Introduction
The purpose of this notice is to provide you with information on our use of your personal data in accordance with the Data Protection Law, 2017 (the "DPL").
In this document, "we", "us" and "our" refers to Cittrust Online LLC and its or their affiliates and/or delegates.
Your Personal Data
We act as an intermediary for a number of international investment companies and fund managers with whom we have entered into agency agreements (each, a "Product Provider"). By virtue of making an investment through us and your associated interactions with us (whether past, present of future), you will provide us with certain personal information which constitutes personal data within the meaning of the DPL. In our use of your personal information, we will be characterised as a "data controller" for the purposes of the DPL. Our affiliates and delegates may act as "data processors" for the purposes of the DPL.
Who this Affects
If you are a natural person, this will affect you directly. If you are a corporate investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with personal information on individuals connected to you for any reason in relation to your investment through us, this will be relevant for those individuals and you should transmit this document to such individuals
Details of where we collect personal information from
- Our Fact Find document used in the initial stages of consultation;
- Emails and letters;
- Telephone conversations;
- The Policy application form;
- Public sources
Details of the information we will collect
- Name, date of birth, address and telephone number;
- Gender;
- Identification information such as passport number or driving licence number;
- Family details such as beneficiaries, children’s ages and education plans;
- Financial data such as financial history and needs, income, savings, bank & payment card details;
- Employment details such as job title and role;
- Profile data such as username and password for the service providers website; and
- Marketing preferences.
In most cases, we do not collect any “sensitive” personal information about you. Sensitive personal data includes:
- Your health, physical or mental;
- Information relating to criminal convictions and offences;
- Your race or ethnicity;
- Your religious, philosophical or political beliefs or opinions;
- Your sexual orientation.
However, we may be required to keep on record information relating to criminal behavior, Politically Exposed Persons and Sanctions to comply with the Anti-Money Laundering, Terrorist and Proliferation Financing legislation to ensure that we can prevent and report any suspicious activity.
Purpose for collecting this information
We gather this information to:
- Enable us to provide the most suitable advice in the selection of products and services available through us;
- To assist with any transactions related to the product you have selected;
- To provide information to your Product Provider to create and operate your policy;
- To meet our legal and regulatory obligations;
- To follow up with respect to the financial product you have selected, such as conducting an annual review;
- To provide you with information about other financial services that we offer.
Change of purpose
We will only use your personal information for the purposes for which we collect it, or where it is necessary for the purposes of our legitimate interests and such interests are not overridden by your interests, fundamental rights or freedoms. If you wish to have a more detailed explanation as to what we use your personal information for, please contact us.
Please note that we may process your personal information without your knowledge or consent, where this is required or permitted by law.
Sending information overseas
Your personal information will be provided to the relevant Product Provider. These may include certain entities located outside the our jurisdiction or the European Economic Area. The Product Providers will process your personal information for their own lawful purposes in connection with the financial product provided to you.
We also use selected third party service providers based outside of our jurisdiction and will transfer your personal information to establish, service and maintain your financial product.
Where we make a transfer of your personal information outside of our jurisdiction we will take the required steps to ensure that your personal information is protected. This will include placing the party we are transferring information to under contractual obligations to protect it to adequate standards.
Your duty to inform us of changes to your personal information
It is important that the personal information we hold about you is accurate and current. We also have obligations under the law to maintain up to date identity information. Please inform us of any changes to your personal information during the period of our relationship.
Personal Information retention period
We will only store your information for as long as is necessary for the purposes for which we process the information as set out in this document and to comply with our regulatory and/or legal obligations. Our maximum retention period is five years after the end of our relationship with you, to comply with applicable legal requirements.
If you decide not to purchase a financial product through us, with your consent, we will retain your information for a period of up to three years to enable us to service your needs if you were to change your mind.
Your Rights
You have certain rights and responsibilities under the DPL as summarized below. Such rights include:
1)The right to be informed
You have the right to be informed about the processing of your personal data.
2)The right to access your data
You are entitled to receive a copy of your personal data that we hold.
3)The right to correct your data
You have the right to have any inaccurate personal information about you rectified and to have any incomplete information about you completed.
4)The right to stop processing
In certain circumstances you have the right to request us to restrict the processing of your information.
5)The right to stop direct marketing
You have the right to request us to stop or not to begin direct marketing.
6)The right to complain/seek compensation
You have the right to make a complaint on how we have handled your personal data, you can contact us as described below and we will investigate the matter.
You also have the right to make a complaint to the supervisory authority.
We do not envisage that any decisions will be taken about you using fully automated means, however we will notify you in writing if this position changes.
Protection of your personal information
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have a number of organisational and technical security measures in place to prevent fraud and cybercrime.
We will restrict internal access to your information to only those that need to know to perform the purposes laid out above. Our staff are trained on our responsibilities around information security, fraud prevention and privacy obligations annually.
Tools such as firewalls, anti-virus software and malware protection are used across the business. Our internal procedures cover the storage, access and disclosure of your information.
We shall notify you of any personal data breach that is reasonably likely to result in a risk to your interests, fundamental rights or freedoms.
Cookies policy
Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. When you visit our website we may collect information from you automatically through cookies or similar technology. Further information can be found at https://www.allaboutcookies.org/.
Our cookies policy can be found here.
Changes to our privacy policy
Our Company keeps its privacy policy under regular review and will place any updates on this website. This privacy policy was last updated 1st October2019.
How to Contact us
If you have any questions about Our Company’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.
Email us at: info@cittrustonline.com