WENSFER Ltd (“WENSFER” or “We”) considers customer privacy to be a fundamental aspect of its relationship with clients. WENSFER is committed to maintaining the confidentiality, integrity, and security of its current, prospective and former clients’ personal information. WENSFER has developed policies that are designed to protect this confidentiality, while allowing client needs to be served.

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”). WENSFER is responsible for ensuring that it uses your personal data in compliance with data protection law.

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 and understand this notice so that you understand how we will use your personal data and your rights in relation to your personal data.

Personal data that we collect from you

We will collect and use the following personal data about you and your representatives:

Information you give us

This is personal information about you and any other individuals (such as representatives or advisors) that you give us by filling in forms or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your, and your representatives’, name, address, e-mail address and phone number, financial information, and identification records (including your nationality).

You should ensure that in respect of any information you provide us with, which does not relate to you (for example, information about your representatives), you have obtained the necessary consent in order to disclose such information.

Information we collect or generate about you and your representatives

We sometimes record telephone conversations and monitor email communications to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements. The information we capture in this way may include your name, address, e-mail address and phone number, financial information, and identification records (including your nationality).

We generate data to improve our service and to manage, administer and take decisions about the accounts we provide. The information we capture in this way may include your name, address, e-mail address and phone number, financial information, and identification records (including your nationality).

In the course of operating our websites, we may collect and process the following information about you:

• Information that you provide by filling in forms on our websites at www.wensfer.com (and associated sites) (together, “our website”). The personal information you provide in this way may include your full name, title, telephone number and email address.
• Information about when you use our services. We use various technologies to collect and store information when you visit our website. We may, for example, collect information about the type of device you use to access the websites, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our websites, the web pages and the search terms you enter on our websites.
• Information when you report a problem with our website.
• Details of your visits to our website and the resources that you access, for example we may collect information about the content you view and features you access on our websites, the web pages and the search terms you enter on our websites.

Information we receive from other sources

Intermediaries – We may receive information from dealers, brokers and introducers for the purposes of entering in to and administering your agreement. This may include your name, address, e-mail address and phone number, financial information, and identification records.

Publically available information – We may obtain information about you from publically available databases, such as social media sites. The information we capture in this way may include your name, employer, email address and phone number.

How we use your personal data

Your personal data may be used by us in the following ways:

Products & Services

• to ensure content from our website is presented in the most effective way for you and your computer;
• in order to manage and administer accounts and holdings we provide to our clients;
• in order to provide you with information, products or services you may request from us;
• to record and monitor your use of our website or our other online services for our business purposes which may include analysis of usage and measurement of site performance;
• where you have provided your consent to do so, to send promotional information about our products and services via the methods you specify (for example by email or post).

Legal bases pursuant to which we process your personal data

We process your personal data pursuant to the following legal bases:

• in order to perform our obligations under our contract with you;
• to comply with our legal and regulatory obligations;
• to establish, exercise or defend our legal rights and / or for the purpose of (or in connection with) legal proceedings;
• for the prevention of fraud; and
• the use of your personal data as described is necessary for our legitimate business interests such as:
  • to enable us to improve the website and deliver a better and more personalised service to you;
  • enforcing the terms and conditions of any agreement we have with our clients;
  • the recovery of outstanding debts existing under an agreement with our clients;
  • to send promotional information about our products and services via the methods you specify (where you have provided consent to do so).

Sharing your personal data

As a matter of policy, WENSFER does not disclose any personal information provided by its clients or gathered by WENSFER to non-affiliated third parties, except as required or permitted by law or for WENSFER’s everyday business purposes, such as to service a client account. We may disclose your personal data within the WENSFER and to third party service providers in the circumstances described below:

• to ensure the delivery of products or services to our clients;
• to ensure the safety and security of our data;
• to assess compliance with applicable laws, rules and regulations, and internal policies and procedures across our business; and
• for internal research and statistical analysis purposes.

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 WENSFER:

• in order to enforce or apply the terms of use and other agreements our clients have with us;
• any distributor, broker or introducer of an agreement with us;
• if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
• if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer; and
• to third party agents or for the purposes of providing services to us.

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 WENSFER 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 disclosures made to regulators and Companies House), and to establish, exercise or defend our legal rights.

Transfer of personal data outside the European Economic Area

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 WENSFER 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:

• the recipient of the data might be a signatory to WENSFER binding corporate rules;
• the country that we send the data to might be approved by the European Commission or a relevant data protection authority;
• the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data; or
• where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme.

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 or binding corporate rules) by contacting us in accordance with the “Contact us” section below.

How long we keep your personal data

The retention period will be determined by various criteria including:

• our internal policies that dictate the period for which we hold personal data; and
• legal obligations – laws or regulation may set a minimum period for which we have to store your personal data.

Your rights

You have a number of rights in relation to the personal data that we hold about you. These rights include:

• the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
• the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
• in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
• the right to request that we rectify your personal data if it is inaccurate or incomplete;
• the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
• the right to request that we restrict our processing of your personal data in certain circumstances. Please note that there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request;
• the right to object to our processing of your personal data where we process your personal data pursuant to our legitimate business interests. Please note that there may be circumstances where you object to our processing of your personal data but we are legally entitled to refuse that request;
• the right to object to any automated decision making (including profiling) which we conduct based on your personal data, which significantly affects you. Please note that there may be circumstances where you object to us conducting automated decision making but we are legally entitled to refuse that request;
• the right to object to the processing of your personal data for direct marketing purposes; and
• the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.

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 Information Commissioner or by searching their website at https://ico.org.uk/.

Changes to our privacy policy

We keep our privacy policy under regular review. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact us

Please contact us if you have any questions about our privacy policy or personal data we hold about you by completing the ‘contact us’ form on our website.

WENSFER has appointed a Data Protection Officer who can be contacted using the ‘contact us’ details above.

Last updated: March 28 2019