In this Policy, we refer to INDOS Financial Limited and its affiliate INDOS Financial Ireland Limited as “we”, “us” or “our”. The INDOS Financial Limited registered office is 54 Fenchurch Street, London, EC3M 3JY. We are registered with the Information Commissioner’s Office under number ZA359846.
We are authorised and regulated in the UK by the Financial Conduct Authority (firm reference number 602528). You can find contact details for each of our operating locations on our website.
We may revise this Policy at any time and it will be available on our website.
The information that we collect and where we get it from
“Personal information” is any information that can be used to identify you or that we can link to you and which we have in our possession or control.
We will collect and process the following personal information about you:
Information that we collect from you
We will process personal information that you give to us including when you email us or contact us through various channels as follows:
- Signing up for our newsletters: when you sign up for newsletters or when you contact us with queries or respond to our communications the personal information you provide may include your full name, title, telephone number, email address and content, date and time of your email correspondence and information about your employer or your business. Our newsletter database only contains email addresses and these are not shared with any other party.
- In connection with our provision of depositary services: if you are a client of ours you will provide us with personal information when the company or fund you represent becomes a client and during the client relationship. If you are not a client we may collect or receive your personal information from an event or other business meeting. A separate agreement governs our depositary services and contains more information about the type of data we hold in relation to our services.
- Recruitment application: when you apply for a role with us you may provide us with your full name, date of birth, nationality, education and qualification details, your gender, your CV, photograph, passport details, marital status, home address and home telephone number, mobile telephone number and other details set out in your application and during the recruitment process in general.
Information we obtain from other sources
If you apply for a position with us we may collect personal information relating to past employment, qualifications and education, opinions from third parties about you, past employment history and other details about you, which may also be provided to us by a third party that provides background screening services to us.
If we collect or receive your personal information in the context of our provision of depositary services we might receive information from third parties such as a fund administrator or other service providers to the fund. Further details are contained in the depositary contracts entered into with clients.
How we use the information we collect
We may do the following with your personal information:
- use it to provide depositary services to the relevant client.
- use it to engage in marketing and business development activity in relation to our depositary services. This may include sending you newsletters, business updates and other information that may be of interest to you.
- where you have applied for a position with us, to review and process your job application.
to comply with legal and regulatory obligations that we have to discharge.
- record and monitor your use of our websites or our other online services for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports.
- use it for our legitimate business interests, such as undertaking business research and analysis, managing the operation of our website and our business.
- use it to look into any complaints or queries you may have.
Grounds for using your personal information
We rely on the following legal grounds to process your personal information, namely:
- Performance of a contract – we may need to collect and use your personal information to enter into a contract with, and to perform our obligations under a, contract with your firm, or a fund under your management.
- Legitimate interest – we may use your personal information for our legitimate interests.
- Compliance with law or regulation – we may use your personal information as necessary to comply with applicable laws/regulations.
How we share information with third parties
We may share personal information with another entity within the INDOS Financial group and we engage sub-processors in connection with our depositary services (such as IT service providers), that may have also access to your data. Your personal information may be retained or accessed from locations outside Europe.
We may also share your personal information outside the Firm. This may include:
- Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers.
- Third parties relevant to the depositary services that we provide. This may include, but is not limited to, other service providers to the funds.
- To the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal information in order to comply with any legal or regulatory obligation.
Where we transfer your personal information outside Europe, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information.
Keeping your information and information security
How long we hold your personal information for will vary and will depend principally on:
- the purpose for which we are using your personal information – we will need to keep the information for as long as is necessary for the relevant purpose, and
- legal and regulatory obligations – laws or regulation may set a minimum period for which we have to keep your personal information.
We will ensure that the personal information that we hold is subject to appropriate security measures.
Your choices and rights
You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below.
These rights include:
- Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you.
- Requesting that we correct your personal information if it is inaccurate or incomplete.
- Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it.
- Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. There may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
- Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
- Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us.
- We can, on request, tell you which data protection authority is relevant to the processing of your personal information.
We may collect information about your computer, including where available your IP address, operating system and browser type, to collect aggregate information for internal reporting purposes. Our website uses ‘analytical’ cookies which allow us to distinguish you from other users of the website, recognise and count the numbers of visitors to our site and which pages they visit.
How to contact us
If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us. You can do this by emailing us at firstname.lastname@example.org or in writing to INDOS Financial Limited at 54 Fenchurch Street, London, EC3M 3JY.