Blenheim Global Assets may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy has been updated and is effective from 25th May 2018.
When we ask you for personal information online, it will only be in response to you actively applying for or using one of our online products or services.
If you are giving us information for the first time, we shall explain the purposes for which we shall use it at that time. If you are a client already, this explanation will be in your account terms and conditions.
We may use personal information you provide for the purpose of providing more relevant content to you.
Purpose and Scope
The Policy is meant for use by Blenheim Global Assets (Europe) Ltd, Clients and relevant authorities.
Blenheim Global Assets are compliant with the requirements of the General Processing of Personal Data Regulation as well as other legislations applicable in Europe.
This policy applies to former, existing and potential clients as well as to any visitors of the company website
This policy aims to provide you with information on what type of information we collect, how it is used and the circumstances where it could be shared with third parties.
The protection of your privacy and personal information is very important to us. This is in relation to personal and financial information and any other data as provided to us by you whether in paper form, verbally or electronically.
We are committed to safeguarding any Client information we collect, process and store, applying all reasonable measures, including strict security standards and sophisticated security technology, to ensure that Clients’ personal data will be processed in a manner that provides protection against unauthorized or unlawful processing and against accidental loss, destruction or damage.
Collection of personal data
Blenheim Global Assets shall collect information required to fulfil their legal and regulatory obligations and to improve our service to you. Blenheim Global Assets will gather information and documentation to personally identify, contact or locate you and may gather information from third parties and or other sources which will help Blenheim Global Assets to offer our services effectively. As a client, you are responsible for the true and accurate information and to keep Blenheim Global Assets informed of any changes in your personal information or circumstance by emailing our back office department at info@BlenheimGlobalAssets.com and/or compliance@BlenheimGlobalAssets.com . We are required to evaluate the appropriateness of the financial instruments and suitability based on three main parameters;
a) The sources of your income and wealth as well as your financial obligations
b) Your investment knowledge and experience including your objectives, your knowledge and experience of the financial market along with your understanding of the risks involved.
c) Your experience in dealing in complex and non-complex financial instruments, especially your investment and risk attitude as they relate to such financial instruments.
The following is an example of personal data that is required from you:
Personal information requested during the registration process such as your name, date, place of birth, citizenship, nationality.
- Status, identification numbers and contact details;
- Financial information such as your income, source of funds, investment objectives;
- Verification of your identity and residency
Blenheim Global Assets is obliged by Law to maintain these records for five years after the termination of a client relationship, or up to 7 years, upon request by the local competent authority.
Purpose of collecting and processing of personal data
Your personal data is used for specific, explicit and legitimate purposes and only as required to provide a quality service to you and to comply with applicable legislations as referred to above. The personal data collected from you is used to verify your identity, to construct your economic and investment profile in order to ensure that we provide you with products and services suitable to your requirements, knowledge and risk appetite, to manage your account with us, to process your transactions, to provide you with post-transaction information, to inform you of additional products and / or services relevant to your economic profile, to produce analysis and statistical data which will help us improve our products and services, and for website improvement purposes. These are necessary for the entry into or performance of our contract once signed. We will carry out regular checks to ensure that our systems are working as intended.
Affiliates and Partners
Clients acknowledge and consent that the Company and its partners, affiliates and/or associates may share information in a manner that is useful and relevant only to do so and in relation to one of the following purposes:
a) Reasonably required by such affiliate, partner and/or associate of the Company to provide products and services to its clients,
b) To offer additional similar products and services that meet clients’ needs
The Company may disclose clients’ personal information to any organisation at the clients’ request or to any persons acting on behalf of clients, including clients’ financial adviser, broker, solicitor or accountant.
The Company may disclose clients’ personal information to companies hired by the Company to provide limited services on behalf of the Company, including but not limited to packaging, mailing and delivering purchases, postal mail. The Company will take all reasonable measures to ensure that the said companies will be subject to such personal information/data necessary to deliver the service and are prohibited from using personal information for any other purpose.
Non-affiliated third parties
The Company may disclose information to non-affiliated third parties where necessary in order to carry out the following internal functions of the Company:
a) Use of Credit reporting or collection agencies as reasonably required in order to provide the services to its clients;
b) Use of specialized agencies to help carry out certain internal functions such as account processing, fulfilment, client service, client satisfaction surveys or other data collection activities relevant to its business.
The Company may contact clients by telephone, email or other means of medium for the purpose of offering them further information about the Company’s product and services and/or informing clients of unique promotional offerings. The client consent to the receipt of such contact.
