We Global Currency Exchange Network Limited and Global Custodial Services Ltd (both trading as GC Partners) are committed to protecting your privacy and personal data to comply with the UK Data Protection Act 2018, implemented through the General Data Protection Regulation (GDPR). The purpose of this policy is to explain how and why we collect information from you, who has access to it and what your rights are.
What information do we process?
We process personal information about you which may include your name, date of birth, address, contact details, employment, bank account details, 2 forms of identification and requirements. We may require further information depending on requirements.
Why is it being processed?
We process this information in order to be able to deliver services that suit your needs, and in order to deliver services to our clients. We also collect this information to comply with the Money Laundering Regulations and the Financial Conduct Authority (FCA) requirements.
How is your information collected and who is collecting it?
We receive information:
- directly from you (via telephone, face-to-face, registration forms, email or written); or
- from our clients and third party brokers (with whom you may have a direct relationship with, for example as a third party or an investor) who have shared your information with us in order for us to provide services to our clients.
We collect the email addresses of those who communicate with us via email. Our systems may also collect the email addresses and aggregate information on what pages you access or visit, user-specific information on what pages you access or visit, information volunteered by the you, such as survey information and/or site registrations, name and address, telephone number.
GC Partners will collect information relating to how you found our site. For example, if you have arrived at our site through a search engine or clicked a link on another website.
All other information that is collected by us is information that you provide to us yourself, or that we have received from one of our clients (as set out above).
How do we use your information and on what basis do we process it?
We only process your information for legitimate business purposes, and then only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes. In exceptional circumstances, we may also be required by law or regulation to disclose or otherwise process your information.
The information we collect (whether directly from you, or from one of our clients) may be used in the following ways in pursuing our legitimate business interests:
- to communicate and inform you when providing a service to you;
- to notify you about updates to our web site or mobile telephone / Tablet apps;
- if you provide us with your telephone number, to contact you in relation to enquiries;
- to verify or enforce compliance with the policies governing our website and applicable laws or to protect against misuse, or unauthorised, use of our website;
- used by us to contact you for marketing purposes (only if you choose to “opt-in”); and/or
- to provide services to our clients, which in some cases may involve us processing your personal data so that we can receive monies from you (which we will hold on behalf of our client).
PLEASE NOTE: We will only use your information for marketing purposes if you choose to “opt-in” to the privacy notice email. If you no longer want to receive emails, texts, or “push notifications” from us in the future, please let us know by sending us an email at [email protected].
With respect to Ad Servers: We do not partner with, or have special relationships with any ad server companies.
Who will we share your information with?
We may share your personal information with the following categories of people/organisations:
- with our banks and other service providers who assist in providing support for our internal operations;
- with service providers who assist in providing our services such as relevant agents, affiliates, introducers, investment providers;
- to relevant authorities, when legally required to do so, at the request of governmental authorities conducting an investigation;
- to other GC Partners group companies and offices, including our office in Dubai; and/or
- to a successor entity in connection with a corporate merger, consolidation, sale of assets or other corporate change which affects the operation of the website.
These disclosures will in some cases involve transferring your personal information overseas. If you are dealing with us within the European Economic Area (EEA) or the United Kingdom (UK), you should be aware that this may include transfers to countries outside the EEA / UK. Where required, when we transfer personal data to our affiliates or our service providers, we will ensure that our arrangements with them are governed by appropriate safeguards or agreements on terms approved for this purpose by the European Commission and / or the relevant authority in the UK (as the case may be).
We use information about you only for our own purposes. We do not pass your information on to any third parties for marketing purposes unless we have specifically obtained your permission to do so.
What rights do I have and can I access the information held on me?
Under the Data Protection Act 2018, you have rights as an individual which you can exercise in relation to the information we hold about you.
- A right of access to the personal data that we hold about you, and to some related information, under applicable data protection law and regulation. We will provide you with one copy of your personal data free of charge, but we may charge you a fee to cover our administrative expenses if you request further copies of the same information.
- A right to require any inaccurate personal data that we hold about you to be corrected or deleted.
- A right to object to our use of your personal data for direct marketing purposes at any time.
- A right to object to our processing of some or all of your personal data (and require it to be deleted).
- A right to data portability, which means the right to receive your personal data in a structured, commonly used and machine-readable format.
You also have the right to complain to the Information Commissioner’s Office at www.ico.org.uk/global/contact-us.
You can read more about these rights here – https://ico.org.uk/your-data-matters/
Upon request we can provide you with access to all information. that we maintain about you, including:
- unique identifier information (e.g. reference number, user ID or password);
- transaction information (e.g. dates on which you made purchases, amounts and types of purchases);
- communications that you have directed to our site (e.g. emails, customer enquiries);
- contact information (e.g. name, address, phone number); and/or
- a description of information that we maintain about you.
You can access this information and exercise your other rights by emailing us at [email protected] .
How long do you keep my information for?
We keep your information for a period of 5 years from the last time our client received services from us and it will be permanently deleted from our database after this. This is to comply with the Financial Conduct Authority’s record keeping requirements and the current UK Money Laundering Regulations, as well as our obligations under data protection laws and regulations.
Where we have received your personal information from our client, we will keep your information for a period of 5 years from the last time our client received services from us and it will be permanently deleted from our database after this.
Where do we store your information?
All information is stored in the UK.
How is the information we hold protected?
With respect to security: We have advanced security measures in place in our physical facilities and industry leading security solutions across all of our technical systems to protect your information against security breaches, loss, misuse or alteration.
We endeavour to protect your information by;
i) Only requesting information that is relevant for our purposes
ii) Try to keep information on you up to date and accurate
iii) Delete any information which is no longer relevant
iv) Protect your data against unauthorised use
If you are concerned about how your information is used, you should check back to our website periodically.
You may prevent your information from being used for purposes other than those for which it was originally collected by emailing us at [email protected] .
For further information about how we process your personal information, please contact us at [email protected] and/or 3rd floor, 100 New Bond Street, London, W1S 1SP.
Further information about us
Global Currency Exchange Network Ltd Registration number: Z3248515
Global Custodial Services Ltd Registration number: ZA083139