the right to withdraw your consent at any time; and (viii) the right to lodge a complaint with a supervisory authority. You should note that these rights may not always apply to the personal data that we hold and, in particular, your right to be forgotten is not likely to be available in respect of the personal data we hold, given the purpose for which we collect such data, as described above.
You may contact us at any time to limit our sharing of your personal information.
Who to contact about this Privacy Notice
Please contact our Compliance Officer at +44 20 7661 9562 or by writing to the following address: 33 St. James’s Square, London SW1Y 4JS, UK, for any questions about this Privacy Notice or requests with regards to the personal data we hold.