Effective Date: from 29 July 2020
This Privacy Notice explains how particular companies in the UAB ‘One IBC’ collects, uses, and discloses your personal data, and your rights in relation to the personal data it holds.
UAB ‘One IBC’ (in this Privacy Notice, “us”, “we” and “our”) is the data controller of your personal data and is subject to the EU General Data Protection Regulation 2016/679 (the “GDPR”) and any locally applicable data protection laws.
You can contact us concerning the EU’s GDPR matter via the contact details below:
This Privacy Notice supersedes any previous Privacy Notice or equivalent which you may have been provided with or seen prior to the Effective Date stated above.
Under the GDPR you have the following rights:
- To obtain access to, and copies of, the personal data that we hold about you;
- To require that we cease processing your personal data if the processing is causing you damage or distress;
- To require us not to send you marketing communications;
- To require us to erase your personal data;
- To require us to restrict our data processing activities;
- To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
- To require us to correct the personal data we hold about you if it is incorrect.
Please note that the above rights are not absolute, and we may be titled to refuse requests where exceptions apply.
If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact us using the following:
How we collect your data
We collect your personal data in a number of ways, for example:
- From the information about you provided to us by our partner;
- When you communicate with us by telephone, fax, email, or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
- When you complete (or we complete on your behalf) client on-boarding or application or other forms;
- From other legal entities in the One IBC Group;
- From your agents, advisers, intermediaries, and custodians of your assets;
- From publicly available sources or from third parties, most commonly where we need to conduct background checks about you.
The categories of personal data we collect
We collect the following categories of personal data about you:
- Your name and contact information such as your home or business address, email address and telephone number;
- Biographical information which may confirm your identity including your date of birth, tax identification number and your passport number or national identity card details, country of domicile and/or your nationality;
- Information relating to your financial situation such as income, expenditure, assets, and liabilities, sources of wealth, as well as your bank account details;
- Information about your knowledge and experience in the investment field;
- An understanding of your goals and objectives in procuring our services;
- Information about your employment, education, family or personal circumstances, and interests, where relevant; and
- Information to assess whether you may represent a politically exposed person or money laundering risk.
The basis for processing your personal data (other than with your consent), how we use that personal data and whom we share it with
(i) Performance of a contract with you
We process your personal data because it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
In this respect, we use your personal data for the following:
- To prepare a proposal for you regarding the services we offer;
- To provide you with the services as set out in our Terms of Service with you or as otherwise agreed with you from time to time;
- To deal with any complaints or feedback you may have;
- For any other purpose for which you provide us with your personal data.
In this respect, we may share your personal data with or transfer it to the following:
- Your agents, advisers, intermediaries, and custodians of your assets who you tell us about;
- Third parties whom we engage to assist in delivering the services to you, including other legal entities in the One IBC Group;
- Our professional advisers where it is necessary for us to obtain their advice or assistance, including accountants, IT or advisers;
- Other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you;
Our data storage providers
(ii) Legitimate interests
We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person.
In this respect, we use your personal data for the following:
- For marketing to you. In this respect, see the separate section on Marketing below;
- Training our staff or monitoring their performance;
- For the administration and management of our business, including recovering money you owe to us, and archiving or statistical analysis;
- Seeking advice on our rights and obligations, such as where we require our own legal advice;
In this respect we will share your personal data with the following:
- Our advisers or agents where it is necessary for us to obtain their advice or assistance;
- With third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.
(iii) Legal obligations
We also process your personal data for our compliance with a legal obligation which we are under.
In this respect, we will use your personal data for the following:
- To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws;
- As required by tax authorities or any competent court or legal authority.
- In this respect, we will share your personal data with the following:
- Our advisers where it is necessary for us to obtain their advice or assistance;
- Our auditors where it is necessary as part of their auditing functions;
- With third parties who assist us in conducting background checks;
- With relevant regulators or law enforcement agencies where we are required to do so.
We will send you marketing about similar services we provide, as well as other information in the form of alerts, newsletters, and invitations to events or functions which we believe might be of interest to you.
We will communicate this to you in a number of ways including by post, telephone, email, or other digital channels.
If you object to receiving marketing from us at any time, please contact us:
Withdrawal of Consent
If you have given your consent and you wish to withdraw it at any time, please contact us at the same details as above.
Retention of your data
We will only retain your personal data for as long as we have a lawful reason to do so. In particular:
- Where we have collected your personal data as required by anti-money laundering legislation, including for identification, screening, and reporting, we will retain that personal data for five years after the termination of our relationship, unless we are required to retain this information by another law or for the purposes of court proceedings; or
- Otherwise, we will in most cases retain your personal data for a period of seven years after the termination of our contractual or other relationship with you in case any claims arise out of the provision of our services to you.
What is a cookie?
A cookie is a small text file stored in a computer’s web browser memory.
There are three main types of cookies:
- Session cookies – they help you do not re-enter information and stay logged in each time you change web–pages. Session cookies are deleted automatically after you leave the site or when you close your browser.
- Persistent cookies – they help us to recognize you each time you return to the One IBC Site and remember your preferences for viewing the site. Such cookies are stored on your computer until deleted by you or automatically after its expiration.
- Third-party cookies - are the persistent cookies placed not by One IBC which help to gather browsing activity across numerous websites and during several sessions. Such cookies are stored on your computer until deleted by you or automatically after its expiration.
You can find out more from https://www.aboutcookies.org/
What are cookies for?
Are cookies safe?
Yes, they are. Cookies are small text files. They can't look into your computer or read any personal information or other material on your hard drive. Cookies can't transmit viruses or install anything harmful on your computer.
- Fraud prevention: With help of cookies we can obtain information about security of your computer and web browser used to access to One IBC Site or One IBC Account and to detect harmful or illegal use of One IBC Services.
What other technologies can we use?
There are other technologies used by us to track your activity on the site or One IBC Account portal.
- Web beacons (web pixels): are small graphics helping to understand browsing activity, track conversion and optimize ads. These graphics files are downloaded when you visit the site or One IBC Account portal.
- Local storage objects (flash cookies): are files that can be stored on your browser and can be used to detect preferences, to record the history of usage, or remember settings of the site or One IBC Account. You can block or control flash cookies at any time by modifying the settings of your browser.
How can you change the cookie setting?
You can delete and disable cookies using the settings of your browser. You can find out more about how to manage cookies from the following links:
For the Chrome browser: https://support.google.com/chrome/answer/95647?hl=en
For Explorer browser: https://support.microsoft.com/en-us/products/windows?os=windows-10
For Safari browser: https://support.apple.com/kb/ph21411
For Firefox browser: https://support.mozilla.org/products/firefox/cookies
For Opera browser: http://www.opera.com/help/tutorials/security/cookies/