Concentric Group Ltd
- This Privacy Notice sets out how personal information is collected, processed and disclosed in connection with Concentric Group Limited, Concentric Financial Services Limited and Concentric Analytics Limited (together, “Concentric“).
- As a result of your use of the Concentric website, our provision of services to you (or someone with whom you are connected) or a proposed or actual transaction with Concentric either made by you or a firm or entity with which you have a connection (the “Client“), your personal information and/or the personal information of other relevant individuals (such as directors, officers, employees or beneficial owners)(together, the “Relevant Individuals“) may be provided to Concentric and its service providers.
- Concentric will act as data controller in respect of its use of personal information about Relevant Individuals. In this Privacy Notice, “Concentric”, “we“, “our” or “us” refers to Concentric and “you” refers to the Relevant Individual.
- Service providers appointed by Concentric (as referred to in Concentric’s various Terms and Conditions) may also process personal information relating to Relevant Individuals when conducting administrative and other activities relating to Concentric. Where they are required to do so in order to comply with their own legal and regulatory obligations, they will do so as data controllers in their own right.
- This Privacy Notice sets out how the personal information of Relevant Individuals is collected, processed and disclosed in connection with the activities of Concentric. Unless otherwise provided for in this Privacy Notice, terms and expressions defined in Concentric’s various Terms and Conditions shall have the same meaning where used in this Privacy Notice.
2. The personal information we process
We may collect various types of personal data about you, including:
- identification information (which may include your name, ID card and passport numbers, nationality, place and date of birth, gender, photograph and/or IP address and personal data relating to claims, court cases and convictions, politically exposed person (PEP) status, personal data available in the public domain and such other information as may be necessary for Concentric and its service providers to perform their functions and comply with their customer due diligence processes and discharge anti-money laundering and combating the financing of terrorism obligations);
- tax status information (which may include your tax residency, tax ID and/or your tax status);
- contact information (which may include postal address and e-mail address and your home and mobile telephone numbers);
- information about your family relationships (which may include (for example) your marital status, the identity of your spouse and the number of children that you have);
- professional and employment information (which may include your level of education and professional qualifications, your employment, employer’s name and details of directorships and other offices which you may hold); and
- financial information, sources of wealth and your assets.
- We may also collect and process personal data regarding people connected to you, either by way of professional (or other) association or by way of family relationship.
- Whilst we do not generally collect or process special category data, you may in some circumstances be asked to provide such data to those service providers who we may recommend or otherwise put you in touch with. Additionally, some information collected or processed during the course of our customer due diligence processes may constitute special category data, which will be processed in order to comply with our legal and regulatory obligations.
3. Where we obtain your personal information:
We collect personal information from the following sources:
- personal information which you provide to us or which is given to us by a Client, including but not limited to:
- such forms and documents as we may request that are completed in relation to Concentric;
- information gathered through client due diligence carried out as part of our compliance with regulatory requirements; or
- any personal information provided by way of correspondence with us by phone, e-mail or otherwise;
- personal information we receive from third party sources, such as:
- entities in which you or someone connected to you has an interest;
- your legal and/or financial advisors;
- other financial institutions who hold and process your personal information; and
- credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements; and
- personal information received in the course of dealing with you (or your advisors), regulators, official authorities and service providers by whom you are employed or engaged or for whom you act.
4. Why we collect your personal information:
Lawful grounds for processing:
- We may hold and process your personal information on the following lawful grounds, namely where:
- the processing is necessary for our legitimate interests, provided your interests and fundamental rights do not override those interests;
- the processing is necessary to comply with our respective contractual duties under the terms of Concentric’s Terms and Conditions and any supplemental agreements thereto;
- the processing is necessary to comply with our legal and regulatory obligations;
- (on rare occasions) where we have obtained consent to processing personal information for a specific purpose; and
- on rare occasions, where it is needed in the public interest.
