Privacy Policy
This Privacy Policy (as updated and amended from time to time) is available at those websites (each a “website”) owned by Execution Limited (company number 4058971 with registered office at Block D, The Old Truman Brewery, 91 Brick Lane, London, E1 6QL) and operated for and on behalf of itself and all entities within its group (“Execution Group”) and it is also available at websites owned and operated by other members of the Execution Group, including Sourcecap International Limited.
The terms “we”, “us”, “our” and “ours” when used in this Privacy Policy means the Execution Group of companies (and subject to change from time to time) which are available on request by calling us on 0207 426 4211 or by writing to us at the address below.
The terms “you”, “your” and “yours” when used in this Privacy Policy mean any user of our website, enquirer, customer, employee or consultant of the Execution Group.
Introduction to Privacy Policy
We are committed to the privacy and confidentiality of information provided by you to us. This Privacy Policy describes our current policies and practices with regard to Personal Data collected by us from you directly and/or through the website where such Personal Data is protected by the Data Protection Act 1998 (“DPA”). The term “Personal Data” refers to personally identifiable information about you, such as your name, job description, health related data, birthday, e-mail address or mailing address.
Please note that by submitting Personal Data manually or in electronic form to us and/or by using our website you give your consent that all Personal Data on each occasion that you submit may be processed by, and/or shared within the Execution Group, in the manner and for the purposes described in this Privacy Policy.
Notification of changes to this Privacy Policy
We are continually improving our methods of communication and adding new functionality and features to our website and to our existing services. Due to these ongoing changes, changes in the law and the changing nature of technology, our data practices will change from time to time. If and when our data practices change, we will notify you of the changes by posting our updated Privacy Policy on our website. We encourage you to check our Privacy Policy frequently.
Collection of Personal Data including e-mail addresses
You may provide us with your Personal Data in order to receive information, advice, products or services from us or in connection with your job application or employment by us. We may request personal information about you such as your name, postal address, email address, telephone numbers and we may ask for information which enables us to provide a personalised service to you. The information you give us is either manually or electronically stored in our databases.
We sometimes supplement the information that you provide with information that is received from third parties. For instance, if inaccurate post codes are received, we will use third party software to fix them.
To comply with money laundering regulations, we may need to request additional evidence of identity from you, and may use a credit reference agency for this purpose (which will record that an enquiry has been made).
We also reserve the right to monitor, intercept and/or record your communication with us by mail, voice, email or any other form of transmission for the purposes of quality control, security, regulatory and other business needs. We may reject, delay or remove content from emails which have a nature, content or attachments which may disrupt our system or because they may pose security risks. We may also filter out emails which contain certain content which is deemed offensive or unwanted spam. Unavoidably such filtering may affect the delivery of some “innocent” emails. Any Personal Data contained in such recorded information will be processed in accordance with the terms of this Privacy Policy.
We may also receive your Personal Data from other members of the Execution Group, our service providers, agents, advisers including external independent financial advisers (IFAs), brokers or business partners. Where Personal Data is disclosed to us by third parties, it is the obligation of the disclosing party to ensure such Personal Data is disclosed with requisite authority and consent and we will process such Personal Data in accordance with this Privacy Policy.
If you provide us with the Personal Data of a third party pursuant to a power of attorney, we may process such Personal Data (including information about the third party’s mental health) in order to provide information, goods or services to the third party for whom you act as attorney. In addition, we may hold information about your position as attorney for the purpose of administering products or services to the third party for whom you act as attorney.
