Last updated 14 August 2018.
1. Who we are and about this policy
This website (the ‘Website’), www.halofinancial.com, is operated and maintained by Halo Financial Ltd. In this policy ‘we’, ‘us’ and ‘our’ shall mean Halo Financial Ltd.
The privacy and security of your personal information is very important to us and we treat the privacy of your information seriously. We know that you care how information about you is used and shared and we appreciate your trust in us to do that carefully and sensibly.
If we make any significant changes to the way we use your personal information from that stated at the time we obtained your information, we will notify you by posting a notice on this website, or where appropriate contact you directly i.e. should we wish to introduce profiling based upon any sensitive data.
We maintain appropriate technical, physical and organisational security measures to protect against any unauthorised access or damage to, or disclosure or loss of, your information by anyone, including our employees. We use leading technologies such as (but not limited to) firewalls, CCTV & secure entry to protect the security of your information and our employees are bound by confidentiality agreements in relation to your information.
3. What information do we need to collect from you
We collect information from you when you register with us or request information from us to provide our services to you. We will ask you to provide certain true, up to date and accurate personal information about yourself and this will normally be collected as part of our sales process or during the registration process for some services.
This personal information may change from time to time but can only be collected when you voluntarily give it to us. It is important that you notify us immediately of any changes to the information you have provided as we strive to ensure the information we maintain about you is current, complete and accurate and we respond to requests to correct inaccurate information as soon as possible.
The information we collect will vary according to your individual circumstances and the services you require. Examples of the type of information include:
- Your basic personal information – name, address, date of birth, nationality, phone and email contact details, driving licence/passport details for identification
- Company information – if using our services on behalf of your organisation, the names of contacts and beneficiary owners
- Financial details, including bank account, payment details, currency requirements and source of funds/wealth information
- Information about your use of our website such as your IP address (a unique number which can identify your computer).
In some circumstances, we may obtain information on you from other sources, which include:
- Publicly available sources of information, such as Companies House or the non-UK equivalent
- Electronic Identity Verification (IDV) services
- Information shared by the affiliated partner who introduced you to us, such as your Visa Application firm, financial adviser, or by a price comparison website. Please note, the information in this policy will apply in addition to any information given to you by our affiliated partner or the price comparison website about the use of your personal information.
4. Why do we need to collect this information from you?
We will use your information to facilitate and complete your trade and, if necessary, may disclose your personal information to a third party or provider to the trade to do so, for the following reasons:
- Necessary for the performance of the service we provide you
To facilitate the foreign exchange trade you require as the basis of our agreement with you/your company, which includes opening a trading facility, providing you with accurate currency rates and making payment to the account beneficiary.
Without the information such as your name, address, date of birth and bank account details, we will be unable to provide this service.
- Necessary to meet a legal or regulatory obligation we may have.
We are required to maintain appropriate records of our trades and our correspondence with you to ensure we appropriately meet the requirements of our regulatory bodies. This also helps us to manage our relationship with you.
To ensure that we carry out your instructions accurately, to help us to continually improve our service, to meet our regulatory obligations and in the interests of security, our telephone lines are digitally recorded, and we may monitor these calls for training purposes or query resolution.
Your personal information may also be disclosed if required to do so for legal reasons, to our agents and contractors we engage to help provide our services (on the understanding they will keep it confidential), to any law enforcement agencies once we are satisfied as to the circumstances of the request, and/or to enforce our rights. If we sell or integrate our business with another, we may pass your information to our advisers and those of prospective purchasers for this purpose (on the understanding an adequate Non-Disclosure Agreement (NDA) is in place).
- Where it is in the Public Interest.
It is in the public interest for us to assist with the prevention of Money Laundering, Fraud and Terrorist Financing. For us to protect against these we are required to undertake checks and ongoing monitoring in accordance with UK and European Union legislation (including, money laundering regulations).
This may involve checking your personal information against the various databases available to the financial services industry, including UK government and Credit Reference Agencies. These databases enable us to identify you, any potential issues and where necessary report to the appropriate enforcement agencies. We use the services of a Credit Reference Agency in order to validate your identity. This is an ID check and does not affect your credit rating.
Further information regarding how your data is processed can be accessed via: https://www.callcredit.co.uk/legal-information/bureau-privacy-notice. These procedures, in addition to being legal requirements, also contribute to efforts to protect you from Identity theft and fraud.
- Where we have a legitimate business interest to use your information.
There are certain circumstances where we have a legitimate interest in using your information, which may not be aligned to the core element of the service we provide you, but may enhance the overall service we can provide you. For example, for our registered clients we will keep you informed of the foreign currency markets, providing interesting insight and research, as well as continuing to understand your individual currency requirements as part of our ongoing relationship with you.
We will perform various anti-fraud checks as part of the client on-boarding process and via on-going monitoring.
We may also want to contact you for feedback on our performance using online surveys to monitor the level of service we provide. You will always have a right to refuse to complete any surveys.
We may pool the information we hold on our internal databases together with the personal information you provided and use of IP addresses and website performance statistics, to develop and help improve the services we offer.
