Regulatory Information

PRIVACY POLICY

 

At Reyker Securities plc group we are committed to protecting your right to privacy. We handle and store all personal identifiable data provided by you to us on our website, via application forms, financial reviews and customers surveys, via email, telephone, letter and or from third party institutional or personal financial advisors or companies in a secure and diligent manner and in compliance with all applicable data protection laws.

Please read this privacy policy in conjunction with our Cookies Policy which can also be found on our website. We encourage you to contact us at any time shall you require further information or more clarity regarding our data privacy practices.

We reserve the right to update this privacy policy at any time. Please note that our latest updated policy will always apply, please find this information below.

Scope of this privacy policy

This privacy policy applies to these websites www.reyker.com and www.augerefinancial.com.

The lawful basis for processing personal data

We collect, process and disclose personal data to fulfil our contractual, regulatory and statutory obligations to our clients, independent financial advisers, distributors, platforms, trustees, third party regulated advisers among others. Reyker is regulated by the UK Financial Conduct Authority and must comply with all UK and EU legislation. Therefore, processing your personal data may be necessary for compliance with a legal obligationa to which Reyker is subject. We may process your personal information when we have a legitimate business or commercial interest reason. Please find below our legitimate interests and reasons for processing your personal data.

The personal data we collect

We may collect your personal information when you decide to apply for our products or services either by completing our application forms, provide the information via an appointed financial advisor or through an agent acting on your behalf. When you provide your personal information directly to us, we will be acting as Data Controller while processing your data and as such we are registered with the Information Commissioner’s office under registration number Z5124079.

The personal information we process includes but it is not limited to: your name, date of birth, residential and historical address, contact details, bank details, national insurance number, passport number, nationality, employment and financial details, tax-related information and or data relating to your investments, financial products or services. Please note that not all personal data we hold about you will always come from you directly; we may obtain information about you when conducting anti-money laundering checks and identity checks to prove who you are and or information which is available in public records such as in the electoral register.

Reyker may also receive or obtain your personal information from companies or financial advisers that introduce you to us, payment providers, banks, settlement platforms, government and law enforcement agencies such as the Financial Conduct Authority, fraud and crime prevention and credit checks agencies and Companies House.

How we use the personal data we collect about you

Any personal data which you or your adviser may have provided directly or indirectly to us may be used as per below.

To provide our services or financial products

  • To provide the services or products you have requested and contracted with us for the delivery of safe custody, trading or advisory, execution only or discretionary management services or any other service we may provide
  • To advise you of any changes in our terms and conditions or charges
  • To obtain your consent when we need to fulfil your instructions
  • To provide you with valuations and transaction reports
  • To administer your account with us and provide technical and customer services support
  • To liaise with your appointed independent financial advisor and or agent working on your behalf when fulfilling the services delivery to you
  • To send your personal and investments information to a third party when you may decide to transfer your investments from us
  • To respond to any complaints, requests or enquires you may submit to us
  • To share your personal information with companies we may have an agreement in place to deliver financial products or services such as anti-money laundering service providers
  • In the event of acquisition, joint venture, sale, restructure, transfer of all or any part of our business or assets; we will ensure that the party to receive the personal information can protect and comply with applicable data protection laws.

To fulfil our regulatory obligations

  • To verify your identity and conduct credit, anti-money laundering and due diligence checks
  • To fulfill our compliance monitoring and audit duties, including but not limited to our obligations under MiFID II regarding market monitoring
  • To detect and prevent fraud and comply with applicable laws and regulations, including but not limited to fulfill requirements by HMRC, FCA, ICO, FATCA, Companies House among others
  • To monitor and or record phone calls and any other electronic checks or communications to perform the services, comply with applicable laws and prevent financial crime
  • To maintain our records up to date when requested by you to amend your details
  • To allow law enforcement agencies, regulatory bodies and tax authorities to access your personal information when we are legally required to do so. This is to support their duty to detect, investigate, prevent and prosecute crime
  • To keep personal information for different lengths of time to fulfil our legal reporting, data back up and document retention obligations under all applicable laws.

For marketing research and new financial products development

  • To conduct market research and customer surveys which help us to improve our products and services and to develop new products which may be marketed to you, such as requirements under MiFID II and ongoing suitability
  • To market services and events directly to you when you have opted to receive marketing materials from us; we will include instructions on how to opt out shall you wish to do so
  • When we request you to take part in our financial products reviews or promotions
  • When we enter into an agreement with market researchers to perform such services on our behalf
  • To enhance and improve your experience when using our site and services.

If you choose not to give personal information

We may need to collect personal information that is legally required, or under the terms of a contract we will enter or 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 or business policies. It could mean that we need to cancel a product or terminate the service or account you have with us.

Your right to be informed, withdraw consent, object to processing, request access, data correction, restrict processing, request data portability or deletion of your personal data

Under data protection laws you have certain rights to the personal data we hold and process on your behalf.

