The personal information we process
- your identification information (which may include your name, ID card and passport numbers, nationality, place and date of birth, gender, photograph and/or IP address and personal information relating to claims, court cases and convictions, politically exposed person (PEP) status, personal information available in the public domain and such other information as may be necessary for us to provide our services and to complete our client due diligence and on-boarding processes and discharge or AML/CFT obligations);
- your tax status information (which may include your tax residency, tax ID and tax status);
- your contact information (which may include postal residential and business addresses, personal and business e-mail address and your home, business and mobile telephone numbers);
- your family relationships (which may include your marital status, the identity of your spouse and the number of children that you have);
- your professional and employment information (which may include your level of education and professional qualifications, your employment, employer’s name and details of directorships and other offices which you may hold);
- financial information, sources of wealth and your assets (which may include details of your assets, sources of wealth, shareholdings and your beneficial interest in assets, your bank details and your credit history); and
- personal information regarding people connected to you, either by way of professional (or other) association or by way of family relationship.
The list set out above is not exhaustive, and there may be other personal information which we collect, store and use in the context of the client relationship.
Where we obtain your personal information
The majority of the personal information which we process will be directly collected from you. We collect your personal information from the following sources:
- personal information which you give to us, including but not limited to: (i) on such other forms and documents as we may request you complete or provide in relation to the administration/management of any of our services; (ii) information gathered through client due diligence carried out as part of our compliance with regulatory requirements; (iii) any personal information provided by way of correspondence with us by phone, e-mail or otherwise;
- personal information we receive from third party sources, such as: (i) entities in which you or someone connected to you has an interest; (ii) your legal and/or financial advisors; (iii) other financial institutions who hold and process your personal information; (iv) credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements;
- personal information received in the course of dealing with advisors, regulators, official authorities and service providers by whom you are employed or engaged or for whom you act;
- databases made publicly available by third parties.
Why we collect your personal information
The lawful basis under which personal information will be processed:
Unless we inform you otherwise then we may hold and process your personal information on the following lawful grounds:
- the processing is necessary to comply with our legal obligations;
- the processing is necessary for our legitimate interests or the legitimate interests of a third party to whom your personal information is disclosed, provided your interests and fundamental rights do not override those interests;
- the processing is necessary for the performance of a contract to which you are a party, or to take such steps, at your request, with a view to entering you into such a contract;
- the processing is necessary in our performance of a public task;
- the processing is necessary to exercise, bring or defend a legal claim; and
- in exceptional circumstances, where we have obtained your consent to processing your personal information for a specific purpose.
The purposes of processing:
We process your personal information for a variety of purposes in order to perform our obligations under the contract(s) between you and us and/or a member of the Iroko group, to comply with legal obligations or otherwise in pursuit of our legitimate interests. We have set out below the purposes for which we process your personal information:
- to communicate with you as necessary in connection with transactions to be considered or entered into between you and us and/or a member of the Iroko group via email, phone, mail or other means of communication;
- to conduct Know Your Customer (KYC) and other pre-transaction checks necessary in order to consider a client relationship with you;
- to produce legal documentation for transactions between you and us and/or a member of the Iroko group;
- to make payments or confirm the source of receipts of sums due under legal transaction documentation entered into between you and us and/or a member of the Iroko group;
- the day to day processing and management of any transaction between you and us and/or a member of the Iroko group;
- to monitor and record, including telephone and electronic communications and transactions, for: (i) quality, business analysis and related purposes in order to improve service delivery; and (ii) investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act);
- to enforce or defend our legal and contractual rights or those of third-party service providers;
- to comply with a legal or regulatory obligation imposed on us;
- to collect, process, transfer and store customer due diligence, source of funds information and verification data under applicable anti-money laundering and terrorist financing laws and regulations; and
- to liaise with or report to any regulatory authority (including tax authorities) with whom we are either required to cooperate or report to, or with whom we decide or deem it is appropriate to cooperate.
Sharing personal information
We may share your personal information with any member of the Iroko group and third parties including insurers, banks, financial institutions or other third-party lenders, IT service providers, auditors and legal professionals based in or outside of the UK. We may also share your personal information in the context of a merger, sale or acquisition, or other change in our organisational structure.
We will share your personal information with other parties (including and member of the Iroko group) only in limited circumstances and where this is necessary for the performance of contracts or to comply with a legal obligation, or otherwise in pursuit of our legitimate interests.
How long personal information will be retained
We will retain your personal information for the longer of (i) the period required by applicable law; or (ii) such other period necessary for us to meet our operational obligations, such as proper account maintenance, facilitating client relationship management, and responding to legal claims or regulatory requests. Most personal information collected is kept for the duration of the contractual relationship with you plus a period of at least six years after the end of the contractual relationship, or as otherwise required by applicable law. Records may be retained for longer periods if it cannot be deleted due to legal, technical or regulatory reasons.
Access to and control of personal information
There are a number of rights you can exercise over your personal information held and processed by us, including the right to:
- Access: you can obtain information relating to the processing of your personal information, and a copy of such personal information.
- Rectify: where you consider that your personal information is inaccurate or incomplete, you can require that such personal information be modified accordingly.
- Erase: you can require the deletion of your personal information, to the extent permitted by law.
- Restrict: you can request the restriction of the processing of your personal information.
- Object: you can object to the processing of your personal information, on grounds relating to your particular situation.
- Withdraw your consent: where you have given your consent for the processing of your personal information, you have the right to withdraw your consent at any time.
- Data portability: where legally applicable, you have the right to have the personal information you have provided to us be returned to you or, where technically feasible, transferred to a third party.
There may be legal or other official reasons why we need to keep or use your personal information. However, please tell us if you think that we should not be using it. If you require further information, or if you wish to exercise the rights listed above, please send an email to the Data Controller as follows: [email protected]
You are also entitled to raise any concern about how your personal information is being processed with the Information Commissioner’s Office (ICO) by going to the ICO website: www.ICO.org.uk or contacting the ICO on 0303 123 1113.
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 measure to ensure that your personal information is not disclosed to any person who has no right to receive it.