IUR Capital Ltd collects personal information from you when you open an account with us. If you require a hard copy of this policy please contact us.
Third Floor, Lansdowne House
57 Berkeley Square
Authorised and Regulated by the Financial Conduct Authority
Firm Registration Number 514394
IUR Capital Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value your privacy and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Information About IUR Capital Ltd
Registered in England under company number 6346900.
Registered address: Third Floor, Lansdowne House, 57 Berkeley Square, London, W1J 6ER, United Kingdom.
Data Protection Officer Email address: firstname.lastname@example.org
Telephone number: +44 203 687 0581
Postal Address W1J 6ER.
IUR Capital is regulated by UK Financial Conduct Authority as an investment advisor and registered as a Data Controller with the UK Information Commissioners Office (ICO).
1. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
2. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about [our] collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact IUR to find out more or to ask any questions using the details in Part 9.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by IUR is inaccurate or incomplete. Please contact using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact [us] using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, OR we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Part 6 explains more about how we use your personal data, including (automated decision-making) OR (profiling)
For more information about our use of your personal data or exercising your rights as outlined above, please contact IUR using the details provided in Part 9.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
3. What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us:
• (Date of birth;)
• (Email address;)
• (Telephone numbers during recorded calls as part of our regulatory requirements;)
• (Business name;)
• (Job title;)
• (Information about your preferences and interests;)
• Brokerage account information
• Acknowledgements of risk disclosure statements
Your personal data is obtained from several third (parties) who we have a third-party relationship and with whom you have shared some or all of the above data.
Please click here to obtain a full list of third party service providers (link to form, user provides name and email and form data is emailed to email@example.com)
4. How Do You Use My Personal Data?
Under the GDPR, IUR must always have a lawful basis for using personal data. This may be because the data is necessary for [our] performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
• (Providing and managing your account.)
• [Providing our products OR services to you. Your personal details are required in order for us to enter into a contract with you.)
• (Personalising and tailoring products AND services for you.)
• (Communicating with you. This may include responding to emails or calls from you.)
• (Supplying you with information by email you may unsubscribe or opt-out at any time by emailing firstname.lastname@example.org with email subject “Unsubscribe”)
With your permission and where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email OR telephone with information, news, and offers on our products AND services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
If at any point you wish to query any action that [we] take on the basis of the above or to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on a profiling or any automated method), the GDPR gives you the right to do so. Please contact IUR to find out more using the details in Part 9.
• The following profiling may take place:
o Providing monthly educational webcasts, collecting information from one or more brokerage accounts which you have established to determine suitability for any potential investments or investment strategy which we may recommend,
o Establishing criteria for marketing of services ie; geographical location, age, financial profile.
5. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected and our regulatory requirements which are generally 7 years.
• If we obtained your data from previous educations webcasts which you have attended, or if we have communicated with you in the past after our webcasts or presentations, we believe you have provided a legitimate interest in communicating with you to provide details of upcoming educational webcasts or for the purpose of marketing our services.
6. How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
We use specific contracts (Data Processing Agreements) with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. We have reviewed the Data Processing Agreements with each third party to ensure the third party is compliant with GDPR and satisfies requirement to safely store and protect your data.
Please contact IUR using the details below in Part 11 for further information about the particular data protection mechanism used by [us] when transferring your personal data to a third country.
7. Do You Share My Personal Data?
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may sometimes contract with third parties to supply (products) OR (services) to you on our behalf. These may include delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
Please click here to obtain a full list of third party service providers.
If any personal data is transferred outside of the EEA, we will take suitable steps (via a Data Processing Agreement with that external third party) in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
8. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the Data Protection Officer (DPO) email shown in at the top of this policy and in part 10.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
9. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Data Protection Officer):
Email address: email@example.com
10. How Do I Contact You?
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on our website and by email request to the above email address.