Who We Are
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This Policy applies to you if you are an individual client, or their authorised person. It applies to you if you are a person associated with a corporate client (such as a director, beneficial owner or authorised signatory). This Policy also applies to prospective clients and persons who have asked to receive our promotional or other material.
Our Commitment to You
We are bound by the Data Protection Principles contained in the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
The Data Protection Principles are as follows:
Personal data collected must be:
• used fairly, lawfully and transparently;
• used for specified, explicit purposes;
• used in a way that is adequate, relevant and limited to only what is necessary;
• accurate and, where necessary, kept up to date;
• kept for no longer than is necessary; handled in a way that ensures appropriate security, including protection against unlawful or unauthorised processing, access, loss, destruction or damage.
This Policy will be reviewed periodically to take account of changes to our operations or practices and, further, to make sure it remains appropriate to any changes in law, technology and the business environment. You should check this page from time to time to ensure that you are aware of any changes. Any information held will be governed by our most current Policy.
The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
If you visit our website, contact us about employment, or to enquire about our products and services or are a customer making contact with us via our website or by telephone or email, we may collect, store, use and transfer different kinds of personal data about you. We may collect and process the following data about you:
• Identity Data may include but is not limited to title, name, username or similar identifier, date of birth, gender, national/tax identification number ID and our passport number;
• Contact Data may include address, email address and telephone/mobile number;
• Technical Data may include but is not limited to internet protocol (IP) address, Details of any orders or transactions (historic or otherwise) that you have carried out through our website;
• Usage Data may include your information about how you use our website, products and services;
• Marketing and Communications Data may include your preferences in receiving marketing from us and your communication preferences.
• Profile Data may include information about your investment interests and history, your income and wealth including details about your assets and liabilities, account balances, tax and financial statements, any event history and feedback and survey responses.
• Any similar information
If You Fail To Provide Personal Data
Where we need to collect data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are attempting or intending to enter into with you (for example, to provide you with our services or open an account for you). In this case we may have to suspend or cancel a service or agreement with you, but we will notify you of this at the time.
How We Use The Data
We use information held about you in the following ways:
• to ensure that the content in our website is presented to you in the most effective manner;
• to provide you with products and services that you request from us or, where you have consented to be contacted, for products and services that we feel may be of interest to you;
• managing and administering the products and services provided to you;
• keeping you updated as a client in relation to changes to our services and relevant matters;
• to carry out our obligations arising from any contracts entered into between you and us.
We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by email.
Who We Disclose The Information To
Depending on the products and services concerned and the relevant restrictions on sensitive data, personal information may be disclosed to:
• any member of our group of companies who provide financial and other services;
• potential successors in title to our business;
• third party consultants, contractors or other service providers who may access your personal information when providing services (including but not limited to IT support services) to us;
• any organisation or person acting on your behalf to whom you request us to provide information, including your solicitor, banker, auditors, insurers and accountants based in the UK who provide consultancy, legal, banking accounting and insurance services;
• third parties where it is necessary to process a transaction or provide services you have requested;
• The Financial Conduct Authority, Financial Ombudsman Service, National Crime Agency, HM Revenue & Customs, regulators, law enforcement organisations, police and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances (such as criminal activity, suspected fraud or tax evasion);
• credit providers, courts, tribunals and regulatory authorities in response to legal and regulatory requests, as agreed or authorised by law;
• auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes, in any jurisdiction where we operate;
• at your request or with your consent.
Your Rights in Relation To Your Personal Information
You have a number of legal rights in relation to the personal information that we hold about you. These rights include:
• request access to your personal information ("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 lawfully processing it.
• withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so.
• 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 below).
• object to processing of your personal information where we are relying on a legitimate interest (or those 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 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.
• lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us. If you wish to exercise these rights, please contact MBU Capital in writing.
You can find out more information about your rights by contacting the Information Commissioner’s Office, or by searching their website at www.ico.org.uk.
Please note that the application of these rights varies according to the legal basis used to process your data. In certain circumstances we are required to retain copies of information we hold about you by other regulations. In this instance we will not be able to erase or modify the data.
Data Security and Safeguard Measures
Our security measures are designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorised manner, altered or disclosed. We limit access of information only to those relevant employees or partners that need to know the information in order to enable the carrying out of the Agreement between us. We do not hold or store Credit/Debit card data.
We have procedures in place to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally obliged to do so.
We will not keep your personal information for any longer than is necessary to fulfil the purposes we collected it for or for the purpose of any legal, accounting or regulatory requirements. We will generally retain our clients’ data for a period of up to 7 years after a contract or agreement has ended.
While we will use all reasonable efforts to safeguard our clients’ personal information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data transferred from you, or to you via the internet.
Your use of the Website will signify that you agree to any such changes. Owing to the global nature of the Internet infrastructure, the information you provide may be transferred in transit to countries outside the European Economic Area. We may transfer your personal information outside the European Economic Area (“EEA”) to other of our group companies as well as processors who are engaged on our behalf. To the extent we transfer your information outside the EEA, we will ensure that the transfer is lawful and that there are appropriate security arrangements. In order to transfer personal information to third parties in territories where applicable legislation may not be adequate, we will enter into arrangements with such third parties to ensure appropriate and suitable measures based on standard contractual terms and conditions adopted by the European Commission.
Where we make transfers to third parties in the US, we may in some cases rely on applicable standard contractual clauses, binding corporate rules or any other equivalent applicable arrangements.
We are not responsible for the privacy policies and practices of other websites even if you accessed a third-party website using links from our Website. We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have concerns or questions. How to contact us.
If you have any questions regarding this Policy, wish to access or change your information or have a complaint, or if you have any questions about security on our Website, you may email us at firstname.lastname@example.org.
You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO. Should you have any concerns please contact the Compliance Officer at MBU Capital Ltd in the first instance.
MBU Capital, 65 Curzon Street, Mayfair, London, W1J 8PE
+44 (0) 207 100 7860