What personal information might we collect

• Biographical information such as your photo, name, date of birth, gender, identification number, national insurance number, tax number, biometric identifiers, occupation, country of residence, residence status, and nationality.
• Contact information such as your address, telephone number, email address, and website registration.
• Information relating to your employment history, education, family or personal circumstances and interests, where relevant.
• Information relating to your financial position such as bank account details, income, and source of wealth and source of funds.
• Information to understand your needs and objectives or to carry out your instructions.
• Information to assess whether you represent a politically exposed person, money laundering, or negative publicity risk.
• Static and moving images of persons.
• Voice recordings of telephone conversations.
• We use a third-party service provider, Google Analytics, to distinguish you from other users of our website and to better monitor our website traffic. If you consent to the use of cookies, we may collect from you the following data: your browser type, language, operating system, device ID, geolocation data, the state or country from which you accessed the website’s services, the webpages you visited, and the date and the time of a visit. Please note that this information is aggregated and therefore the data is anonymous and will not be traced back to you.
• Where you have submitted a copy of your CV to us in connection with any role, such personal data as you have included within the CV.

How we collect personal information

We will only collect information in line with relevant regulations and laws, information which you provide us, and anonymised usage data provided by your browser’s cookies when you use our website and consent to our use of cookies. You provide us with your personal information entirely voluntarily. However, there may be contractual conditions under which we will not be able to act or process your instructions without you providing the relevant personal information to us. We may have CCTV in operation which will capture footage of you whilst you are on company premises.

How we use your personal information

We will only use your personal information as allowed by law, i.e. carrying out an instruction or agreement, fulfilling a legal obligation because we or a third-party recipient have a legitimate interest, or as agreed by you. We may share your personal information with another company within our group where there is a legitimate business interest in doing so. A legitimate business interest to use your personal information may include:

• To comply with our legal obligations, including reporting and/or being audited by regulatory bodies.
• To analyse and improve our services and communication with you.
• To recognise and count the number of visitors and to see how visitors move around our website when they are using it to improve the way our website works.
• For marketing to you, but we do not share personal information with third parties for marketing purposes.
• For the management and administration of our business.
• For insurance purposes.
• Seeking advice on our rights and obligations.
• Protecting the security of our Information Technology and communication systems, website and other systems, preventing and detecting security threats, fraud, and other criminal or malicious activities.
• To comply with court orders and/or defend our legal rights.
• To detect, prevent, or reduce the incidence of crime and create a safer environment.
• To assist with health and safety of employees, service providers and visitors, and to assist with serious occurrences, for example disciplinary investigations.
• Where you have provided us with a CV, for vetting or verification purposes prior to or during the course of an employment assessment.

Who can we share your personal information with

• Your agents, intermediaries, and advisors with your permission.
• Our group companies.
• Third parties we engage to provide services to you such as agents, advisors, banks, brokers, insurers, or any third party to whom we assign or novate any of our rights or obligations.
• Professional advisors such as lawyers, auditors, accountants, IT software and hardware providers.
• Our data processors.
• Courts, regulators, and law enforcement agencies, where required.
• Where you have provided us with a CV, background checking agencies for the purposes of verifying the information contained within your CV.

How long we keep your personal information

We will keep your information for as long as you have a relationship with us. After it ends, we will keep your information as long as we may have a legitimate purpose or you withdraw your consent (where applicable) and we are not legally required or otherwise permitted to continue storing your data. In particular, we will retain your personal data:

• Where we have collected your personal information as required for anti-money laundering legislation.
• To help us respond to queries or complaints.
• To help us respond to requests from authorities.
• For other reasons such as fighting fraud and financial crime.

Transferring your information overseas

Your information may be transferred and stored as set out in this Policy to countries outside the European Economic Area or to countries not approved as providing an adequate level of protection for personal information. This may include countries which do not provide the same level of protection for personal information. When this happens, we will ensure any such transfers are made subject to appropriate or suitable safeguards. Such transfers will occur where you have given explicit consent, or where the recipient has entered into standard contractual clauses.

Your rights

• Request a copy of the personal data we hold about you.
• Ask us to share your personal data with another party.
• Ask us to update incorrect or incomplete details.
• Ask us to erase your personal information.
• Object to or restrict our processing activities of your information.
• Make a complaint.
• Withdraw consent.

Cookies

What are cookies?

Our website uses cookies which are small text files that are placed on your device when you visit a website. Our use of cookies aims to provide you with an optimum user experience when you browse our website, and allows us to monitor the performance of the website on an ongoing basis.

What type of cookies do we use?

We use third-party cookies by Google Analytics in order to monitor and analyse the use of our website. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. You can learn more about data collected by Google and what this data is used for in Google’s Privacy Policy. Additional information on Google services and products is available in Google’s Terms of Service.

What data is collected by the cookies?

The data we collect from you may include your browser type, language, operating system, device ID, geolocation data, the state or country from which you accessed the website’s services, the webpages you visited, and the date and the time of a visit. Please note that this information is aggregated and therefore the data is anonymous and will not be traced back to you.

How to manage cookies?

You can opt-out of having your activity made available to Google Analytics across all websites by installing the Google Analytics opt-out browser add on, which you can access here: Google Analytics Opt-out Browser Add-on Download Page. You may also opt-out of tracking by Google Analytics on our website by pressing the ‘Reject’ button on our cookies banner. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page.

Links to third-party websites

Our website may provide links to third-party sites, including social networking sites. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content and Privacy Policy of any third-party sites or services.

Updates to this Privacy Policy

We reserve the right to update and change this Privacy Policy from time to time in order to reflect regulatory changes or changes to the way we process your personal information. In case of such changes, we post the amended Privacy Policy on our website. The changes will come into effect upon publication.

Complaints and further information

If you wish to submit a complaint or need further information in relation to this Policy, please contact [email protected].