Where we do this, we will ensure that your privacy rights are not impacted and your freedom to opt out will be respected.
- Where you have given us your consent.
For much of what we do with your information we will obtain your consent in advance. This may be when you register on our website or when our affiliated partner introduces you to us.
We may share your information with our affiliated partners as part of our service to you and we will do this with your consent. We will inform you of the specific company we will refer you to, however the categories of firm we may share your information with are detailed in Section 5 below.
We do not collect sensitive personal information about you for the service we offer, however should this ever be necessary, for example to support our anti-money laundering obligations, then we will seek your explicit consent to obtain and use this sensitive information.
5. How we use and disclose your personal information
As part of our relationship with you, we will communicate our products and services to you, which we believe, may be of interest to you and which relate to your currency needs. We may use your contact and other details you provide, through this website or when you register with us or from our records of our dealings with you, to obtain your views on our products and services, and to identify our products and services, and those of our strategic partners, which may interest you.
We will communicate with you by post, email, telephone, SMS or social media, based upon our legitimate interest or your consent to do so.
You can change your marketing preferences (i.e. how you would like us to communicate our products and services to you) at any time by contacting us.
We have strategic partners who provide services that may be of interest to you, we may contact you in order to seek your consent to share your data with these third parties. Examples of such services would be:
- Property development and related services
- Estate agency
- Legal advice
- Financial advice and planning, and
Should their service be of interest to you, we will name the provider prior to passing your details on.
6. Your rights
There are a number of specific rights you have with regards to our use of your personal information that we hold, which include a right:
- of access to and a copy of the personal information
- to request that we correct or delete the personal information, or restrict or object to the use of your personal information at any time
- to withdraw your consent, which you have previously provided, please note we will discontinue the processing of your data within a reasonable timeframe from the point of with-drawl onwards. Any processing prior to this point, will remain valid.
- to complain to the Information Commissioners Office (ICO) at any time if you object to the way we use your personal information
- to object to any automated decision making / profiling we do, if we undertake such activity
- to request a copy of the information you provided to us in a ‘structured, commonly used and machine readable’ format. This may be directly to you as the data subject or, where technically feasible, to another data controller.
Restriction of processing – the right to obtain from us a restriction of processing where one of the following applies:
- you contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data
- the processing is unlawful, and you oppose the erasure of the personal data and request the restriction of its use instead
- we no longer need the personal data for the purposes of the processing, but are required by you for the establishment, exercise or defence of legal claims
- you have objected to processing, pending verification as to whether our legitimate grounds override yours.
Object to processing – the right to object, on grounds relating to your situation, at any time to processing of personal data concerning you including profiling. We shall no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. This includes, where you object to processing for direct marketing purposes. In these scenarios we may add limited identifiable data to a suppression list to ensure your wishes are met.
Please be aware that in some situations, despite your request as noted above, we may not be able to or be required to honour it as it may result in us not being able to meet our legal and regulatory obligations or we may need to retain the information for a specified period. We will inform you if this is the case within one month.
7. How long will we keep your information
For information relating to you and your trades with us, we will retain this for a minimum period of 5 years after the end of our business relationship with you. This is defined as 5 years from account opening OR the last cash movement whichever is the later.
If you do not register with us, we will retain any information we hold about you for a period of 2 years from the point at which it was obtained.
8. International data transfers
We may need to transfer your information outside the European Economic Area (EEA) to countries whose data protection laws may not be as extensive. We will not transfer your information outside the EEA unless it is to a country assessed by the EU as having adequate data protection laws in place or we will keep control of the information or require anyone we pass it to, to treat it to European Union standards unless you have provided explicit consent to do so.
We or our affiliate partners may use cloud based computer systems, which is where data is stored across multiple servers.
By communicating electronically with us, you acknowledge and agree to our processing of personal information in this way and if you like to obtain further information about the safeguards we have in place please contact the Data Protection Office, whose contact details are provided in Section 11 below.
9. Links to other websites
We may use ‘cookies’ and other similar technologies, for example pixel tags or tracking IP addresses, on our website. A ‘cookie’ is a small amount of data that is sent to your browser and stored on your computer’s hard drive. They enable you to navigate around our website and, where appropriate, enable us to monitor your behaviour on our website to be able to tailor the content to fit your needs. This behaviour profiling will have no legal effect or other outcome for you. They also help us monitor the usage and activities on our website. They provide us with generic usage statistics to allow us to improve our Website and to provide you with information about our service that may interest you. Cookies are also used to help ensure the overall accuracy of the data collection and analysis processes described above.
The web browsers of most computers are usually set up to accept cookies, however, if you prefer you can disable cookies through your Internet browser. Information about cookies and how to reject them can be found at https://www.allaboutcookies.org/
11. Contacting us
Please help us to keep your records up to date by informing us of any relevant changes to your personal details. You can also ask for further information about the way we use your personal information, or to complain about its use, by contacting our Data Protection Officer at: Halo Financial Ltd, Battersea Studios 2, 82 Silverthorne Road, London, SW8 3HE or by emailing firstname.lastname@example.org.