PRIVACY NOTICE

"We", "our" or "us" means Winterflood Securities Limited and its subsidiaries. For the purposes of data protection law, we are a controller in respect of your personal data. We collect and use your personal data as described below. We are responsible for ensuring that we use your personal data in compliance with data protection law.

For the purpose of this privacy notice, the terms ‘controller’, ‘process’ and ‘personal data’ shall have the meaning given in Regulation (EU) 2016/679 (GDPR).

If you have any questions about this notice, about how we process personal data or about your rights over your personal data, you can contact us via email to dp-enquiries@winterflood.com in the first instance. Alternatively, our Data Protection Officer can be contacted using the details set out in the “Contact us” section below.

This notice applies to personal data we receive or otherwise create in connection with the provision of services to professional clients / eligible counterparties and their personnel, including any associated services provided via our website(s) at:

www.winterflood.com;

www.winterfloodresearch.com; and/or

www.winterfloodbusinessservices.com

It is important that you take the time to read this notice so that you understand how we will use your personal data and your rights in relation to your personal data.

Personal data that we collect about you

We will collect and use the following information about you:

Information you give us

Informaton we collect or generate about you

If we do not receive this information we may not be able to provide certain services to you.

How we use your personal data

Your personal data may be processed by us for the following purposes:

Legal basis for processing your personal data

We process your personal data pursuant to the following legal bases:

(i) where necessary to comply with a legal obligation (for example anti-money laundering, know-your-customer and counter-terrorist financing checks and the prevention and detection of fraud and other financial crime);

(ii) where necessary for the purpose of our legitimate business interests which includes:

(iii) where you have separately consented for us to use your personal data to send you specific email updates and communications (by opting-in to such email updates/ communications).

You have the right to object to processing under (ii) by contacting us using the details set out in the “Contact us” section below, and you may cancel your subscription under (iii), at any time by using the ‘unsubscribe’ link within the communications you receive from us or by emailing us at unsubscribe@winterflood.com and requesting the same.

Please note that any instruction to unsubscribe from communications will not affect any processing pursuant to (i) in relation to compliance with a legal obligation.

Sharing your personal data

We may disclose your personal data to our affiliates (being any subsidiary undertaking or parent undertaking, or a subsidiary of any parent undertaking of Winterflood Securities Limited, as the same terms are defined in the Companies Act 2006) and to third party service providers in the circumstances described below:

We will take steps to ensure that the personal data is accessed only by persons that have a need to do so for the purposes described in this notice.

We may also share your personal data with third parties:

These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this notice.

We may also share your personal data with third parties (including, without limitation, regulatory, governmental, judicial and other bodies or authorities of competent jurisdiction) to the extent required by applicable law, for example if we are under a duty to disclose your personal data in order to comply with any legal or regulatory obligation, and to establish, exercise or defend our legal rights.

Transfer of personal data outside the European Economic Area

The information you provide to us will be transferred to and stored on our secure servers in the European Economic Area (“EEA”). However, from time to time, your personal data may be transferred to, stored in, or accessed from a destination outside the EEA. It may also be processed by staff operating outside of the EEA who work for us or an affiliate or for one of our suppliers.

Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance:

In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contact us” section below.

How long we keep your personal data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

Your rights

You have a number of rights in relation to the personal data that we hold about you. These rights include:

You can exercise your rights by contacting us using the details set out in the “Contact us” section below. You can find out more information about your rights by contacting the data protection regulator, the Information Commissioner, or by visiting their website at https://ico.org.uk/.

Changes to this Privacy Notice

We keep this notice under regular review. Any changes we make to this notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this notice.

Contact us

Winterflood Securities Limited is a company registered in England and Wales. Our registered address is at The Atrium Building, Cannon Bridge House, 25 Dowgate Hill, London, EC4R 2GA and our company registration number is 02242204.

Please contact us if you have any questions about this notice or personal data that we may hold about you:

You can write to us at: Data Protection Team, Winterflood Securities Limited, The Atrium Building, Cannon Bridge House, 25 Dowgate Hill, London, EC4R 2GA.

By telephone: 0203 100 0000; or
By email: dp-enquiries@winterflood.com

You can also contact our Data Protection Officer using the following details:

By post: Data Protection, Close Brothers, 10 Crown Place, London EC2A 4FT;
By telephone: 0333 321 6100; or
By email: dpo@closebrothers.com

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