3.1. Identity Verification and Account Management
As part of providing services, or information about our services, to you, we will need to verify your identity in order to set you up as a customer and we will need to use those details in order to effectively manage your account with us as to ensure that you are getting the best possible service from us. This may include third parties carrying out credit or identity checks on our behalf. We collect, process and disclose personal data to fulfil our contractual, regulatory and statutory obligations to our clients. It is in our legitimate business interest to do so and the use of your personal information in this way is necessary for us to deliver our contracted services to you. We also have an obligation to comply with applicable laws of the Financial Services Authority (FSA), Law Enforcement Agencies, among others. For the avoidance of doubt, the lawful basis under which we process your personal data is for the fulfilment of our contractual obligations to you, our legitimate interest and to fulfil Seven Capitals Foreign Brokerage Limited’ legal or statutory obligation.
3.2. Provisions, Improvement and Development of Products and Services
Upon account opening we will need to use your personal information to perform our services and comply with our obligations to you. It is in our legitimate interests to ensure that we provide you with the best products and services so we may regularly review your needs to ensure that you get the best possible products and services from us.
We may from time to time use personal information provided by you through your use of our services and/or through customer surveys to help us improve our products and services when you have opted to receive marketing materials from us, we will include instructions on how to opt out shall you wish to do so in the future.
3.3. Settlement of Enquiries and Disputes
Where we consider there to be a risk that we may need to defend or bring legal claims, we may retain your personal information as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims. We may also need to share this information with our insurers or legal advisers. How long we keep this information for will depend on the nature of the claim and how long we consider there to be a risk that we will need to defend or bring a claim. It is in our legitimate interests to use your personal information in such way.
3.4. Compliance with Applicable Laws and Regulations
We may need to use your personal information to comply with applicable laws, court order or other judicial process, or the requirements of any applicable regulatory authority and share your personal information with third parties including but not limited to auditors and regulators. For instance, to conduct anti-money laundering and due diligence checks, to detect and prevent fraud, to monitor and record phone calls, to inform you of any changes in our services, to respond to complaints and enquiries, to maintain your records up to date. We do this to comply with our legal obligations and because it is in our legitimate interest to do so.
3.5. Profiling and Automated Decision-Making
We may from time to time use personal information about you to form profiles about you so that we understand your needs and provide the very best products and services we can. We may also make decisions about you through automated profiling or automated credit checks which could affect your ability to use our services. We may need to do this either to perform our legal obligations or because it is in our legitimate interest to use your personal information in such a way. You can object to an automated decision being made and ask us to verify the information obtained and or request another staff member to review it. Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, performance at work, economic situations, health, personal preferences, interests, reliability, behaviour, location, movements etc.
We may collect your name and contact details (such as your email address, phone number or address) in order to send you information about our products and services which you might be interested in. We may collect this directly from you, or through a third party. If a third party collected your name and contact details, they will only pass those details to us for marketing purposes if you have consented to them doing so. It is in our legitimate interest to use your personal information in such way.
You always have the right to “opt out” of receiving our marketing. You can exercise the right at any time by contacting us. If we send you any marketing emails, we will always provide an unsubscribe option to allow you to opt out of any further marketing emails. If you “opt-out” of our marketing materials, you will be added to our suppression list to ensure we do not accidentally send you further marketing. We never share your name or contact details with third parties for marketing purposes unless we have your “opt-in” consent to share your details with a specific third party for them to send you marketing. We do use third party service providers to send out our marketing, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. It is in our legitimate interest to use your personal information in such way.
We retain your details on our marketing list until you “opt-out” at which point we add you to our suppression list. We keep that suppression list indefinitely to comply with our legal obligations to ensure we do not accidentally send you any more marketing.
3.7. Website Information
Our web pages and e-mails may contain web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence. Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. However, where your personal information is not in an anonymised form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market.
3.8. References and Surveys
From time to time, third parties, such as credit agencies may approach us to provide a credit reference about you for credit and identity checks. It may be in our legitimate interest to comply with our legal obligations or we may be obliged to provide such a reference in order to comply with a legal obligation.
From time to time, we may send you surveys as part of our customer feedback process and it is in our legitimate interest to ask for feedback to ensure that we provide the best service to you. However, we may from time to time also ask you to participate in other surveys and if you agree to participate in such surveys we rely on your consent to use the personal information we collect as part of such survey. All responses to any survey we send out whether for customer feedback or otherwise will be aggregated and depersonalised before survey results are shared with any third parties.
3.9. Internal Business and Record Keeping
We may need to process your personal information for internal business and research purposes and record keeping
purposes. Such processing is in our own legitimate interests and is required in order to comply with our legal and regulatory obligations. This may include any communications that we have with you in relation to the services we provide to you and our relationship with you. We will also keep records to ensure that you comply with your obligations under any contract you have entered into with us.
3.10. Our Premises
We collect information about visitors to our premises. We may record information on your visit, including the date and time, who you are visiting, your name, employer, contact details and vehicle registration number. If you have an accident at our premises, this may include an account of your accident. It is in our legitimate interest to do so.
We may operate CCTV at our premises which may record you and your activities. We display notices to make it clear what areas are subject to surveillance. We only release footage following a warrant or formal request from law enforcement, or as necessary in relation to disputes. It is not only a legal requirement but also in our legitimate interest to do so.
3.11. Sharing with Cooperation Partners and Suppliers
We may share your personal information with cooperation partners who provide services on our behalf or have introduced you to us or other cooperation partners or suppliers we have engaged with. It is in our legitimate interest to use your personal information in such way to provide you with our services.
3.12. Sharing with Group Entities and Corporate Restructuring
We may share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganization or group restructuring exercise, and for system maintenance support and hosting of data. It is in our legitimate interest to use your personal information in such way.
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business where necessary in connection with the purposes which your information was collected for. It is in our legitimate interest to do so.