Purposes of processing
- Pursuant to paragraph 4.1 above, personal information may be processed for the purposes set out below (“Purposes“). The Purposes based on our legitimate interests (either wholly or partly) are set out in paragraphs 4.2.1 to 4.2.5 inclusive):
- facilitating the administration of Concentric and its service providers;
- communicating with data subjects as necessary in connection with the contract between the Client and Concentric;
- providing our services to the Client;
- monitoring and recording telephone and electronic communications and transactions:
- for quality, business analysis, training and related purposes in order to improve service delivery; and
- for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act);
- maintaining marketing lists and sending marketing emails and other communications;
- to comply with the legal, regulatory, reporting and/or financial obligations of Concentric or any legal or regulatory obligations of any service provider or functionary (or his/her employer) of Concentric;
- disclosing your personal information to any bank, financial institution or other third party lender providing any form of facility, loan, finance or other form of credit or guarantee to Concentric;
- to enforce or defend the rights of Concentric, or those of third parties who provide services to Concentric;
- collecting, processing, transferring and storing customer due diligence, source of funds information and verification data under applicable laws and regulations relating to anti-money laundering and combatting the financing of terrorism; and
- liaising with or reporting to any regulatory authority (including tax authorities) with whom we are either required to cooperate or report to, or with whom we decide or deem it is appropriate to cooperate in relation to an investment, and which has jurisdiction over Concentric or its investments.
5. Sharing personal information
- We may share your personal information with our group companies and third party service providers, including those referred to in Concentric’s various Terms and Conditions, such as banks, financial institutions, asset managers, IT service providers, auditors, compliance consultants, regulators and legal professionals,to facilitate the running of Concentric. The third party service providers to whom your information may be transferred are based in the following jurisdictions: Jersey, the UK, the British Isles and the European Economic Area.
- Where we share your information with a third party, we require the recipients of that personal information to put in place adequate measures to protect it.
- Where we transfer your personal information outside the European Economic Area, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. This can be done in a number of different ways, for instance:
- the country to which we send the personal information may be approved by the European Commission as providing adequate protection for personal data; or
- by utilising a contract based on “model contractual clauses” approved by the European Commission.
- In other circumstances, the law may permit us to otherwise transfer your personal information outside the EEA.
- If you would like further information about the safeguards we have in place to protect your personal information, please contact email@example.com.
6. Retention of personal information
Your personal information will be retained for as long as required:
- for the Purposes for which the personal information was collected;
- in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations; and/or
- as required by data-protection laws and any other applicable laws or regulatory requirements.
7. Access to and control of personal information
- You have the following rights in respect of the personal information about you that we process:
- the right to access and port personal information;
- the right to rectify personal information;
- the right to restrict the use of personal information;
- the right to request that personal information is erased; and
- the right to object to processing of personal information.
- You also have the right to lodge a complaint about the processing of your personal information either with us, with the Office of the Information Commissioner in Jersey (https://oicjersey.org/), the Information Commissioner (ico.org.uk) should you live or work in the UK, or the data protection authority in the EU member state of your usual residence or place of work.
- Where we have relied on consent to process your personal information, you have the right to withdraw consent at any time.
If you wish to exercise any of the rights set out in this paragraph 7, please contact firstname.lastname@example.org.
8. Inaccurate or amended information
- Please let us know as soon as possible if any of your personal information changes (including your correspondence details). Failure to provide accurate information or to update information when it changes may have a detrimental impact upon Concentric’s ability to provide services. Failure to provide information where it is required for anti-money laundering or other legal requirements means that we may not be able to proceed with transactions in relation to the Client or otherwise provide our Services.
9. Visiting the Concentric Website
- Concentric maintains www.concentric.je (the “Site“).
- We collect some personal data from anyone who visits our Site and we 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.
- 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 you are interested in and make any future visits to the Site easy for you. The information collected by Concentric cookies expires after two years.
- You can block some or all cookies in your browser settings. If you block all cookies (including essential cookies) you may not be able to access all or parts of the Site.
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12. Link to third-party websites
- The Concentric Privacy Notice does not apply to third-party websites which the Site links to or which advertise on the Site.
13. 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.
- 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 email@example.com.
- 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 firstname.lastname@example.org.
- If you have any questions about this Privacy Notice or how we handle your personal information (e.g. our retention procedures or the security measures we have in place), or if you would like to make a complaint, please contact email@example.com.
- This Privacy Notice is up-to-date as of 17th May 2021. If it is updated, we will publish the revised version on the Site.