- Insignis Cash Solutions which is a trading name for Insignis Asset Management is committed to protecting your personal information and ensuring that it is used fairly and responsibly. This policy explains the information we collect about you and how it will be used.
- This privacy notice sets out the processing practices in relation to personal data which is collected, stored and retained through the use of this Website and any other electronic communications by Insignis Asset Management Limited, which is the data controller for that data.
- References to “we”, “us” or “our” refer to Insignis Asset Management and references to “you” or “your” refer to any users of our website.
- We will use your information to assist us in providing a high level of service to you, to prevent and detect crime and to develop and test our services. This may include sharing your information with any person we appoint to advise on, or perform any of the services, we offer for business and operational purposes.
- All personal information provided by you or your introducer, and any other information relating to your relationship with us will be treated in confidence, except when we are required by law to provide it, or where your consent has been received.
- The uses of your personal information are covered by the registration of Insignis Asset Management Limited under the Data Protection Act 2018. Insignis Asset Management Limited is a registered Data Controller under the DPA, registration number (ZA158030)
- For the purposes of meeting the Data Protection Act 2018 territorial scope requirements, the United Kingdom is identified as the named territory where the processing of personal data takes place
- Under the GDPR, your individual rights in relation to your personal data are as follows (you can read more about your rights in detail at https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/).
- the right to be informed about the personal data being processed,
- the right of access to the data,
- the right to rectification,
- the right to erasure,
- the right to restrict processing,
- the right to data portability(to receive an electronic copy of your personal data) ,
- the right to object to processing of your personal data and
- the right not to be subject to automated decision-making. including profiling
Identity verification and the prevention of money laundering
- If you decide to take advantage of our services, we will ask you to provide us with certain information to enable us to verify your identity and address. This information may additionally be used for the prevention of money laundering as well as in the management of the services we provide you. We may check the data provided by you against corroborative sources of electronic data to validate the data and authenticate an individual’s geographic locale. We will also use the data provided to access a widely adopted source of structured intelligence on Politically Exposed Persons (PEPs), heightened risk individuals and organisations.
- Insignis Asset Management Limited may use your postal address, email address and telephone number to contact you about our services for as long as you are a client, or a potential client, of this company.
- If you are a direct client of Insignis Asset Management we may also use your postal and email address for the purposes of sending direct marketing information to you on other products and services we offer. You may ask us to stop sending such direct marketing information to you at any time.
- We will only pass on your personal details to third parties when we are required to by law, or for the purposes of opening accounts in your name as part of the operation of our service.
- We will maintain records of data held about you for at least as long as required by law, and in any event for a minimum of five years from the termination of any relationship between you and us.
- By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
- ‘Cookies’ are small amounts of data sent in a text file from a web server to your web browser which help operators understand more about the way in which you use a website. The information collected through cookies on our website is only used by Google Analytics to help us analyse how you use the website.
- Two types of cookie may be used on the website, “session” or “persistent”. Session cookies are used to maintain the state of the connection between the web server and your computer enabling you, once you are logged in, to move between web pages on the same website without having to keep logging in. Session cookies are deleted at the end of the browsing session.
- Persistent cookies are stored on the hard disk of your computer, unless you have configured your web browser not to accept cookies. Persistent cookies can be used for authenticating users and maintaining specific information about users, such as site preferences and to provide the website owner with information about how users use their site.
- If you would prefer not to accept cookies then you can alter your settings within your web browser (e.g. Internet Explorer, Google Chrome, Mozilla Firefox). Please visit the help section within your browser for instructions on how to do this.
- Please note that if you do not permit cookies to be used, we may not be able to offer you an online service.
If you have any questions would like further information about our privacy and information handling practices, would like to discuss opt-outs or withdrawing consent, please contact our Data Protection Officer by e-mailing at email@example.com or writing to the address below.
Data Protection Officer
Insignis Cash Solutions
St John’s Innovation Centre,
We are committed to working with you to settle any complaint or concern about privacy. If you are not happy with how we have dealt with your complaint or concern, you can complain to the data-protection authority of the United Kingdom contacting the Information Commissioners Office:
Information Commissioner’s Office
- We may provide links to external websites on our website. We are not responsible for the content of any external websites.
Personal Data Use
Your personal data is in safe hands.
We do: use your personal data to help us provide a great customer service, which includes tailoring the information we share with you to help ensure that it’s relevant, useful and timely.
We do: respect your privacy and work hard to ensure we meet strict regulatory requirements.
We don’t: sell your personal data to third parties.
The Personal Data we may collect from you or your introducer could include:
- Email address
- Phone numbers
- Job function and employer details/institutional affiliation
- Gender and nationality
- ID Documentation
- NI Number
- Recruitment Information (e.g. CV, certificates, date of birth, performance assessments, reference letters etc.)
- Connection Information (e.g.IP address, web cookies, host information, approximate host location, pages visited, services used)
We may use your Personal Data:
- To provide cash management services
- To comply with anti-money-laundering regulations
- To provide you with information about our services, activities or our online content by offering to subscribe you to newsletters, publications, event announcements, etc.
