Concentric Financial Services Limited
GDPR Privacy Notice

 

PRIVACY POLICY

Concentric Financial Services Ltd. is a regulated entity based in Jersey (“Concentric”).

This Privacy Policy (the “Policy”) describes how Concentric collects, uses and shares the information you provide to us and the information we collect in the course of operating our website and our business.

If you would like to request any further information for Concentric please contact gbennie@concentric.je.

CONCENTRIC PRIVACY PLEDGE

Within the provision of Concentric services, we commit to the principles of respecting your privacy, keeping your personal data secure and keeping the decision as to how your information is used or shared in your control.

Our privacy pledge:

  • Concentric will collect personal data only that is useful and necessary for providing the services, or improving our products, services and your experience;
  • Concentric will consistently act fairly and with transparency with respect to the collection of and processing of your personal data;
  • Concentric will not sell your personal data, and will share your personal data only when given your explicit consent to do so for a specific reason, or where it is in the legitimate interests of the business to utilise your data in specific circumstances;
  • Concentric will not make decisions based solely on automated processing or profiling of personal data; and
  • Concentric will always take seriously the security of your personal data.

To understand more about the personal data potentially collected by Concentric, please read the full Privacy Policy statement across the following paragraphs.

DATA COLLECTION AND PROCESSING

Subject to relevant local law, Concentric may process certain information about you if this information is necessary in order to perform our contract with you, if you provide your consent, or where it is in our legitimate interests in order to provide our services to you in the most effective way.  This personal data may include what is known as Personally Identifiable Information (PII). PII includes personal data that could identify you as a natural person, including but not limited to names (current and former), address, contact details, date and place of birth, nationality, occupation and other personal identifiers such as tax identification numbers.

Concentric processes your personal data in line with its Privacy Policy and T&C’s to provide you with the information that is of most interest to you, and deliver the services you have requested.

AUTOMATED PROFILING

Concentric does not carry out automated profiling and will not make any decisions based on the automated processing of personal data. No statement or information on this site constitutes a recommendation, offer or invitation to invest in any investments, securities or products of Concentric.

SENSITIVE DATA

Concentric does not seek to collect special categories of personal data (“sensitive data”), including but not limited to data revealing racial/ethnic origin, political opinions, gender, religious or philosophical beliefs, health, genetic and biometric data, or trade union memberships, via this site. We may however ask you to provide this information directly to a third party life assurance provider for the purposes of an application made to them. In such an instance we do not store this data in any way.

Please note that, if you freely provide Concentric with unsolicited sensitive data, subject to the relevant laws, you are explicitly consenting Concentric to use the said data in conformity with this Privacy Policy.

VISITING THE CONCENTRIC WEBSITE

Concentric maintains www.concentric.je (the Site).

We collect some personal data from anyone who visits our Site, we will also track usage patterns with the aim of refining and expanding our service. We may gather details of your domain name, IP address and the details of the website you came from to enable us to improve the Site. Concentric uses Google Analytics to gather this data, we also collect data for cookies.

For more details on what cookies are and what they are used for, please read our full Cookie Policy.

LINK TO THIRD PARTIES WEBSITES

The Concentric Privacy Policy does not apply to third party websites which our Site links to or which advertise on the Concentric website.

Concentric does not control or endorse and is not responsible for the contents of these linked Third Party Sites. Concentric provides hyperlinks to other websites for your convenience only. When you use Third Party Sites, you will be legally bound by the specific terms of use posted on such websites.

COOKIE POLICY

The Cookie Policy is part of our Privacy Policy. Concentric uses cookies on its websites to ensure that you receive the best user experience possible when browsing the Site.

What are Cookies?

Cookies are pieces of data that are sent by servers to web browsers and stored on your computer. Cookies were designed to be a reliable mechanism for websites to remember stateful information (such as items added in the shopping cart in an online store) or to record the user’s browsing activity. The cookies tell us which parts of the Site you have visited so that we can ensure we provide you with information that you are interested in and make any future visits to our website simple and easy for you. The information and data collected by Concentric cookies expire after two years.

What are Social Buttons?

Social media tools, like widgets and plug-ins, are sometimes used so that you can share information from Concentric on other sites such as Twitter or LinkedIn. These interactive mini-programs collect your IP address, record the pages you visit on our site, and set cookies that will enable the widget to function properly. Your interactions with these widgets are governed by the privacy policy of the company providing them, not by Concentric’s Privacy Policy. We may also use Twitter, Facebook and LinkedIn pixel tags to help us understand how effective our marketing is on those sites.

What is Browser control?

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all/parts of our website. If you wish to decline the use of cookies please refer to the instructions for your file management software.

Most browsers allow you to see what cookies you have and delete them on either an individual basis, or block them. You can block cookies for specific websites or for all websites, depending on your preferences.

EMAIL MARKETING

If you are subscribed to a Concentric marketing list, we may periodically send you relevant updates. When you receive marketing emails from Concentric, we may use web beacons, customised links, or similar technologies to determine whether e-mails have been opened and which links you activate, to ensure we can provide focused e-mail communications or other information going forwards.

