It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the ‘What are your rights in relation to the personal data we hold about you?’ section below.
Who are we?
What personal data do we process about you?
We and our service providers collect the above information in a variety of ways. This includes from you directly and:
If you correspond with us via e-mail, we retain a copy of such correspondence for internal use. The information collected is also used to provide a record of communications between you us and to comply with any applicable legal and/or regulatory requirements.
Do we collect personal data about you from third parties?
We also collect your personal data from third parties:
How do we use your personal data?
We use your personal data:
In order for us to provide you with certain services, including but not limited to brokerage and research services, which require us to process your personal data due to regulatory and legal requirements (for example KYC and AML) the provision of information is mandatory.
If relevant data is not provided to us, then we will not be able to provide you with the full range of our services meaning that our services may only be offered with a limited scope or not at all. All other provision of your information is optional.
Cookies and similar technologies
Cookies are small pieces of information sent by a web server to a web browser which allows the server to uniquely identify the browser on each page. Other tracking technologies are also used which are similar to cookies. This can include pixel tags and tracking URLs. All these technologies are together referred to in this Policy as “Cookies”.
The types of Cookies that we use on our website, and the purposes for which they are used, are set out below:
If you don’t want to allow Cookies at all (other than 'strictly necessary cookies'), you can choose to “No, I Disagree” to accepting Cookies using the cookie consent management tool on our websites or rely on your browser’s settings to disable all Cookies. You can choose “Yes, I Agree” to accepting all Cookies. You can you can also accept or decline cookie categories (other than “strictly necessary cookies”) using the cookie consent management tool on our websites. Where you don't allow Cookies or delete or disable Cookies, certain features of our website may not be able to function.
To find out more about Cookies please visit: www.allaboutcookies.org or see www.youronlinechoices.eu which contains further information about behavioural advertising and online privacy.
For how long do we keep your personal data?
Where we process data for: (i) registration purposes, (ii) support purposes or (iii) in order to customize your website experience, we keep this data for the duration of the period where you are a user and for an additional five-year period from when you cease to be a user.
Where we process data for marketing purposes we will do so unless we receive a request from you to stop. We will hold a record of such data for five years from when you request us to stop.
Where we process data for website security, we hold this data for a maximum period of one year.
Who do we share your personal data with?
Where we send direct marketing materials to you, we send your personal data to third parties with whom we have contracted to provide these materials to you on our behalf and in our name. These third parties may be located inside or outside the EEA.
We also share your personal data with:
(a) to enable you to receive the services provided by our affiliate entities which may cover different financial services or be in different jurisdictions to those that we cover;
(b) to allows us to improve the services that we provide across the EFG Hermes group; and
(c) to allow us to produce analytical reports reflecting the services provided throughout the EFG Hermes group.
We also disclose your personal data to:
If it becomes relevant, we will share your personal data with a potential buyer and their advisers in connection with any proposed purchase, merger or acquisition of any part of our business.
Where is your personal data transferred?
When we share your personal data with the parties listed above, it involves transferring your personal data outside the European Economic Area (EEA), to countries where the level of protection of personal data has not been deemed adequate by the European Commission.
Where information is transferred outside the EEA, and this is to a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by the standard data protection clauses (as approved by the European Commission) or other appropriate transfer mechanisms (e.g. EU-US Privacy Shield, binding corporate rules). Please contact us using the contact details provided in the Annex below to obtain a copy of our standard data protection clauses or further information about other appropriate transfer mechanisms we rely on.
What are your rights in relation to the personal data we process about you?
Subject to the conditions prescribed in applicable laws, you have the right: (i) to access, rectify or request erasure of your personal data; (ii) to ask us to restrict processing of it; and (iii) to request portability of it
Subject to the conditions prescribed in applicable laws, you have the right (i) to object, on grounds relating to your particular situation, to processing of your personal data which is based on our or a third party’s legitimate interests; and (ii) to object to processing of your personal data for direct marketing purposes.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and Member State data protection laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.
You can exercise these rights by contacting us using the contact details provided in the Annex below.
You also have the right to lodge a complaint with a supervisory authority about our use of your personal data in the EU Member State of your habitual residence, place of work or place where you consider an alleged infringement has taken place.
How can you contact us?