"We", "our" or "us" means Close Brothers Group plc and its subsidiaries, affiliates and their respective parent and subsidiary companies (“Close Brothers Group”). For the purposes of data protection law, we are a data controller in respect of your personal data. We collect and use your personal data and where applicable this may include information related to your spouse/partner, directors, partners and owners (your “representatives”). Close Brothers is responsible for ensuring that it uses your personal data in compliance with data protection law.
If you have any questions about this notice, about how we process personal data or about your rights over your personal data, our Data Protection Officer can be contacted at email@example.com or DPO, Close Brothers, 10 Crown Place, London EC2A 4FT.
This notice applies to any personal data we receive from you, create or obtain from other sources and explains how it will be used by us. It is important that you take the time to read this notice so that you understand how we will use your personal data and your rights in relation to your personal data.
We will collect and use the following personal data about you and your representatives:
Your personal data may be used by us in the following ways:
We process your personal data pursuant to the following legal bases:
We may disclose your personal data within the Close Brothers Group and to third party service providers in the circumstances described below:
We will take steps to ensure that the personal data is accessed only by personnel that have a need to do so for the purposes described in this notice.
We may also share your personal data outside of the Close Brothers Group:
These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice.
We may also share your personal data outside of the Close Brothers Group to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation including but not limited to disclosures made to:
The information you provide to us will be transferred to and stored on our secure servers in the European Economic Area (“EEA”). However, from time to time, your personal data may be transferred to, stored in, or accessed from a destination outside the EEA. It may also be processed by staff operating outside of the EEA who work for a company in the Close Brothers Group or for one of our suppliers.
Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance:
In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.
You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contact us” section below.
How long we hold your personal data for will vary. The retention period will be determined by various criteria including:
If you are a customer we will retain your personal data for 7 years following the end of our relationship with you, unless we are required by law to keep it for a longer period of time (in which case, we will keep it until the expiry of the period required by law).
You have a number of rights in relation to the personal data that we hold about you. These rights include:
You can exercise your rights by contacting us using the details set out in the “Contacting us” section below.
You can find out more information about your rights by contacting the data protection regulator, the Information Commissioner, or by searching their website at https://ico.org.uk
We are registered in the UK and our registered address is at Close Brothers Group, 10 Crown Place, London, EC2A 4FT and our company registration number is 520241.
Write to us at our address: Close Brothers Group, 10 Crown Place, London, EC2A 4FT;
By telephone: 0333 321 6100; or
By e-mail: firstname.lastname@example.org