UNSUBSCRIBING

You may choose to stop receiving marketing emails from Concentric at any time, by Unsubscribing/Opting Out. There is a link at the bottom of every marketing email within which you should update your preferences by selecting/deselecting items based on your personal interests, or unsubscribe in respect of all marketing communications. If you prefer you can make a direct request to unsubscribe by emailing gbennie@concentric.je.

Please note, that by unsubscribing from all marketing emails Concentric will remove your contact details from all mailing lists and place you on a “no mail” list. If you wish to amend or update your preferences use the link at the bottom of any Concentric marketing email or if preferable contact gbennie@concentric.je.

CROSS BORDER TRANSFERS AND THIRD PARTIES

Concentric may share your personal data with: –

  • Concentric affiliates and third-party vendors who process information on Concentric’s behalf, including providers of information technology, identity management, website hosting and management, data analysis, data back-up, security and storage services; or,
  • Other third parties where you have given your consent to the disclosure (either to Concentric or the third party).
  • To competent authorities (including tax authorities), courts and bodies as required by law or requested or to affiliates for internal investigations and reporting.

The disclosure of personal information to the third parties set out above may involve the transfer of data to the USA and other jurisdictions outside Jersey and the European Union (EU) in accordance with the requirements of GDPR and The Data Protection (Bailiwick of Jersey) Law 2018 (as may be amended or replaced from time to time) (the “Data Protection Law”).

In the event that Concentric transfers your personal data to countries that may not have the same level of data protection as that provided in your home country, Concentric will put a contract or other legal instruments available in place to ensure that your personal data is protected in accordance with the relevant laws and regulations, or operate in accordance with your consent where you have provided instructions to us.

INFORMATION SECURITY

Concentric is committed to protecting the security of your personal data. Concentric has put in place measures to protect the security of your personal data and information from loss, misuse, alteration or destruction. Concentric ensures that all appropriate confidentiality obligations, technical, and organisational security measures are in place to prevent unauthorised or unlawful disclosure or processing of such information and data as well as the accidental loss or destruction of or damage to this information and data.

In addition, we limit access to your personal information to authorised Concentric employees and service providers whom are authorised to access the data, and are legally obliged to ensure confidentiality of this information.

DATA RETENTION

The data you submit to Concentric will only be retained for as long as required in order to carry out our contractual, regulatory or legal obligations. When the data is no longer necessary or relevant for the rationale of its collection, Concentric will erase all your personal data held in its systems without undue delay.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once our business relationship has terminated we will retain and securely destroy your personal information in accordance with our data retention and destruction policy and applicable laws and regulations.

RIGHT OF ACCESS AND CORRECTION

Your duty to inform us of changes: –

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Subject to the relevant laws, you have the right to access your personal information (commonly known as a ‘data subject access request’), which enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. Please note that for the execution of this request, you must provide us with a clear identification of yourself and the personal data you require. Such requests should be made by email to gbennie@concentric.je.

You also have the right to request rectification of inaccurate personal data we hold about you. If you would like to exercise this right, you may provide Concentric with a supplementary statement by email to gbennie@concentric.je. Please note Concentric does not assume responsibility for verifying the ongoing accuracy of the personal data provided.

RIGHT TO BE FORGOTTEN

This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.  Such requests should be made by email to gbennie@concentric.je.

Please note, if you wish to exercise your ‘right to be forgotten’ we recommend that you request Concentric retain your information on its ‘no mail’ list. If you are totally removed from the system you could be legitimately and legally added back into the system at some point in the future and therefore could receive future communications from Concentric. If your data is kept on the ‘no mail’ list you will not receive any future marketing communications from Concentric, unless you revise your decision and explicitly request it.

LEGAL DISCLOSURE

Concentric may disclose your personal information to law enforcement, regulatory, or other government agencies or to other third parties as required by, and in accordance with, applicable laws or regulations.

CONTACT AND COMPLAINTS

If you have any questions about this Privacy Policy, you may contact us at gbennie@concentric.je or post at the following address:

Concentric Financial Services Limited
8 Hill Street
St Helier
Jersey
JE2 4UA

 

The Office of the Information Commission in respect of Jersey matters can be contacted at enquiries@oicjersey.org or in respect of UK matters https://ico.org.uk/concerns, should you wish to make a complaint.

AMENDMENTS

Concentric is entitled to update the terms of this Privacy Policy in line with new regulations or directions by the relevant Information Commissioner at any time and without giving you notice. When we make changes to our Privacy Statement, we will amend the revision date at the bottom of this page, and modifications of amendments shall be considered effective as of that revision date for you and your information. We encourage you to periodically review this Privacy Statement if you have concerns as to how we are protecting your information.

Updated November 2019

Concentric Financial Services Limited
8 Hill Street, St Helier, Jersey, JE2 4UA
Tel: +44(0)1534 888801
www.concentric.je

 

Concentric Financial Services Limited is regulated by the Jersey Financial Services Commission for the conduct of investment business.