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Conflicts of Interest Policy
This Privacy Notice sets out how we use and look after the personal information we collect from you. We are the data controller, responsible for the processing of any personal data you give us. We take reasonable care to keep your information secure and to prevent any unauthorised access to or use of it.
What personal data we hold on you
Personal data means any information about an individual from which that individual can be identified.
We collect, use, store and transfer some personal data of our clients.
You provide information about yourself when you register with Optiva, and by filling in our application forms at an event, online or in a meeting or by corresponding with us by phone, e-mail or otherwise.
The information you give us may include your name, date of birth, National Insurance number / Identifier, address, e-mail address, phone number, gender, financial priorities and attitude to risk and the contact details of a third party for transactional purposes. We may also ask for relevant health information, which is classed as special category personal data. Where we hold this data, it will be with the explicit consent of the participant or, if applicable, the participant’s registered carer / attorney.
Where we need to collect personal data to fulfil Optiva’s responsibilities and you do not provide that data, we will not be able honour or administer for you the services you require.
Why we need your personal data
We will only use personal data for purposes for which it has been specifically provided.
The reason we need clients’ personal data is to be able to operate and administer your account and provide the client services and the relationship you are signing up to when you open an account with Optiva. Our lawful basis for processing your personal data is that we have a contractual obligation to you as a client to provide the services you are registering for.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|Purpose/ Processing Activity||Lawful Basis for processing under Article 6 of the GDPR|
|Processing client application forms||Performance of a contract|
|Contacting clients||Performance of a contract|
|Sharing data with James Brearley & Sons Limited, JHC Limited, the Financial Conduct Authority, stock exchanges of which we are a member, law enforcement and government agencies||Performance of a contract, legal obligation|
|Sharing data with third party service or facility providers||Performance of a contract|
|Sending out marketing or promotional information such as newsletters and information about products and services||Consent. We will only send you direct marketing if you are an existing client and you have not previously objected to this marketing, or if you have actively provided your consent|
Who we share your personal data with
When you become a client of Optiva, your information, as a client or interested party will be entered onto the Neon CRM database, which is administered by JHC Limited. We also pass your information to James Brearley & Sons Limited, our settlement agent and custodian, for account opening purposes. We may also pass information to the FCA for regulatory purposes.
We may share your personal data with other selected third parties, suppliers and sub-contractors such as service providers. Third-party service providers will only process your personal data for specified purposes and in accordance with our instructions.
We may disclose your personal information to third parties where there is a legal obligation for us to do so; or to protect the rights, property, or safety of our clients and affiliates, or others.
Optiva’s data processing may require your personal data to be transferred outside of the UK. Where the firm does transfer your personal data overseas it is with the sufficient appropriate safeguards in place to ensure the security of that personal data.
Protection of your personal data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
How we use your Personal Information
In general, the personal information will be used for the following purposes:
Processing and executing transactions on the clients’ behalf, answering your questions on Optiva products and services, or providing you with technical updates on our products and services.
Analysing your personal information including your personal preferences in order to provide you with personalised marketing information on Optiva products, services and promotions, as well as on products and services of partners of Optiva.
You will receive this information by email, sms, over the phone or by personalised mail only if you have asked to receive such messages from Optiva and its commercial partners. You will receive adequate information on our partners at the time we collect your data.
Optiva may add additional data received from third parties to your personal information for analysis and marketing purposes.
Establishing statistics on your use of the website, for marketing and analysis, in order to improve our website and our offers.
Transferring your personal information to third parties for the purposes set out above.
For a detailed description of how we use your information and how you can control its use, we invite you to examine our specific online or offline privacy policies.
How long we hold your personal data
We keep personal data on our participants and members while they continue to be client or are otherwise actively involved with us. We will delete this data 6 years after a client has left or otherwise ended their client relationship, or sooner if specifically requested and we are allowed by regulation to do so. We may need to retain some personal data for longer for legal or regulatory purposes. The personal data that is stored on the JHC CRM and James Brearley Figaro systems is subject to their respective privacy policies, so we advise you to review those policies together with this notice.
Your rights regarding your personal data
As a data subject you may have the right at any time to request access to, rectification or erasure of your personal data; to restrict or object to certain kinds of processing of your personal data, including direct marketing and the porting of your personal data. If you feel your personal data has been treated inappropriately you have the right to complain to the UK’s data protection supervisory authority (ICO) about the processing of your personal data.
As a data subject you are not obliged to share your personal data with Optiva. If you choose not to share your personal data with us, we may need to close your account.
We may update this Privacy Notice from time to time, and will inform you of any changes in how we handle your personal data.
If you have any questions about this Privacy Notice then please contact Jeremy King.
Optiva Securities Limited
+44 (0) 203 981 4187
Information Commissioner’s Office (ICO)
Information Commissioner’s Office
Telephone: 0303 123 1113