Use of Personal Data
We process your Personal Data, and share your Personal Data with other members of the Execution Group, or others, only for specific and limited purposes. We ask only for data that is adequate, relevant and not excessive for those purposes. Some of these purposes may include the following:
o To provide the financial and investment services you specified (including but not limited to providing investment advice and research, execution of sales and trading, and corporate access services).
o To process your customer application form(s) and associated documentation including, where relevant, categorising you as a Professional Client or a Retail Client under the Rules of the Financial Services Authority.
o To process and respond to your inquiries and requests for information and/or advice.
o To send you newsletters, update emails and other information you request.
o For the purposes of processing, servicing and maintaining accounts and transaction records.
o To monitor and archive communications with you.
o To contact you occasionally to inform you of products and services provided by us, other members of the Execution Group or third parties whose products and/or services we think you may be interested in. We may contact you by letter, telephone or email for this purpose.
o To carry out credit checks, money laundering checks, identification authentication or verification checks.
o To comply with legal and regulatory requirements and to resolve disputes.
o To help diagnose any problems with our customer database, server and administer our website.
o To process your job application and other employment related matters.
Anonymous data collected through our websites
In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our websites. For example, we use technology to track which pages of our websites our visitors view. We also use technology to determine which Web browsers our visitors use. This technology does not identify you personally; it simply enables us to compile statistics about our visitors and their use of our websites. However, if you access any password protected areas of our websites, then once you submit your password, the website will recognise you and the anonymous information may be combined with other identifying information that we have about you.
We use anonymous data to improve the contents and functionality of our websites and our e-mail updates, to better understand our customers and visitors, and to improve the services we offer.
Cookies
In order to collect the anonymous data described in the preceding paragraph, we may use temporary “cookies” that remain in the cookies file of your browser until the browser is closed.
Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. If you choose not to accept cookies from our websites you may not be able to access and use all of part of such websites or benefit from the information and services they offer. The IAB website at www.allaboutcookies.org tells you how to remove cookies from your browser. This advice currently comprises the following steps (however please check the IAB website for the latest guidance):
If you are using Microsoft Windows Explorer
• Open ‘Windows Explorer’
• Click on the ‘Search’ button on the tool bar
• Type ‘cookie’ into the search box for ‘Folders and Files’
• Select ‘My computer’ in the ’Look In’ box
• Click ‘Search Now’
• Double click on the folders that are found
• ‘Select’ any cookie file
• use the ‘Delete’ button on your keyboard
If you are not using Microsoft Windows Explorer, then you should select ‘cookies’ in the ‘Help’ function for information on where to find your cookie folder.
We also use your IP address to help diagnose problems with our server and to administer our websites. An IP address is a numeric code that identifies your computer on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information, such as determining how many of our visitors are from outside of the UK.
We may also perform IP lookups to determine which domain you are coming from (i.e. aol.com, yourcompany.com) to more accurately gauge our users' demographics.
Disclosure of your Personal Data
We do not share with, nor rent nor sell nor distribute your Personal Data to unrelated third parties, except under these limited circumstances:
o We may share various details about you with our financial service partners within the Execution Group (including but not limited to investment advisers, investment managers and brokers) in order to provide you with the specific services you require and to look after your investment and financial needs. For example, we may share your Personal Data for the purposes of providing you with information and services relating to your existing investments and new investments and financial products, or in connection with our corporate access services, or to process your customer application form(s) and associated documentation, or to update and maintain our databases, IT systems and accounts, or to process your job application and other employment related matters).
o Personal Data may occasionally be transferred to third parties who act for us for further processing in accordance with the purposes for which the data was originally collected or for purposes to which you have consented or otherwise in accordance with this Privacy Policy. For example, these non-affiliated third parties may be financial services providers (such as securities broker-dealers, banks or insurance companies), non-financial companies (such as consumer reporting agencies, mailing houses or technology companies that need to process your Personal Data in order to help us develop, operate and maintain our services and systems) or other services providers (such as legal, accounting and consulting service providers).
o Unless you have given us your consent to the processing of your Personal Data in accordance with our Privacy Policy (which includes sharing or other disclosing), we will not share or disclose your Personal Data to any unrelated third parties for their own marketing purposes.
o We may share or transfer the information in our databases to comply with a legal or regulatory requirement, for the administration of justice, interacting with anti-fraud databases, to protect your vital interests, to protect the security or integrity of our databases or this website, to take precautions against legal liability, or in the event of our sale, merger, reorganisation, transfer of business, dissolution or similar event.
o If we sell or buy any business or assets we may disclose your Personal Data to the prospective seller or buyer of such business or assets and we may transfer your Personal Data to any such buyer.
