Privacy Notice

This privacy notice explains how we use personal information we collect about you.

What information do we collect about you?

We collect information about you when you engage with us for financial advice, use of our apps, trading services, foreign exchange service or any investment banking services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.

We may collect information when you voluntarily complete client surveys or provide feedback to us.

Information relating to usage of our website is collected when you visit and communicate with us, complete forms or make a purchase. Information may also include the resources you access, but is not limited to traffic data, location data, weblogs and other communication data.

We shall have the right to, in accordance with the applicable laws, to request to you for more information or data throughout the course of the business relationship, and to take reasonable measures to meet the regulatory requirements, and you undertake to provide proper assistance to such measures.

Why do we need to collect and use personal data?

The lawful basis that we intend to use for the processing of your data is for the ‘Performance of a Contract’ or ‘Legitimate Interests’.  The information that we collect about you is essential for us to be able to effectively carry out the services that you require from us. In addition, without collecting your personal data, we would be unable to fulfil our legal and regulatory obligations. Where special category or sensitive data is required, we will obtain your explicit consent in order to collect and process this information. This information may be about physical or mental health, lifestyle choice, racial origin, political beliefs etc. and we will obtain your consent before processing any sensitive personal data.

If we give information about another person, then we will confirm that he/she has given their consent for us to act on their behalf.

How will we use the information about you?

We collect information about you to provide you with the services for which you engage with us.

Who might we share your information with?

If you agree, we may contact you about other products or services that we think may be of interest to you.

If you agree, we will pass on your personal information to other deVere Group companies, especially if you move jurisdiction, so that you will receive ongoing services; they may also offer you their own products and services.

This consent to transfer your data to a new controller will be obtained at the time of your relocation and will require you to sign a Data Transfer Form.

We will not share your information for marketing purposes with companies outside our group of companies.

We do not sell, rent or lease our client personal data to third parties and it is our policy to only disclose your personal information as required or authorized by law. In order to deliver services to you effectively, we may send your details to third party providers, such as those we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.

Where third parties are involved in processing your data, including those based outside of the European Economic Area (EEA) we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our written instructions.

Where it is necessary for your personal data to be forwarded to a third party, we will use appropriate security measures to protect your personal data in transit. This could include password protection and/or encryption of data. Administration services are outsourced and provided by deVere Group back office administration, based in Malta.

To fulfil our obligations in respect of prevention of money laundering and other financial crime, we may send your details to third party agencies for identity verification purposes.

Where we need to collect personal 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 trying to enter into with you or perform the required services. In this case, the services offered may be cancelled but we will notify you if this is the case.

How long do we keep hold of your information?

All information you provide to us is stored on our secure servers. In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we are subject to regulatory requirements to retain data for specified minimum periods. We reserve the right to retain data for longer under the legal basis of ‘Legitimate Interests’. In any case, we will not retain your personal data for longer than 7 years past the time of your death.  

You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and Legitimate Interests as noted above.

Your Individual Rights

You have a right of access to your information. We will provide your information within one month of your request without charge. In order to do this, please contact directly your assigned consultant or the client services team at [email protected].

You have the right of data portability. When your personal data is processed by automated means, you have the right to ask us to move your personal data to another organisation for their use.

You have the right of rectification meaning we have an obligation to ensure your personal information is accurate and up to date. If you believe your data is inaccurate, please notify us and we will rectify this for you.

You have the right to restrict processing. Should you contest the accuracy of the data held about you, in some circumstances, we can restrict data processing.

You have the right to object to your data being used in certain circumstances, for example, direct marketing.

You have rights relating to automated decision making, which means you have the right to not be subject to decision making based solely on automated processing.

You have the right of erasure which is to request the deletion of your data from our system, although we will only be able to comply where it does not conflict with our regulatory requirements.

Marketing

We would like to send you information about our products and services and those of other companies in the group which may be of interest to you. If you have agreed to receive marketing information, you may opt out at a later date.

You have a right at any time to stop us from contacting you for marketing purposes or giving information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by email or post by writing to the address given.

Cookies

We use cookies to track visitor use of the website and to compile statistical reports on website activity. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information.  We may use your information collected from the website to personalise your repeat visits to the site. Any data used to collate statistics from your visits will not identify you personally and will not breach any personal details.  

For further information visit http://www.allaboutcookies.org/

You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

Other websites

Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

What can you do if you are unhappy with how your personal data is processed?

You also have the right to lodge a complaint with the supervisory authority for data protection.  

Changes to our privacy policy

We keep our privacy policy under regular review and we will inform you of any changes when they occur, or we will place any updates on our website.

This privacy policy was last updated on 25th May 2018.