Sancus BMS Group Limited Privacy Policy

(hereinafter, “Sancus” or “We” or “Us”)

Please read this Privacy Policy and our Website Terms and Conditions carefully. By using our Site, you agree that you understand and agree to the terms in both, including the acceptance and use of cookies. If you don’t agree to these terms, please stop using the Site. This Policy is in relation to Sancus BMS Group Limited and its subsidiaries, which entities may be located outside of Guernsey.

  1. ABOUT US AND THIS POLICYThis Policy sets out how we will use personal information that we collect and receive, including information about your past use of our products and services. We acknowledge your right to privacy and we are committed to safeguarding the privacy of your information. We limit access to personal information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs. We have physical, electronic and procedural safeguards that comply with legislation and regulations to protect personal information about you.
  2. INFORMATION WE MAY COLLECT FROM YOUWe may receive information from other sources when conducting AML due diligence checks, for example, via screening tools. We might also request from you, documentation such as a certified copy of your passport, driving licence and proofs of address. If you are a limited liability partnership, limited company or trust we may conduct identity checks in respect of some or all of the directors, partners, members, shareholders, trustees, settlors and/or beneficiaries (as the case may be).

    The information collected may include your individual name, your date and place of birth, your nationality, country of residence and Tax Identification Number, your business or trading name, your current and previous postal addresses; your contact details such as telephone, fax and e-mail, details of any bank accounts, and Information you provide to access any interactive services.

    We may collect and process personal information about you when you register with us, when you use our products or services, when you visit us at our office(s), when corresponding with us by telephone or e-mail or otherwise or when you register via our Website. The information we receive may include technical details including your Internet Protocol (“IP”) address, your login information, browser type, operating system and platform and may also include information about your visit including, but not limited to, traffic data, location data, Weblogs and other communication data.

  3. PRIVACY PRINCIPLESWe will only collect and use your information where we have lawful grounds and legitimate business reasons to do so. We will be transparent in our dealings with you and will tell you about how we will collect and use your information. If we have collected your information for a particular purpose we will not use it for anything else unless you have been informed and, where relevant, your permission obtained. We will not ask for more information than we need for the purposes for which we are collecting it. We will update our records when you inform us your details have changed and we will continue to review and assess the quality of the information we hold on you. We will implement and adhere to information retention policies relating to your information and we will ensure that your information is securely disposed of at the end of the appropriate retention period. We will observe the rights granted to you under applicable privacy and data protection laws and will ensure that queries relating to privacy issues are promptly and transparently dealt with. We will train our staff on their privacy obligations. We will ensure we have appropriate security measures to protect your information and that when we outsource any processes, the supplier has appropriate security measures in place and we will require them to comply with these Privacy Principles.
  4. COOKIESYou may choose to block cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to log in to your account on our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system may issue cookies when you visit our Site.Kindly note that to the extent our Site is linking to social media sites, these sites may have their own opt in/opt out rules.

    We may obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. Some of the cookies we may use may be essential for the Site to operate. This website uses “analytical” cookies on each website page. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they’re using it. This helps us to improve the way our website works and to deliver a better and more personalised service, for example by making sure users are finding what they need easily. Read more about the individual analytical cookies we use and how to recognise them here https://www.google.com/policies/technologies/cookies/. If you register with us on our Site, you agree to our use of cookies.

  5. WHERE WE STORE YOUR PERSONAL DATAUnfortunately, the transmission of information via the internet may not be completely secure. Although we will do our best to protect your data, We cannot guarantee the security of data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

    The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your requirements, the processing of your financial transactions and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

  6. USES MADE OF INFORMATIONWe may use information held about you to post on social networking platforms (such as LinkedIn) but we will not post any of your personal information on such Sites.

    We may use information for general purposes, such as to improve our services, contact you, conduct research, and provide anonymous reporting for internal and external clients. Information may be used to carry out our obligations arising from any contracts entered into between you and us; to check details and assess your deal application; to verify your identity in order to prevent and detect crime and money laundering; to manage your account, and update the records we hold about you from time to time; to identify fraud; to identify unauthorised access to any portion or feature of our Site, or any other systems or networks connected to our Site or to any Sancus server, or to any of the services offered on or through our Site by hacking, password “mining” or any other illegitimate means; to trace your whereabouts and recover debts (if you do not repay money you have borrowed); to carry out statistical analysis and market research; to carry out regulatory checks; to allow you to participate in interactive features of our service, when you choose to do so; to ensure that content from our Site is presented in the most effective manner for you and for whatever device you are using to access our Site; to provide you with information, services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes; and to notify you about changes to our service.

  7. DISCLOSURE OF YOUR INFORMATION AND MARKETINGWe believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violation to our terms of use, or as otherwise required by law. We may also share information in response to subpoenas, court orders, or legal processes, or to establish or exercise our legal rights or defend against claims.

    We do not rent, sell, or share personal information about you with other people or non-affiliated companies except to provide products or services you may have requested, or when we have your permission, or in the following instances: we may provide your information to trusted partners who work on behalf of or with Us under confidentiality agreements. These trusted partners may use your personal information to help us communicate with you about our offers, services and products, however these trusted partners do not have any independent right to share this information. We may also use your data, or permit selected third parties to use your data, to provide you with information about services which may be of interest to you and we or they may contact you about these by e-mail, telephone or SMS. You may opt out of these services at any time by following the unsubscribe instructions we or they send with each message.

    We do not disclose information about identifiable individuals to third parties, but we may disclose anonymous information with selected third parties for research, statistical or analytical purposes.

    Where other parties participate in your deal, we may disclose your details including Sensitive Personal Data however we will only provide such information as we deem material to allow them to make decisions about their participation in the deal.

    We may be under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of use, or terms and conditions and any other agreements; or to protect our rights, property, or safety or those of our clients.

    We may disclose your personal information to any member of our Group or to third parties in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. We may transfer information about you if we merge with another company. In this event, you will be subject to a new privacy policy and you will be asked to agree to the new terms.

  8. ACCESS TO INFORMATIONYou have the right to ask for a copy of your information and to correct any inaccuracies. You can do this by contacting data.controller@sancus.com. Sancus will make every endeavour to respond to your request per the details found in our Website Terms and Conditions.
  9. CHANGES TO OUR PRIVACY POLICYWe may revise this privacy policy at any time. Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.
  10. COMPLAINTSIf you are dissatisfied with either an individual or our standard of service or any aspect of the delivery of our services, please refer to the Sancus complaints procedure set out on our Site or contact us at data.controller@sancus.com.
  11. CONTACTQuestions, comments and requests regarding this privacy policy are welcomed and should be addressed to data.controller@sancus.com

    Dated 16th January 2017