Privacy and Cookies Policy
What is Personal Data?
The General Data Protection Regulation applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified by reference to data items such as: name, contact details, unique identification numbers, location data or online identifiers.
What we need?
Culross Global is a Controller of the personal data you provide us. We may collect the following types of personal data from you:
- Your contact details such as name, title, addresses, telephone numbers and email addresses;
- Date of birth and/or age;
- Nationality and any dual nationality;
- Country of residence;
- Marital status and details of any dependents;
- Next of kin and emergency contact information;
- Photographic ID, utility bill, and any other anti-money laundering documentation as required;
- Occupation, including details of where you work;
- Bankruptcy information;
- Bank account details;
- Tax status;
- Product and services records you hold or have applied for with us;
- Voice recordings of any telephone conversations you have with us (see further below);
- Information from fraud agencies, credit reference agencies, electoral roll, court records such as in respect of bankruptcy and other publicly available information;
- Personal data of your financial adviser, investment consultant, trustee or legal adviser, including their name address and contact details.
Why we need it?
In most cases your personal data will be processed to perform our contract with you, and/or to comply with a legal obligation. Most commonly we will use your personal data in the following circumstances:
- Whereeed to perform the contract of Investment Management/Advice or Administration we have entered into with you (“Contract Purposes”);
- Whereeed to comply with a legal obligation (“Legal Purposes”);
- Wheres necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests Purposes”);
- Where we have your consent (“Consent Purposes”).
What we do with it?
Culross Global has comprehensive policies and procedures in place to ensure your personal data is kept safe and secure. Your personal data is processed in:
- Culross Global Management Limited located in the United Kingdom;
- Culross Global Investment Management Limited located in Malta; and
- Culross Global Investment Management AG located in Switzerland.
Hosting and storage of your data takes place in the following secure data centres (all with firewalls, data encryption, intrusion detection and 24/7 physical protection of facilities):
- Microsoft located in the United Kingdom.
Your personal data will be used for the following purposes (which may overlap):
- To submit our trading instructions or recommendations as part of your contract.
- To communicate with you in the day-to-day running of your contract.
- To update our records.
- To provide personal data to others where it is necessary in the running of your contract and for legal and regulatory purposes and related disclosures.
- When you contact us regarding exercising your rights under data protection laws.
- To contact you about your contract.
- We may keep your data after your contract has terminated, where we are required to do so by law (see below “How long we keep it”).
- For prevention, detection, investigation and reporting of a crime, which may include providing your personal data to fraud prevention agencies.
- To verify your identity for anti-money laundering purposes.
- To monitor your communications with us (see further below).
- For information security purposes.
- To comply with orders of the courts of competent jurisdictions and for the establishment and defence of legal rights.
Legitimate interests purposes
- To ensure good and proper governance, administration, auditing, management of our business and your contract.
- To conduct market research, analysis and statistics to improve our products and services.
- To keep you informed of our products and services.
- To monitor your communications with us (see further below).
Where there is no other lawful basis to process personal data, we may ask for your consent. For example:
- When required before disclosing your personal data to third parties.
- For certain direct marketing communications.
- For market research purposes.
Monitoring your communications with us
We monitor and record your communications with us in accordance with applicable laws. This includes telephone calls, emails and letters. We do this for the purposes of complying with legal obligations to prevent and detect crime, quality control and monitoring purposes, and when we need to consider a record of communication (such as if you make a complaint).
How long we keep it
Under applicable laws, we are required to keep your documents for at least five years according to the Data Retention Policy. After this period, your personal data will be irreversibly destroyed. Any personal data held by us for marketing and service update notifications will be kept by us until such time that you notify us that you no longer wish to receive this information. Please refer to our Personal Data Protection Policy for more information on our personal data retention schedule.
Duty to inform
It is important that your personal data remains current and accurate. Please keep us informed if your personal data changes during your relationship with us.
What are your rights?
Should you believe that any personal data we hold on you is incorrect or incomplete, you have the ability to request to see this information, rectify it or have it deleted. Please send written notice to any registered office of Culross Global or alternatively email us.
In the event that you wish to complain about how we have handled your personal data, please send written notice to any registered office of Culross Global or alternatively email us. A senior manager will be appointed to look into your complaint and work with you to resolve the matter.
If you still feel that your personal data has not been handled appropriately according to the law, you can file a complaint with our Data Protection Authority:
Information Commissioner’s Office
Helpline: 0303 123 1113 (local rate – calls to this number cost the same as calls to 01 or 02 numbers).
If you're calling from outside the UK, you may not be able to use the 03 number, so please call +44 1625 545 700
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