Privacy Policy

This privacy policy explains how Bordier & Cie (UK) PLC (“us”, “we”, “Bordier UK)” uses any personal information which we collect about you.

How do we collect information about you?

We collect information about you when you contact us, when you apply to use our services, when you or an intermediary on your behalf asks us to provide a service proposal for you and in the course of meetings and discussions with you and/or your appointed intermediary.

We only collect information about you which is needed to provide you with the services which you have requested or an intermediary has requested on your behalf. This includes data which is required for us to comply with legal and regulatory requirements.

Special Category Data

EU data protection regulation defines certain categories of information as “special category data” which we may require your consent to hold.

In the course of meetings and discussions with you we may record information which you tell us about your health, political opinions, religious beliefs, trade union memberships and your children, where it is relevant to how we provide services to you. You have the right to ask us not to record this information and may withdraw your consent at any time by contacting [email protected].

In order for us to advise about and arrange certain types of products for you we may need you to provide information about your medical history. This information may also be shared with the providers of such products. You may withdraw your consent for us to hold this data at any time by contacting [email protected]. However, if you do so we may no longer be able to provide the services you have requested.

Cookies

What is a cookie?

A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, mobile phone or tablet browser from a website and is stored on your device’s internal storage. Each website can send its own cookie to your browser if your browser’s preferences allow it, but to protect your privacy browsers usually only permit a website to access the cookies it has already sent to you, not the cookies sent to you by other websites.

 How does Bordier UK use cookies?

Cookies are used for three purposes on the Bordier UK website. Firstly they are used to collect information about how visitors interact with our site including information such as your IP address, operating system and browser type. This is anonymous statistical data which provides us with information we can use to help monitor the performance of the website and improve it.

The other use of cookies on the Bordier UK website is in the “Client Login” and “Professional advisers” areas. When you log in to these areas, our site will send you a unique identifier in a cookie so that it can keep you logged in. This is destroyed when you log out of the site or close your browser and does not contain any information which personally identifies you.

If you choose to tick the box on the “Client Login” page so that your browser remembers your username, then our site will send your computer a cookie that contains the information in an encrypted form (using Triple DES encryption). If you want to remove this cookie you can do so by unticking the box the next time you log in. Please note that we will never save your password in a cookie.

What do we use your information for?

We use the personal information we collect about you for the following purposes:

• to respond to a query you have sent us
• to process your application to use our services
• to provide you with services which you have requested
• to identify you when you contact us
• to comply with regulatory and legal requirements
• for internal analysis and research
• to contact you about our services which we believe to be in your interest

Who do we share your information with?

Your information may be shared with third parties where it is necessary to enable us to provide services to you or to comply with legal or regulatory requirements. The third parties we may share your information with are as follows:

Legal and Regulatory Bodies

We have a legal obligation to disclose certain information to the Financial Conduct Authority, other regulatory bodies and some government agencies if requested by them.

Your appointed advisers

We may provide relevant information about you and your investments to advisers appointed by you such as your financial adviser, accountant or other such professional adviser.

Pension trustees, bond providers and other service providers

You may ask us to advise you about, setup on your behalf or manage your investments within products such as pensions, trusts, bonds and other such products. We will share required information with the providers of such products in order to provide services you have requested from us.

Credit reference and fraud prevention agencies

In order to comply with legal and regulatory requirements and in order to help prevent money laundering and other financial crime we may have to verify your identity. This involves us entering your details into credit reference and fraud prevention websites, which will check your details against international databases and provide us with a verification report. We may do this as part of our account opening process, and will repeat these checks at least every three years, or if significant changes in your life have occurred since you first invested with us. Some of the websites we use may undertake ongoing automatic checks to see if your details have changed.

Trusted third parties who assist us with conducting our business

Our appointed professional advisers such as lawyers, auditors and accountants will sometime require access to the data we hold. In addition, some of the data we hold about you is disclosed to third party service providers who assist us with conducting business and providing services to you.

We do not share your data with any third parties other than those defined in this privacy policy and we will never sell your information to a third party.

Transferring information outside the EEA

We share your information with third parties who assist us in providing services to you and this may involve transferring it to countries outside the European Economic Area (EEA) whose data protection laws may not be as extensive as those which apply here. Where we do so, we will ensure that this is done in accordance with UK and EU regulations and will take appropriate measures to ensure that the level of protection for your personal information remains the same as within the EEA by using suitable contractual clauses.

How long do we keep your information for?

We will retain relevant information about you as long as you remain a client with us and for up to 7 years after you cease to be a client of ours in order to comply with our legal and regulatory obligations and for us to be able to respond to queries and claims about the services we have provided to you. Where information is no longer relevant or is excessive we will delete it as soon as possible.

Your rights

You have various rights over the personal information which we hold about you:

The right to object

• You may object to us using your data for marketing purposes by contacting [email protected] with the subject “Please unsubscribe me from all marketing materials”.
• You may also object to us using your information or for our legitimate business interests. We will delete your personal information held for this purpose where there is no overriding reason for us to continue to hold the information such as regulatory requirements or where we need to hold the data to defend the business against legal claims. Should you do this we may no longer be able to provide services to you.

Other rights

• You may at any time request a copy of the information which we hold about you.
• You may request a copy of your information in a standard electronic format (csv file) for you to give to another service provider. We will provide such data where we are required to and on a best endeavours basis in all other circumstances
• If you find any inaccuracies in the information we hold about you then you have the right to ask us to correct them.
• You have the right to ask us to delete your data, or to restrict what we do with it and we will do so where there is no overriding reason for us to retain the data such as regulatory requirements. Should you do this we may no longer be able to provide services to you.
• For data which we require your consent to hold (see “Special Category Data” above) you may withdraw that consent at any time and we will delete the data. Should you do this we may no longer be able to provide services to you.

Please contact [email protected] if you wish to make a request under any of the rights outlined above.

You have the right to lodge a complaint with the Information Commissioner’s Office. You can find up to date details on how to contact them at https://ico.org.uk/concerns/

Bordier & Cie (UK) PLC is authorised and regulated by the Financial Conduct Authority and registered with the Information Commissioner’s Office. Incorporated in England No. 1583393. Registered office 23 King Street, London, SW1Y 6QY.