Where appropriate, before disclosing Personal Data to a third party, we contractually require the third party to take adequate precautions to protect that data and to comply with applicable law.
Data Integrity and Security
We strive to maintain the reliability, accuracy, completeness and currency of Personal Data in our databases and to protect the privacy and security of our databases. The security measures in place on our website and computer systems, aim to protect the loss, misuse or alteration of the information you provide to us. We keep your Personal Data only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or regulatory requirements, or our data retention policy.
Data Access
Upon receipt of your written request and enough information to permit us to identify your Personal Data, we will (subject to the exceptions to the requirement to disclose under the DPA) disclose to you the Personal Data we hold about you, for which we may make a small charge.
Requests to delete Personal Data are subject to any applicable legal and regulatory requirements or document retention obligations and any of our current contracts which are still in force.
If you wish to make a subject access request, relating to Personal Data held about you by the Execution Group of companies, please write to:
The Data Protection Officer
Sourcecap International Limited
Block D,
The Old Truman Brewery,
91 Brick Lane,
London,
E1 6QL
Inaccurate Data
We encourage you to ensure that your Personal Data is accurate and kept up to date so please regularly update any information you have given to us by sending an email to info@sourcecap-intl.com, or by writing to us at the address at the end of this Privacy Policy. We will correct, amend or delete any Personal Data that you notify us is inaccurate and notify any third party recipients of necessary changes.
Links from our websites to third party websites
Our websites may contain hyperlinks to websites that are not operated by us. Any such hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators. We do not control these websites and are not responsible for their data or privacy practices. We urge you to review any privacy policy posted on any site you visit before using the site or providing any Personal Data about yourself.
Our websites contains hyperlinks to other pages on our websites. We may use technology to track how often these links are used and which pages on our websites our visitors choose to view. Again this technology does not identify you personally – it simply enables us to compile statistics about the use of these hyperlinks.
Transfer of Data Abroad
We may transfer data between members of the Execution Group, and our offices and third party processors which may be located outside the EEA. Where your Personal Data is transferred outside the EEA we will ensure that the recipient agrees to keep your information confidential and hold it securely in accordance with the requirements of the DPA.
If you visit our websites from a country other than the country in which our servers are located (currently the UK), the various communications will necessarily result in the transfer of information across international boundaries.
BY PROVIDING US WITH YOUR PERSONAL DATA, YOU CONSENT TO THE PROCESSING AND TRANSFER OF YOUR PERSONAL DATA AS SET OUT IN THIS SECTION.
Unsubscribe
We hope you will be delighted with our services. If you no longer wish to receive information from us and want to be removed from our standard mailing list you can "unsubscribe" by email or post by contacting us at the address given below. Please allow twenty eight days for the unsubscribe process to be completed.
Remember that stopping the information that you receive from us about our products and services may not benefit you. For example, we will not be able to inform you about changes to your investments or about new financial products we think you may be interested in.
If you do not want to receive unsolicited mail, you can stop this by registering with the "Mailing Preference Service". There are also telephone, fax and email preference services. For more information on the preference services, please visit the Direct Marketing Association's website.
Governing Law
This Privacy Policy governs how we process your Personal Data and forms part of our website Terms of Use which can be viewed at www.sourcecap-intl.com. This Privacy Policy shall be governed by and construed in accordance with the laws of England. You agree to submit any dispute arising out of or in connection with our processing of your Personal Data to the exclusive jurisdiction of the courts of England.
Feedback
We welcome comments about this Privacy Policy. If you have any questions about this Privacy Policy, or any part of our service, you may contact us by emailing info@sourcecap-intl.com or telephoning The Data Protection Officer on 0207 426 4211.
Our correspondence address is:
Sourcecap International Limited
Block D,
The Old Truman Brewery,
91 Brick Lane,
London,
E1 6QL