- To personalise the way our web content is presented to you
- To use IP addresses to identify your location for statistical reporting purposes and if necessary to block disruptive use
- To analyse and improve our websites by examining statistical usage information
- To generate statistical reports as to how our website and services are being used
- For managing events that you have registered for
We may disclose your Personal Data:
- To banking institutions in the provision of our services
- To service providers processing your information on our behalf which are required to keep your information confidential
- In forming part of the record of data submitted to our data archives
We may use your Personal Data to contact you:
- When you have asked us to as part of a specific service request (e.g. password reset, help desk request, voicemail message)
- In relation to any contribution that you have provided to our archives
- To invite your voluntary participation in surveys about our services
- In relation to any service, activity or online content you have signed up for in order to ensure that we can deliver the services to you (e.g. to notify you of service down time)
- When you have opted in to receive further correspondence for and outreach purposes (e.g. newsletters)
If you choose not to give personal information
We may need to collect personal information by law, or under the terms of a contract we have with you. If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts. It could mean that we cancel a product or service you have with us. Any data collection that is optional would be made clear at the point of collection.
Fraud Prevention Agencies (FPAs)
We may need to confirm your identity before we provide products or services to you or your business. Once you have become a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks. We use Fraud Prevention Agencies to help us with this.
Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.
A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for.
We will use the information to:
- Confirm identities
- Help prevent fraud and money-laundering
- Fulfil any contracts you or your business has with us.
We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime.
FPAs can keep personal information for different lengths of time. They can keep your data for up to five years if they find a risk of fraud or money-laundering.
These are some of the kinds of personal information that we use:
- Date of birth
- Residential address and history of where you have lived
- Contact details, such as email addresses and phone numbers
- Financial data
- Data relating to your or your businesses products or services
- Employment and income details
- Key information including nationality, NI number and ID documents
- Data that identifies computers or other devices you use to connect to the internet. This includes your Internet Protocol (IP) address.
These are only used in the provision of our services.
Automated decisions for fraud prevention
The information we have for you or your business is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
Data transfers out of the EEA
Our products and services may be provided using resources and servers located in various countries around the world. Therefore, your personal data may be transferred outside the country where you use our services, including to countries outside the European Economic Area (EEA). We will transfer data in such circumstances only if the level of data protection in that jurisdiction is deemed adequate and if there are appropriate safeguards in place to protect your privacy.
Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of information on an international basis. Therefore, by browsing the Website and communicating electronically with us, you acknowledge and agree to Insignis processing personal data in this way.
How long we keep your personal information
We will keep your personal data only for so long as it is reasonable for us to do so, depending upon the nature of the data and our processing, and the grounds upon which we collected it. In general, we will delete redundant account information within 14 days of our relationship ending. However, we are obliged to keep certain records of our relationship to comply with the FCA’s and other regulatory rules, in which case we will instead restrict access through our archiving processes. Subject to any actual or potential legal claim or regulatory investigation, the maximum time that we envisage retaining any of your information is 7 years, after which time it will be destroyed.
Information we use for marketing purposes will be kept by us until you notify us that you no longer wish to receive this information. If you do notify us that you no longer wish to receive marketing information we will keep an encrypted version of your contact information to ensure we respect your wishes.
After you stop being a customer, we may keep your data for up to 7 years for one of these reasons:
- To respond to any questions or complaints.
- To show that we treated you fairly.
- To maintain records according to rules that apply to us.
We may keep your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.
What are your rights?
You have the right to request information on and access to the personal data we hold about you.
You also have the right to request that we correct or delete any incomplete, incorrect, unnecessary or outdated personal data we hold about you. However, we cannot delete personal data that is necessary for compliance with our binding legal or regulatory obligations or if the personal data must be retained according to applicable laws, or is required for the exercise or defence of a legal or regulatory claim.
In case you consider your personal data collected by us to be inaccurate but you do not wish your personal data to be deleted, if we have used your personal data unlawfully or you have objected to the processing and the existence of legitimate grounds for processing is still under consideration, you may request restriction of processing of your personal data.
You may also at any time object to your personal data being processed for direct marketing purposes, sending promotional materials, profiling, or for the performance of market research. Where your personal data is processed based on your consent, you have the right to withdraw your consent for such processing at any time.
In case you wish to make use of your rights mentioned above, you may, as appropriate and in accordance with applicable laws, exercise such rights by contacting us through the contact points referred in the marketing materials or below in this notice. In some cases, especially if you wish us to delete or cease the processing of your personal data, this may also mean that we may not be able to continue to provide the services to you.
Please note that we may need to identify you and to ask for additional information in order to be able to fulfil your requests. Please also note that applicable law may contain restrictions and other provisions that relate to your above rights.
Subject Access Request
You have a right to a copy of and details of the personal data held about you. To obtain a copy of the personal data Insignis holds about you, please write to us at firstname.lastname@example.org . No charge will normally be made by Insignis for providing this information. If your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee.
Letting us know if your personal information is incorrect
You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this.
If you do, we will take reasonable steps to check its accuracy and correct it.
What if you want us to stop using your personal information?
You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.
There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.
We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.
You can ask us to restrict the use of your personal information if:
- It is not accurate.
- It has been used unlawfully but you don’t want us to delete it.
- It not relevant any more, but you want us to keep it for use in legal claims.
- You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.
If you want to object to how we use your data, or ask us to delete it or restrict how we use it or, please contact us.
How to withdraw your consent
You can withdraw your consent at any time. Please contact us if you want to do so.
If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.