1. What this privacy notice covers
This privacy notice covers the processing of data for individuals and companies that we have a prospective or existing business relationship with. We have to process your data to manage this relationship.
We are the data controller for the data that we process about you and we will not collect any information from you that we do not need for the purpose of managing the business relationship.
We keep this privacy notice under regular review. This version was last updated on 16 March 2021.
2. Contact details
Email address: email@example.com
Postal address: etika Finance UK Ltd
PO Box 5600
Telephone number: 0800 028 9321
3. Why is your personal data required
The provision of your personal data is necessary for us to manage the business relationship and meet any contractual obligations that we have with you. If you fail to provide the data, it may mean that we are unable to perform the terms of the contract that we have with you.
4. What information do we collect about you?
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect the personal data about you from the following sources:
- When you provide your business contact details to us for potential business opportunities.
- When we collect personal data as part of our ongoing business dealings and development.
- When you contact us via email, telephone or postal mail
- When you interact with us on social media sites
The information collected may include the following categories of personal data;
- Your first name and last name
If we are entering into a contractual business relationship with you, we may collect the following categories of personal data;
- Relevant Director’s name(s), last name(s), DOB, personal address(es), previous persona laddress(es)
The information collected may include the following categories of non-personal data;
- Your job title
- Your company contact details, including company email address and telephone number
- Your company name and address
5. Why do we process your data?
We may process your personal data for the following reasons:
- We use your personal data as it is necessary to manage our business relationship, including meeting our contractual obligations to you and sending you communications in relation to this relationship.
- We use your personal data to undertake necessary due diligence prior to entering into a contract, such as conducting anti-money laundering checks to fulfil our onboarding requirements.
- We may also use your data where there is no contractual relationship, and where we need to process your data for potential business opportunities. We can use your personal data in this way because it is in our legitimate interests to network and grow the business.
- We use your personal data to send you communications with opportunities/products that we deem to be of interest to you. We can use your personal data in this way because it is in our legitimate interests to network and grow the business.
- We use your personal data where required for us to comply with our legal obligations or to enforce or defend our legal rights.
5.1 Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time via firstname.lastname@example.org
6. How we keep your data safe
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Amongst others, this includes the use of secure socket layer (SSL) encryption technology. We also use firewalls and other security technologies to protect our servers from external attack.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. How long do we keep your data for?
As a rule, where there is a contractual relationship, we will keep your personal data for seven years following the end of your relationship with us. Where there is no contractual relationship formed, we will retain your personal data for two years. Following the end of the retention periods, your personal data will be securely destroyed.
8. Who might we share your data with?
We will only use and share your information where it is necessary for us to lawfully carry out our business activities.
We may share your data on an on-going basis; routinely; or on an ad-hoc basis, for example in response to a particular event or requirement, depending on who we are sharing it with and why.
We will endeavour to share your data as securely as possible, for example by using appropriate security measures where appropriate.
Your personal data will be shared internally with etika employees and may be shared with the following categories of third parties:
- Related Group Companies
- Third-party service providers that etikais contracted with, who process data on our behalf.
9. Where your data will be located
The personal data that we collect from you will be processed in the United Kingdom,Australia and within the European Economic Area (EEA). Whenever we transfer your personal data to Australia, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may use specific contracts approved by theEuropean Commission and UK approved equivalent contracts which give personal data the same level of protection it has in the UK and EEA.
10. When dowe make automated decisions about you?
We will not make any automated decisions about you for the purposes of the business relationship and human intervention will always be involved.
11. Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- withdraw consent where that is the legal basis of our processing
- access your personal data that we process
- rectify inaccuracies in personal data that we hold about you
- be forgotten, if the processing of your personal data is no longer necessary for the purposes it is collected for, your details would be removed from systems that we use to process your personal data
- restrict the processing in certain ways
- obtain a copy of your data in a commonly used electronic form (if the legal basis of our processing is consent or necessary for contract)
- object to certain processing of your personal data by us
If you wish to exercise any of the rights set out above, please contact us at email@example.com
Please see https://ico.org.uk for further information on the above rights. You have a right to complain to the Information Commissioner’s Office about the way in which we process your personal data. Please see https://ico.org.uk