This document explains how Third Financial (‘we’) uses any personal information we collect about you.
What information do we collect about you and why?
We collect and use personal data where we have a legitimate reason to do so. This includes keeping records of transactions and providing a service to our clients. We collect information via the account application process provided to you by one of our customers (who may be wealth managers or other investment service providers) and throughout our relationship with you in order to comply with regulation and for the purpose of performing our contract with you. The provision of your personal data is required in order to enter into a contract with us. We record and may monitor phone calls made to or by us in order to comply with regulatory obligations.
How long do we keep this information?
We will keep your personal information for as long as it’s considered necessary for the purpose for which it was collected and to comply with our legal and regulatory requirements. This will involve keeping your information for a reasonable period of time after your relationship with us has ended – typically 5 years.
Who do we share your information with?
- our IT and service providers in order to provide and maintain the provision of our services;
- our appointed auditors, accountants, lawyers and other professional advisers, to the extent that they require access to the information to provide advice;
- fraud prevention agencies and other organisations to allow us to undertake the relevant checks;
- the Financial Conduct Authority, the Information Commissioner’s Office, or any relevant regulatory authority where they are entitled to require disclosure;
- if required to do so to meet applicable law, the order of a Court or market rules and codes of practice applicable to the circumstances at the time;
- relevant authorities to investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law;
- if tax regulations require us to collect information about tax residency, then in certain circumstances (including if we do not receive a valid self-certification from you), we may be obliged to share information about your account with the relevant tax, payments and customs authority, who may pass this on to tax authorities in other jurisdictions.
We will not lend or sell your information to third parties.
Your personal information may need to be shared with our service providers, which may involve transferring it to countries outside the European Economic Area (EEA). Where we do so, we will ensure that we do this in accordance with current data protection legislation by only transferring your data to jurisdictions in respect of which there is a European Commission adequacy decision or, where this is not the case, by using model clauses which have been approved by the European Commission.
You have certain rights in respect of the data we hold relating to you. Details of these rights can also be found on the Information Commissioner's Office website. You are entitled to a copy of the information we hold about you in a portable format or otherwise, to request rectification, erasure, or restriction of processing of the information we hold about you, and to object to processing or to automated decision making. Please note that the application of these rights vary according to the legal basis used to process your data. In certain circumstances we are required to retain copies of information we hold about you by other regulations. In this instance we will not be able to erase or modify the data. In order to exercise these rights or if you have any concerns about our use of your personal information, please contact the Data Protection Officer using the information at the end of this notice. We will endeavour to keep your information accurate. If, however, at any time after giving us this information it becomes out of date, we ask you to notify us directly and we shall remove or amend the information within a reasonable time frame and in accordance with legislative requirements.
Internet communication, which includes email, is not secure. The protection of data by encryption is possible provided that the encryption method (protocol) used is current and the correct procedure for encryption and decryption is followed at all times. We cannot accept any responsibility for unauthorised access by a third party or for the loss, theft or modification of data while it is being sent to us by email. For security purposes we may monitor emails received or issued by us.
Changes to our Privacy Notice
We keep our privacy notice under regular review. This privacy notice was last updated in June 2019. We reserve the right to update this privacy notice at any time.
How to contact us
If you have any questions about our privacy notice or the information we hold about you please contact us by post at the address below:
Data Protection Officer
20 Birchin Lane