Website Privacy Policy
KBI Global Investors Ltd (“we”, “us” or “our”) is committed to protecting and respecting your privacy. This Privacy Statement tells you about your privacy rights and sets out how we, as a Data Controller, collect, use, process and disclose your personal data about:
- your interactions with our website www.kbiglobalinvestors.com (the “Site”)
- individuals who we communicate or interact with in the course of our business
- individuals whose personal data is provided to us in connection with the provision of our services
This Privacy Statement should be read in conjunction with our Cookie Policy;
https://www.kbiglobalinvestors.com/terms-and-conditions/
Please read the following carefully to understand our use of your personal data.
Information we may collect from you
“Personal data” under Data Protection Law (including the EU General Data Protection Regulation 2016/679 (GDPR), the EU Privacy and Electronic Communications Directive 2002/58/EC, and all national implementing legislation) means any information about an individual from which that person can be identified. You can use our Site without being required to provide any personal data to us. We only collect personal data about you on the Site which you volunteer when you email us, by using our online forms, in order to deliver a service or product to you, or to send you newsletters or other information. In addition to the information you provide to us, we collect certain information, as set out below, when you visit our Site.
In providing our services, we may also receive personal data either directly or indirectly in course of our contact with you. Categories of such personal data include: names, addresses, contact information and other information that we are required to collect under our legal and regulatory obligations that is relevant to the provision of our services.
We may collect and process the following types of personal data about you:
Identity Data including name, username or similar identifier
Contact Data including email address, telephone numbers and delivery address,
Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, operating system.
Under our Anti-Money Laundering & Terrorist Financing obligations we may also collect and process the following types of personal data confirming your identity: billing address, passport, driving licence, status as a director and/or beneficial owner of a company
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you do not provide the requested information, we may not be able to deliver our services or products to you or respond to you.
How we use personal data we collect
We will only use your personal data for the purposes and legal bases set out in the table below.
| Purpose(s) for Processing | Legal Basis for Processing |
|---|---|
|
Communicating with you, our clients or other persons in the course of our business |
To support our legitimate interests in managing our business and providing services to our clients provided such interests are not overridden by the rights and interests of the data subjects concerned |
|
Providing our services to clients and managing our business |
As above |
|
Maintaining and operating our website |
As above |
|
For the prevention and detection of fraud, money laundering or other crimes |
The processing is necessary for us to comply with legal and regulatory obligations |
|
Sending newsletters or other direct marketing electronic communications |
|
|
Transferring information to third parties, including to our own service providers
|
To support our legitimate interests in managing our business and providing services to our clients provided such interests are not overridden by the rights and interests of the data subjects concerned; (b) to comply with our legal obligations; or (c) to protect vital interests. |
To support our legitimate interests in managing our business and providing services to our clients provided such interests are not overridden by the rights and interests of the data subjects concerned; (b) to comply with our legal obligations; or (c) to protect vital interests.
We will store your personal data only for as long as necessary for the purposes of providing access to our Site and related services to you; as required by law, and for the exercise or defence of legal claims.
Disclosure of your information
We may disclose your personal data to third parties who provide a service to us and are bound by confidentiality provisions, or 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 or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or where necessary for our legitimate business interests to protect the rights, property, or safety of KBI Global Investors Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We are currently not transferring your personal data to third parties outside the EEA however to the limited extent that that it may be necessary to transfer your personal data outside of the EEA, we will ensure appropriate safeguards are in place to protect the privacy and integrity of such personal data in line with Regulation.
Links to other sites
Our Site may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those websites.
Your rights
You have the right to request access to, rectification, or erasure of your personal data, or restriction of processing or object to processing of your personal data, as well as the right to data portability. The following is a summary of your rights:
- The right of access enables you to receive a copy of your personal data.
- The right to rectification enables you to correct any inaccurate or incomplete personal data we hold about you.
- The right to erasure enables you to ask us to delete your personal data in:
- It is no longer necessary for us to process your personal data;
- You consider the personal data is being unlawfully processed;
- You withdraw your consent (where the processing is based on consent);
- You object to the processing and there are no overriding legitimate grounds justifying the processing; or
- The personal data have to be erased to comply with a legal obligation.
We may refuse your request if the processing is necessary to comply with a legal obligation or for the establishment, exercise or defence of legal claims.
- The right to restrict processing enables you to ask us to halt the processing of your personal data in certain circumstances, including where:
- You contest the accuracy of your personal data;
- You consider the processing is unlawful, but you do not want your personal data erased;
- We no longer need the personal data but you require it for the establishment, exercise or defence of legal claims; or
- You have objected to the processing, and verification as to our overriding legitimate interests is pending.
We may continue to process your personal data:
- Where we have your consent to do so;
- For the establishment, exercise or defence of legal claims;
- The processing is necessary to protect the rights of other individuals or legal persons; or
- For important public interest reasons.
- The right to object enables you to object to us processing your personal data on the basis of our legitimate interests (or those of a third party). We will stop such processing unless we can demonstrate compelling legitimate grounds for the processing which override your interests or the processing is necessary for the establishment, exercise or defence of legal claims. You also have the right to object to us processing your personal data for direct marketing purposes.
- The right to data portability enables you to request us to transmit personal data that you have provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible. The right only applies where:
- The processing is carried out by automated means; and
- The processing is based on your consent or for the performance of a contract with you.
You have the right to lodge a complaint with the Data Protection Authority, in particular in the Member State of your residence, place of work or place of an alleged infringement, if you consider that the processing of your personal data infringes the GDPR.
If you wish to exercise any of these rights, please contact us (Compliance@kbigi.com). We will respond to your request within one month. That period may be extended by two further months where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within one month of receipt of your request. We may request proof of identification to verify your request. We have the right to refuse your request for the reasons set out above, or if it is manifestly unfounded or excessive, or to the extent necessary for important objectives of public interest.
We currently do not engage in automated decision-making, including profiling, the logic involved, and consequences for the data subject, however should this change we will update our Statement accordingly.
Security and where we store your personal data
We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised access and use. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We have implemented strict internal guidelines to ensure that your privacy is safeguarded at every level of our organisation. We will continue to revise policies and implement additional security features as new technologies become available. Where we have given you a password which enables you to access certain parts of our Site, you are responsible for keeping that password confidential. We ask you not to share your password with anyone.
Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Site. Any transmission of personal data is at your own risk. Once we receive your personal data, we use appropriate security measures to seek to prevent unauthorised access or disclosure.
Changes to this Privacy Statement
We reserve the right to change this Privacy Statement from time to time at our sole discretion. If we make any changes, we will post those changes here and update the “Last Updated” date at the bottom of this Privacy Statement. You should check this page from time to time to take notice of any changes we make, as they will be binding on you. If at any time we decide to use your personal data in a manner significantly different from that stated in this Statement, or as otherwise disclosed to you at the time it was collected we will notify you by e-mail and you will have the choice as to whether or not we use your personal data in the new manner.
Contact Us
If you have any questions or concerns regarding this Privacy Statement please contact us at compliance@kbigi.com. All requests will be dealt with promptly and efficiently.
Last Updated: 25 May 2018