For regulatory and quality assurance purposes, any type of communication between the clients and the Company whether in writing, email or by telephone or other means of medium shall be monitored and may be recorded by the Company. Clients accept that such recordings constitute conclusive evidence of the Orders/Instructions/Requests or conversations so recorded.
Who controls and processes your personal data
Blenheim Global Assets, and any undertakings being a member of our group or agents which we engage with for the purpose of collecting, storing and processing personal data and any third parties acting on our or their behalf, may collect, process and store personal data provided by you.
For the purpose of processing and the storage of personal data provided by you in any jurisdiction within the European Union or outside of the European Union, Blenheim Global Assets can confirm this will be done in accordance with applicable laws.
Blenheim Global Assets can confirm that if they contract any third party a written contract will be in place and this privacy statement will be updated accordingly. The contract is important so that both parties understand their responsibilities and liabilities. The GDPR sets out what needs to be included in the contract which Blenheim Global Assets has adhered to, the below is not an exhaustive list of the obligations of all relevant parties;
- The third party must only act on the written instructions of the ELI (unless required by law to act without such instructions);
- Ensure that people processing the data are subject to a duty of confidence;
- Take appropriate measures to ensure the security of processing;
- The rights of Clients will not be impaired in meeting with GDPR requirements;
- The security of processing, the notification of personal data breaches and data protection impact assessments
- will not be impaired;
- Deletion or return of all personal data as requested at the end of the contract;
- Blenheim Global Assets has a regulatory obligation to supervise and effectively oversee the outsourced functions and its obligation to take appropriate measures when it determines that the service provider is not performing the said functions effectively and in accordance with the applicable legislation.
- We may use or disclose personal information without your consent only in certain circumstances:
- if required by law or by order of a court, administrative agency, or other government entities;
- if there are reasonable grounds showing disclosure is necessary to protect the rights, privacy, property, or safety of users or others;
- if Blenheim Global Assets believes the information is related to a breach of an agreement or violation of the law, that has been, is being, or is about to be committed;
- if it is necessary for fraud protection, risk reduction, or the establishment or collection of funds owed to Blenheim Global Assets;
- if it is necessary to enforce or apply the Terms and Conditions and other agreements, to pursue remedies, or to limit damages to Blenheim Global Assets;
- for other reasons allowed or required by law.
- if the information is public;
When we are required or permitted to disclose information without consent, we will not disclose more information than necessary to fulfil the disclosure purpose.
Blenheim Global Assets informs all clients to maintain confidentially and not share with others its usernames and private password. Blenheim Global Assets bears no responsibility for any unlawful or unauthorized use of clients’ personal information due to the misuse or misplacement of clients’ access codes (i.e. passwords /credentials), negligent or malicious, however conducted.
Your rights: Rights to Access
You have the right to request copies of your personal data.
Information must be provided without delay and at the latest within one month of receipt. Blenheim Global Assets will be able to extend the period of compliance by a further two months where requests are complex or numerous. If this is the case, Blenheim Global Assets will inform the individual within one month of the receipt of the request and explain why the extension is necessary.
Can Blenheim Global Assets charge a fee for dealing with a subject access request?
Blenheim Global Assets must provide a copy of the information free of charge. However, a “reasonable fee” can be charged when a request is manifestly unfounded or excessive, particularly if it is repetitive.
The fee if applied will be based on the administrative cost of providing the information.
If at any time, Blenheim Global Assets refuse to respond to a request, Blenheim Global Assets will explain why, informing them of their right to complain to the supervisory authority and to a judicial remedy without undue delay and at the latest within one month.
When information is provided
Blenheim Global Assets will verify the identity of the person making the request, using reasonable means with data provided by you.
Right for rectification
When should personal data be rectified?
Individuals are entitled to have personal data rectified if it is inaccurate or incomplete.
The GDPR includes a right for individuals to have inaccurate personal data rectified or completed if it is incomplete. You can make a request for rectification verbally or in writing.
If Blenheim Global Assets have disclosed the personal data in question to others, Blenheim Global Assets must contact each recipient and inform them of the rectification – unless this proves impossible or involves disproportionate effort. If asked to, Blenheim Global Assets must also inform the individuals about these recipients.
How long does Blenheim Global Assets have to comply with a request for rectification?
Blenheim Global Assets must respond within one month.
This can be extended to two months where the request for rectification is complex.
Where Blenheim Global Assets are not taking action in response to a request for rectification, Blenheim Global Assets must explain why to the individual, informing them of their right to complain to the supervisory authority and to a judicial remedy.
Your right to erasure
When does the right to erasure apply?
