CLIENT PRIVACY NOTICE
We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Notice explains how Oakbridge Limited (“the Company”) collects, uses and discloses your personal data, and sets forth your rights in relation to the personal data it holds.
We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us, and supervisory authorities, in the event you have a complaint. This notice serves to inform you of the changes to data protection law under the Data Protection (Jersey) Law, 2018 (“DP Law”), as amended to incorporate legislation equivalent to EU Regulation 2016/679 (the “GDPR”).
The Company (“we”, “our”, “us”) aims to protect the privacy of our clients (“you”) as far as possible.
Where your details are provided to the Company as a consequence of your enlisting their services, then the Company, acting as a Data Controller may itself (or through a third party such as your chosen custodian (an “Administrator”) process any personal information we hold about you as our client. When processing your personal information, there may also be times where an Administrator will act as a data controller.
We recognise that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies. Where we do so, we will take appropriate steps to bring the amendment to your attention by publishing it on our website at www.oakbridge.je. This Privacy Notice was last updated on 29 Mar, 2019.
The Company has appointed an internal privacy team for you to contact if you have any questions or concerns about our personal data policies or practices. The Company’s privacy team can be contacted at firstname.lastname@example.org.
How we obtain your information
In the course of providing services to you, we collect information that personally identifies you.
The information we collect about you (or your directors, officers, employees, and/or beneficial owners) comes from:
The information we collect
As our client, we collect information that helps us to identify you and to manage our relationship with you. We also collect financial information about you, information about your transactions with us and information required for us to carry out anti-money laundering and other checks and to comply with our legal obligations.
As our client, information that we collect includes:
In limited cases, we also collect what is known as “special categories” of information. Our money laundering, sanctions, financial crime and fraud prevention checks sometimes results in us obtaining information about political opinion, actual or alleged criminal convictions and offences.
You are not obliged to provide us with your information where it is requested but we may be unable to provide certain products and services or proceed with our business relationship with you if you do not do so. Where this is the case, we will make you aware.
Our use of your information
Your personal data may be processed by the Company or an Administrator (or any of its affiliates, agents, employees, delegates or sub-contractors) for the following purposes:
How we transfer your information
The disclosure of personal information to the third parties set out above may involve the transfer of data to other jurisdictions outside Jersey and the European Economic Area (“EEA”) in accordance with the requirements of the DP Law, as amended or replaced from time to time. Such countries may not have the same data protection laws as your jurisdiction. Some of these countries may have lower standards of data protection than in your home country, and not all countries outside of Jersey and the EEA have data protection laws that are similar to those in Jersey and EEA, so they may not be regarded by the European Commission as providing an adequate level of data protection. Where we transfer your information outside of Jersey and the EEA, we will ensure that the transfer is subject to appropriate safeguards in accordance with data protection laws. Often, these safeguards include contractual safeguards. The Company has Service Level Agreements in place with their Administrators and any relevant parties to whom personal data will be transferred. Please do contact us if you would like more information about these safeguards (see the “Contact Us” section below for further details).
The Company and their Administrators will retain your personal information for as long as required for the Company or their Administrator to perform the Services and/or carry out the purposes for which the data was collected, or perform investigations in relation to the data depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that the Company retains your personal information.
You may have the following rights under data protection laws:
The Company takes the protection of your personal information seriously, and has appropriate technical and organisational measures and policies in place to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will only do so in an authorised manner and are subject to a duty of confidentiality. All staff of the Company are made aware of their information security responsibilities.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to contact us
If you have any questions about our use of your personal information, please be in touch with your Investment Advisor or our privacy team on email@example.com
Version Date: 29 March 2019.