  • You have the right to be informed about the kinds of personal data we hold about you and the purposes for which your personal data is being processed
  • You have the right to object to data processing and or withdraw your consent to process your personal data when such consent has been obtained for the provision of direct marketing, at any time
  • You have the right to request a copy of the personal data we hold about you. We will comply with your request without delay and at least within one month, it may take a little longer when the request is deemed excessive
  • You have the right to request us to correct any inaccurate or incomplete information we hold about you, Reyker will need to verify your identity and where applicable the changes required prior to processing your request
  • You have the right to request us to restrict the processing of your personal data; for instance, until the accuracy of your data is verified
  • You have the right to request us for a copy of your personal data free of charge, which shall be provided to you in a machine-readable format where the data has been processed by automated means and received directly from you
  • You have the right to request us to erase the personal data we hold about you, subject to Reyker being able to comply with its legal obligations under all applicable legislations regarding reporting, back-ups and document retention for a length of time among others. We do not typically keep email trails from our customers, unless these are necessary for us to comply with applicable laws and regulatory obligations.

Your right not to be subject to a decision made via automated means, including profiling

To enter into and perform a contract with our clients, we are legally required to conduct anti-money laundering and due diligence checks to prevent fraud or any other type of financial crime; these checks are normally conducted electronically. Our employees are trained to check such findings and safeguard individuals from potential wrong decisions. You can object to an automated decision being made and ask us to verify the information obtained and or request another staff member to review it.

Reyker does not conduct automated profiling of its clients. Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Please contact us shall you require further information.

Where we store and process personal data

Reyker has an in-house IT and software development programme which enables us to protect your data privacy rights and safeguard against unlawful processing. Our services provide data and document storage, such as your application form, investment valuations, letters from us to you among others. Any information we hold about you is generally kept in the United Kingdom and the European Union, controlled and managed by and only accessible to key authorised personnel with a business reason and need to access and process your personal data to deliver the services or products requested by you.

Personal Data may be stored or accessed or processed through a global cloud service or data network or database or data storage system or remote facility either under our control and / or provided to us as a service by third parties. We take reasonable steps to ensure that where we contract with data service providers and cloud facilities where client data may be stored, that these are within a European jurisdiction. However, where these facilities are, as is usual, operated by third party internet service providers, we cannot either audit or guarantee their data handling and backup arrangements.

For maintenance and system or data recovery purposes some data may be accessed or processed by or on behalf of our third party service providers. These providers may be located in or use data centres in various places around the globe including the United States. Your data may be temporarily or permanently transferred to and stored in, other territories or jurisdictions including the United States by third party data handlers, internet service providers or data storage and backup facilities, and this may not be within our knowledge or control. We remind clients and financial advisers that internet addresses and domains provided by many service providers are operated by United States companies such as Microsoft, Google and Apple and such communications may have passed through US and other jurisdictions.

Should you not wish your data to be processed by us in the way described herein, please contact us and let us know, though this may mean that for practical reasons we may at our option not be able to operate or continue to provide our services to you.

How we protect your personal data

At Reyker we take data security seriously and have in place appropriate security and organisational measures to protect your data against unlawful or unauthorised processing and against the accidental loss of, disclosure or damage to personal data.

We have a business continuity and disaster recovery plan in place which safeguards the continuity of services to clients and protect our clients’ personal data and assets.

Our data security management system has appropriate restrictions on access and distribution of personal data within our departments. We have implemented proportionate measures and controls via our data security, data protection policies and training to our employees; which are frequently reviewed and tested via our compliance and internal audit checks to ensure its relevant and up to date.

Data retention policy

Personal data will not be kept longer than is necessary for the delivery of services or products we are providing to you and or as required by applicable laws. We may keep it for longer than 10 years when we are legally required and or for compliance and audit reasons. For instance, to respond to enquiries

from the Financial Conduct Authority, HMRC or any other regulatory or law enforcement body. When personal data is no longer required and in accordance with our data retention policy, we will securely destroy the data.

Data protection officer

Our Data Protection Officer manages our internal data protection activities and is the first point of contact for supervisory authorities and for individuals whose data are being processed by Reyker. Please find our contact details below.

Cookies

Cookies are files, often including unique identifiers, that are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server. Cookies can be used by web servers to identity and track users as they navigate pages on a website, and to identify users returning to a website. To find out more about how we use cookies when providing our on-line services, please refer to our Cookies Policy which can also be found on our website.

Contact us

If you have any question about this privacy policy, how we process your personal data or have a request regarding your personal information access rights, complaint or If you wish to stop receiving marketing material from us, please contact our Data Protection Officer via email, phone or alternatively write to us at Reyker Securities plc, 17 Moorgate, London, EC2R 6AR. If you require your personal data to be amendment, please contact us at any time via email on dataprotection@reyker.com or call us on 020 3900 2108. We remind you that we will or may require proof of identity and authority before engaging with you or amending any data. If you wish to complain to the Information commissioner’s Office, please find out how by going to https://ico.org.uk/.