The right to erasure does not provide an absolute ‘right to be forgotten’. Individuals have a right to have personal data erased and to prevent processing in specific circumstances:
- Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
- When the individual withdraws consent.
- When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
- The personal data was unlawfully processed (i.e. otherwise in breach of the GDPR).
- The personal data has to be erased in order to comply with a legal obligation.
- The personal data is processed in relation to the offer of information society services to a child.
There are some specific circumstances where the right to erasure does not apply and Blenheim Global Assets can refuse to deal with a request
Blenheim Global Assets has a legal obligation to obtain data on you meeting with their regulatory obligations, based on the legal obligations imposed on Blenheim Global Assets, individuals may have no right to erasure, no right to data portability or right to object on the information gathered meeting with Blenheim Global Assets legal obligation under their license to provide financial services.
When can Blenheim Global Assets refuse to comply with a request for erasure?
Blenheim Global Assets can refuse to comply with a request for erasure where the personal data is processed for the following reasons:
- to comply with a legal obligation for the performance of a public interest task or exercise of official authority.
- the exercise or defense of legal claims.
Does Blenheim Global Assets have to tell other organisations about the erasure of personal data?
If Blenheim Global Assets have disclosed the personal data in question to others, they must contact each recipient and inform them of the erasure of the personal data – unless this proves impossible or involves disproportionate effort. If asked to, Blenheim Global Assets must also inform the individuals about these recipients.
Your right to restrict processing
When does the right to restrict processing apply?
Blenheim Global Assets will be required to restrict the processing of personal data in the following circumstances:
- Where an individual contest the accuracy of the personal data, Blenheim Global Assets should restrict the processing until you have verified the accuracy of the personal data.
- Where an individual has objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and Blenheim Global Assets are considering whether Blenheim Global Assets organization’s legitimate grounds override those of the individual.
- When processing is unlawful, and the individual opposes erasure and requests restriction instead.
- If Blenheim Global Assets no longer needs the personal data but the individual requires the data to establish, exercise or defend a legal claim.
Blenheim Global Assets may need to review procedures to ensure Blenheim Global Assets are able to determine where Blenheim Global Assets may be required to restrict the processing of personal data.
If Blenheim Global Assets have disclosed the personal data in question to others, Blenheim Global Assets must contact each recipient and inform them of the restriction on the processing of the personal data – unless this proves impossible or involves disproportionate effort. If asked to, Blenheim Global Assets must also inform the individuals about these recipients.
Blenheim Global Assets must inform individuals when Blenheim Global Assets decided to lift a restriction on processing.
Your right to data portability
- The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services.
- It allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.
- It enables consumers to take advantage of applications and services which can use this data to find them a better deal or help them understand their spending habits.
- Blenheim Global Assets will respond without undue delay, and within one month. This can be extended to two months where the request is complex or where Blenheim Global Assets may receive a number of requests. Blenheim Global Assets will inform the individual within one month of the receipt of request and explain why the extension is necessary, if applicable.
- Where Blenheim Global Assets is not taking action in response to a request, Blenheim Global Assets will explain why to the individual, informing them of their right to complain to the supervisory authority and to a judicial remedy without undue delay and at the latest within one month.
Right to object
Individuals have the right to object to:
- processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
- direct marketing (including profiling);
- processing for purposes of scientific/historical research and statistics.
Blenheim Global Assets will stop processing the personal data unless
- Blenheim Global Assets can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or
- the processing is for the establishment, exercise or defense of legal claims.
Blenheim Global Assets does not process your personal data for marketing purposes
Blenheim Global Assets does not process your personal data for research purposes
RAISING A CONCERN
You have the right to be confident that Blenheim Global Assets handles your personal information responsibly and in line with good practice.
If you have a concern about the way Blenheim Global Assets is handling your information, for example if you feel Blenheim Global Assets may not be;
- keeping your information secure;
- holds inaccurate information about you;
- has disclosed information about you;
- is keeping information about you for longer than is necessary; or
- has collected information for one reason and is using it for something else;
Blenheim Global Assets takes all concerns seriously and will work with you to resolve any such concerns.
Any concerns and/or requests can be raised to Blenheim Global Assets’s appointed contact person, as stated below:
Blenheim Global Assets
Clifton House, Fitzwilliam Street Lower, Dublin 2 Ireland
Tel: +353 (1) 485 4005
If you are not satisfied with any responses provided by Blenheim Global Assets you have the right to raise such matters with the Data Protection Supervisor;
Data Protection Supervisor
Postal address: Rue Wiertz 60, B-1047 Brussels
Office address: Rue Montoyer 30, B-1000 Brussels
Telephone: +32 2 283 19 00
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