Tavira Securities Privacy Notice

May 2018

Tavira are an agency broker and investment manager specialising in global execution and investment management. For the purpose of the General Data Protection Regulation (“the GDPR”), Tavira are a data controller in respect of any personal data we collect.Tavira may collect and process the personal data of relevant persons and this Privacy Notice explains how Tavira will manage the personal data of such individuals, why Tavira uses it and how individuals may contact Tavira in relation to the use of personal data.

Personal data means any information which Tavira has or obtains, or which an Individual provides to Tavira or its service providers, from which that individual can be directly or indirectly personally identified such as name, title, address, email address, telephone numbers, date of birth, nationality, place of birth, passport details and bank details.

We may also collect and process personal data of individuals from other sources as part of Tavira’s usual due diligence processes.

Such personal data will be held in confidence and processed in accordance with relevant data protection legislation or regulation.

Your Rights

You have certain rights in relation to your personal data.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are processing it lawfully.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see above).

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party in a machine-readable, commonly used and structured format.

If you want to exercise any of these rights then please contact us. The various rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you wish to withdraw your consent or object to processing, we may need to discuss with you whether our use of your data needs to continue for other lawful purposes, such as fulfilment of a legal or contractual requirement.

We will respond to your request within one month of receipt of your request. In some cases we may not be able to fulfil your request to exercise the right before this date, and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Fees

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to complain

If you wish to request further information about any of the above rights, or if you are unhappy with how we have handled your information, please contact us.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office: https://ico.org.uk/global/contact-us/ or 0303 123 1113.

Personal Data Use

Tavira collects and processes personal data for the management of its business including Human Resources applications. This includes:

  • Client Onboarding and Anti Money Laundering checks
  • Risk and Compliance Management
  • Legal, Regulatory and Tax obligations
  • Asset Management and its operations
  • Fulfilling transaction and settlement obligations
  • Marketing and Communication
  • Human Resources and Payroll obligations
  • Fraud and Financial Crime obligations

Information for Marketing Purpose

We use your information to identify products, services and events that we think may be of interest to you.

We will only send you marketing messages where you have consented to such contact, or in the case of products and services, where these are similar to those that we have already provided to you.

You have the right to ask us not to not send you marketing messages by post, telephone or e-mail or any combination of these at any time. You can also let us know at any time that you wish to change your mind and to start receiving such messages.

You can do this:

by replying directly to the marketing message;

at any time by contacting us.

If you choose to unsubscribe, we will cease to send you such communications as mentioned above.

Sharing of Personal Data

We may disclose your personal data with:

  • Tax, Audit and Regulatory authorities where law or regulation in good faith requires us to disclose this data
  • Third party service providers working on behalf of the firm
  • Marketing platform suppliers
  • Third party outsourced IT and document storage providers
  • Third party Compliance providers working on specific firm projects
  • External reference agencies, examining bodies, past and present employers for employment candidates

We will take steps to ensure that the personal data is accessed only by staff of our affiliates and those at Tavira that have a need to do so for the purposes described in this notice.

We may also share your personal data with third parties outside our corporate group for the following purposes:

  • if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third-party buyer
  • to third party contractors for the purposes of providing services to us, including, IT and communications providers, law firms, accountants and auditors. These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice

Our Bases for Collecting and Using the Information

We are entitled to use your personal data in the ways set out in this Privacy Notice on the following bases:

the use of personal data in this way is necessary for the performance of a contract with you for provision of our products and/or services or to take steps at your request prior to entering into such a contract;

we have legal obligations that we have to discharge;

the use of your personal data is necessary for our legitimate interests in: ensuring the quality of the products and services we provide to you; collecting information for marketing purposes;

communicating with you; and

statistical analysis;

you have consented to such use; and/or

to establish, exercise or defend our legal rights for the purposes of legal proceedings.

If provision of your personal information is a legal or contractual requirement or a requirement necessary to enter into a contract with us, and you choose not to provide it, we may not be able to perform some of the tasks we need to in order to provide certain products or services to you.

If you do choose to provide your consent you can withdraw it at any time by contacting us.

You have the following rights, in certain circumstances, in relation to your personal information:

Data Rights

You have the following rights, in certain circumstances, in relation to your personal information:

  • the right to access your personal information via a Data Access Request
  • the right to rectify your personal information
  • the right to restrict the processing of your personal information
  • the right to request that your personal information be erased (right to be forgotten); every effort will be made subject to certain legal and regulatory obligations
  • the right to object to processing of your personal information
  • the right to data portability
  • the right to be informed

Recording Communications

We and persons acting on our behalf may record and monitor communications (including telephone conversations, emails, instant messaging, chat rooms, fax and other electronic communications) between employees of Tavira and also of non-Tavira personnel (such as employees of our clients). This is solely carried out to the extent permitted by law and industry regulation for legitimate business purposes or other purposes permitted or required by law. Data collected for but not limited to:

  • Applicable law and regulation
  • Administration and Operations
  • Internal policy and procedures
  • Legal, Audit and Compliance
  • Security, Fraud and Financial Crime

Transfer of Data outside the EU

The disclosure of personal information between Tavira and third parties may involve the transfer of personal data to foreign jurisdictions that do not impose the same level of data protection as that to which the relevant Tavira entities are subject. Any such transfers will only be made where permitted by law and, in all cases, where Tavira is able to ensure appropriate data protection mechanisms are in place.

Retention Period

Tavira is obliged to retain certain information to ensure accuracy, to help maintain quality of service and for legal, regulatory, fraud prevention and legitimate business purposes.

Other information will be retained for no longer than is necessary for the purpose for which it was obtained by Tavira or as required or permitted for legal, regulatory, fraud prevention and legitimate business purposes. In general, Tavira (or its service providers on its behalf) will hold this information for a period of five years from the termination of the relevant business relationship, unless it is obliged to hold it for a longer period under law or applicable regulations.

Security

We acknowledge that the information you provide may be confidential and will maintain the confidentiality of and protect your information in accordance with our normal procedures and all applicable laws. We employ appropriate technical and organisational security measures to help protect your personal data against loss and to guard against access by unauthorised persons. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

In addition, those employees, agents, contractors and other third parties who process your personal data will only do so on our instructions and they will be subject to a duty of confidentiality.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data we cannot guarantee the security of your data. Any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.

Changes to our Privacy Notice

We reserve the right, at our discretion, to change, modify, add to, or remove portions from, our Privacy

Notice. We will of course notify you of any changes where we are required to do so.

Contact Us

Any queries or complaints regarding the use of personal data by Tavira and/or the exercising of individual rights should be either emailed to data.privacy@tavirasecurities.com or a letter sent to:

The Compliance Officer

Tavira Securities Limited

88 Wood Street

London

EC2V 7DA

Visit us: Tavira Securities Limited - 13th Floor - 88 Wood Street - London EC2V 7DA.