1. Background

 

(1.1) Assetfort collects and uses certain personal data and is responsible for ensuring that it uses personal data in compliance with data protection laws.

(1.2) At Assetfort, we respect your privacy and are committed to keeping your personal data secure.

(1.3) This Privacy Policy is intended for individuals whose personal data we handle in the course of carrying on our commercial activities, whether they are our clients or prospective clients or their representatives, agents or appointees, or an employee, director, officer or representative of organizations with which we have a business relationship. This Privacy Policy is also intended for those who visit our websites.

2. Overview of circumstances in which we handle your personal data

 

(2.1) This Privacy Policy concerns any information that we collect in the following ways:

(A) Information we receive through Assetfort Websites. Details of how we handle the information we receive through Assetfort Websites are set out in paragraph 10 of this Privacy Policy; and

(B) Information we receive as a result of Assetfort Products and Services.

3. The types of personal data we collect

 

Assetfort is required to obtain personal data in order to provide many of the products and services we have been engaged to provide. We will collect and process the following personal data:

  • Information that you provide to Assetfort.  This includes information about you that you provide to us. The nature of our relationship with you will determine the kind of personal data we might ask for, and such information may include:
    • Basic personal data such as first name, family name, national insurance number, email address, phone number, address (including city postcode and country), occupation and job title, bank details ID documentation, date of birth, life events and family information; and
    • Sensitive personal data, which may include information we handle about your nationality, place of birth, health related information, disability status, or details of political affiliation.
  • Information that we collect or generate about you. This may include:
    • Files that we may produce as a record of our relationship with our clients and prospective clients, including contact history; and
    • Personal data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints or improve service, and in order to comply with legal and regulatory requirements for any personal data we obtain in relation to your use of Assetfort Websites.
  • Information we obtain from other sources. This may include:
    • Information from publicly available sources including third party agencies such as credit reference agencies, fraud prevention agencies, law enforcement agencies, public databases, registers and records; and other publicly accessible sources;
    • Information obtained from independent financial advisors (IFAs), other professional advisers, product providers, events organizers, and other agents and/or representatives; and
    • Information obtained from sanctions checking and background screening providers.

4. How we use your information

 

(4.1) Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

  • To allow clients and prospective clients to use and access Assetfort products and services;
  • To assess client and prospective client applications or contracts for Assetfort products and services;
  • To on-board prospective clients to use Assetfort products and services;
  • To keep our records up to date;
  • To monitor IT systems in order to protect against cyber threats or malicious activity including abuse and misuse;
  • To administer or maintain IT systems in order to uphold standards of service;
  • For ongoing review and improvement of the information provided on Assetfort Websites to optimize user experience and prevent potential disruption or cyber attack;
  • To understand feedback on Assetfort products and services and to help provide more information on the use of those products and services quickly and easily;
  • To communicate with clients and prospective clients in order to provide services or information about Assetfort and Assetfort products and services
  • To effectively manage and strengthen client and prospective client relationships, to understand client and prospective client needs and interests and to learn more about our clients and prospective clients in order to develop, improve and manage the products and services we offer;
  • For the management and administration of our business;
  • To comply with and assess compliance with applicable laws, rules and regulations, as well as internal policies and procedures; and
  • For the administration and maintenance of databases storing your personal data.

(4.2)  When we use your personal data, we comply with applicable law. The law allows or requires us to use your personal data for a variety of reasons. These include instances where:

  • We are performing contractual obligations;
  • We have legal and regulatory obligations that we have to discharge;
  • We need to establish, exercise or defend our legal rights or those of our clients or for the purpose of legal proceedings;
  • We have obtained your consent;
  • The use of your personal data as described is necessary for our legitimate business interests, such as:
    • Allowing us to effectively and efficiently manage and administer the operation of our business;
    • Maintaining compliance with internal policies and procedures;
    • Enabling quick and easy access to information about Assetfort products and services; and
    • Offering effective, up-to-date security solutions for mobile devices and IT systems.

(4.3) Within Assetfort your personal data is accessed only by employees of Assetfort that need access for the purposes described in this privacy policy.

5. Disclosure of your information to third parties

 

(5.1) We may share your personal data within the Assetfort Group for the purposes described above.

(5.2) We may also share your personal data outside of the Assetfort Group as further described below:

  • With business partners who are contractually obliged to comply with appropriate data protection obligations;
  • With representatives, agents, custodians, intermediaries and/or other third party product providers appointed by the client or prospective client (such as accountants, professional advisors, custody service providers and product providers);
  • With third party agents and contractors who provide services both to us and to clients or prospective clients (for example, Assetfort’s accountants, professional advisors, IT and communications providers, background screening providers, credit reference agencies and debt collectors). These third parties will be subject to appropriate data protection obligations;
  • With any depository, stock exchange, clearing or settlement system, counterparties, dealers and others where disclosure of your personal data is reasonably intended for the purpose of effecting, managing or reporting transactions, or establishing a relationship which requires a view to such transactions; and
  • Where you are a joint account or portfolio holder (or one of multiple persons holding an account or portfolio), we may disclose your personal data to the other joint account or portfolio holder or other person to the extent required by law or regulation (For example if we must disclose your personal data in order to comply with a legal obligation, including, without limitation, in order to comply with tax reporting requirements or disclosures to regulators, auditors or public authorities), or to establish, exercise or defend its legal rights if we sell any part of our business or assets, in which case we may need to disclose your personal data to the prospective buyer for due diligence purposes.

Definitions in this Privacy Policy:

Client means an investor in our products or a recipient of our services, who may be an individual investor, or an employee, director, officer, trustee, beneficiary, or representative of an institutional or intermediary client of Assetfort.

Assetfort means Assetfort Holdings Ltd with its registered office at PO Box 1350, Clifton House, 75 Fort Street, Grand Cayman KY1-1108, Cayman Islands, or any of its subsidiaries or affiliates, details of which can be found on the Assetfort website. Together these are referred to as the Assetfort Group.

Assetfort Websites means the websites operated by Assetfort.

Assetfort Products and Services means the products and services we offer to our clients, including through our related support, mobile or cloud-based services.

Personal Data means any data which relates to a living individual who can be identified from that data or from other information which is in the possession of, or is likely to come into the possession of, Assetfort or its representatives or service providers. In addition to factual information such as a name or address, it could include an expression of opinion about or an indication of intention in respect of an individual.

You means each individual to whom this notice is addressed, who may be:

(a) A client or prospective client of ours;
(b) A visitor to the Assetfort website; or
(c) An employee, director, officer or representative of another organization with which we have a business.