CONCEPT (“We”) are committed to protecting and respecting your privacy.
This Privacy Statement (together with our General Terms of Business and any other documents referred to) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Concept Group Limited (“Concept” is the Data Controller in accordance with the Data Protection (Bailiwick of Guernsey) Law, 2017, as amended (the Law), as amended or replaced from time to time, details of which can be found at www.dataci.gg .
Processing and using your Data
When providing personal data you are consenting to Concept using your data for the following purposes:
- processing your application;
- the processing of personal data (including where necessary sensitive personal data) in connection with credit, money laundering and financial crime, legal and regulatory checks to comply with our legal and regulatory obligations;
- day to day administration of your product including investing or opening accounts with other institutions;
- processing of information for use in activities that promote other pertinent offerings;
- the transfer of personal detail to other companies, including companies within the same group of companies as Concept who need to process;
- such information under any delegation agreement, or otherwise in relationship to the day to day administration of your product including investing or opening accounts with other institutions;
- prevent and detect fraud, money laundering and other financial crimes i.e. identity fraud.
If you provide us with personal data about other individuals, e.g. joint account holders, dependents/beneficiaries they confirm that you have their authority to provide this information.
The information may include, but is not limited to, contact details, financial information, and details about your health.
Information will continue to be obtained from your interactions with us such as letters, e-mails and telephone calls, which may be recorded and may also be obtained from third parties such as employers and open source intelligence as part of our on-going regulatory requirements.
You may be assured that we and any company associated with us will treat all personal data and sensitive personal data as confidential and will not process it other than for legitimate purposes.
Steps will be taken to ensure that the information is accurate and kept up to date. It is vital that you notify of any changes to your personal information or if there are any changes to your personal circumstances, including who has authority to receive information and or give instructions on your product.
The changes which you should notify us of include but are not limited to:
Name (e.g. marriage, deed poll, etc.), signature, address, telephone number, e-mail address, nationality, tax residence, tax reference no(s), employment, bank account details, beneficiaries.
We will contact you on the details you have provided and will send all correspondence to the most recent address or e-mail address; once we have contacted you we will believe that you have received our communication which is why it is important that you notify us of any changes. Failure to do so may impact the way we are able to administer your product.
If your application is declined, you decide not to proceed or you close your product, your personal information will be retained for as long as required in line with our regulatory requirements.
Where we store your personal data
All information you provide to us is stored on our secure servers. [Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.]
Measures will be taken to safeguard against unauthorised or unlawful processing and accidental loss or destruction or damage to the data.
The data that we collect from you may be transferred to, and stored at, a destination outside the Bailiwick of Guernsey or the European Economic Area (“EEA”). It may also be processed by staff operating outside the Bailiwick of Guernsey or EEA who work for us or a member of our group of companies or for one of our suppliers. Such staff may be engaged in, among other things, the provision of support services or the provision of a service or product to you. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Statement.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Disclosure of your information
We may disclose your personal information, if we have a duty to provide the information for the management of your product, by law or by regulation:
- other companies within the same group of companies as Concept;
- financial institutions, including banks and investments houses to open accounts for your product;
- your advisers, such as financial advisers, investment managers, accountants, tax advisers, if you have provided us with authority for these individuals to represent you, or any other party to whom you have given authority to provide instructions on your behalf e.g. by way of power of attorney;
- Our regulators or any other authorities in any jurisdiction in line with our regulatory requirements including tax authorities;
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If Concept Group Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of use / or other agreement in force between us; or to protect the rights, property, or safety of Concept, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at Concept Group Limited, PO Box 130, Cambridge House, Le Truchot, St Peter Port, Guernsey, GY1 3HH, or email us now.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Access to information and rectification
The Law gives you the right to access information held about you. Your right of access can be exercised in accordance with the Law. Any request for information should be requested in writing and addressed to the Data Controller. You should notify us if any of the data held is incorrect and needs to be amended.
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our user’s browsing actions and patterns, and does not identify any individual. We use IP addresses to analyse trends, administer the Website, track a user’s movement, and gather broad demographic information for aggregate use. IP addresses are not linked to information which identifies an individual. Additionally, for systems administration, detecting usage patterns and troubleshooting purposes, our web servers automatically log standard access information including browser type, access time/ open mail, URL requested, and referral URL. This information is not shared with third parties and is used only within our company on a need-to-know basis. Any information which identifies an individual related to this data will never be used in any way different from that stated above without the user’s explicit permission.
Changes to our privacy statement
Any changes we may make to our Privacy Statement in the future will be posted on this page and, where appropriate, notified to you by e-mail.
Questions, comments and requests regarding this privacy statement are welcomed and should be addressed to Concept Group Limited, PO Box 130, Cambridge House, Le Truchot, St Peter Port, Guernsey, GY1 3HH, or email us now.