Disclaimer

This Privacy Policy explains how we process personal data. It is subject to our applicable website terms of use.

In this Privacy Policy “we“ refers to Mirabaud Securities Limited which acts as a data controller.

"Personal data“ includes any information relating to an identified or identifiable natural person.

As a data controller, we are responsible for collecting and processing some of your personal data in relation to our activities. The purpose of this Privacy Policy is to let you know which personal data we collect about you, the reasons why we use and share such personal data, how long we keep them, what your rights are and how you can exercise them. Further information may be provided where necessary when you apply for a specific service.

We kindly ask you to read this Privacy Policy. Please note that we may also process personal data in respect of an individual who is a "Related Person“ to you.

A "Related Person“ means an individual or entity whose information you or a third party provide to us and/or which otherwise comes to our knowledge in connection with our business relationship. A Related Person may include, but is not limited to, (i) any director, officer, employee or authorized signatory of a company, (ii) a trustee, settlor, beneficiary or protector of a trust, (iii) any nominee or beneficial owner of an account, (iv) a substantial interest owner in an account, (v) a controlling person, (vi) a payee of a designated payment, or (vii) any representative(s) or agent(s).

In this context, we ask that you liaise with and transmit to your Related Persons this Privacy Policy.

1. WHICH PERSONAL DATA DO WE PROCESS ABOUT YOU?

We collect and use your personal data to the extent necessary in the context of our activities, to achieve a high standard of services. We may collect various types of personal data about you depending on the nature of the particular service we provide, including:

• identification information (e.g., full name and IP address);
• contact information (e.g., address and email address, phone number);
• data which relates to your use of our services, in particular information about the browser or device you use to access our website, how you use our website and the pages you visit, traffic and location data;
• data from your interactions with us (e.g., our meetings, calls, chats, emails, phone conversations); and
• cookie information (e.g. cookies and similar technologies on the website).

We never ask for sensitive data (i.e. personal data related to your racial or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, genetic data, data concerning your sexual orientation or data relating to criminal convictions and offences) unless it is required by law. If we need to process sensitive data for other purposes, we will inform you and obtain your explicit prior consent.

2. FROM WHICH SOURCE DO PERSONAL DATA ORIGINATE?

The data we use about you may be directly provided by you or obtained from other sources, such as an entity we provide services to.

In certain circumstances, we may collect and use personal data of individuals with whom we have, or previously had, a direct relationship such as:

• visitors to our website;
• prospective or existing clients; or
• attendees of our events.

We will not collect information about you where you do not have a direct relationship with us.

3. WHY AND ON WHICH BASIS DO WE USE YOUR PERSONAL DATA?

A. TO COMPLY WITH OUR LEGAL AND REGULATORY OBLIGATIONS

We use your personal data to comply with legal and regulatory obligations and to comply with other legal process and law enforcement requirements, which may include laws outside the country you are located in, including to:

• comply with regulations dealing with prevention of money-laundering, financial crime, financing of terrorism and market abuse;
• comply with regulations relating to sanctions and embargos;
• comply with regulations relating to financial markets in particular with regard to investor protection;
• set up security measures in order to prevent abuse and fraud;
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• record, when necessary, our interactions (such as phone calls, chats, email); and
• reply to an official request from an administrative or judicial authority which may include authorities outside your country.

B. TO PERFORM A CONTRACT WITH YOU OR TO TAKE STEPS AT YOUR REQUEST BEFORE ENTERING INTO A CONTRACT

We use your personal data to enter and perform our contracts, including to:

• provide and perform our obligations with respect to the services we provide or otherwise in connection with fulfilling your instructions;
• enforce applicable terms of contracts;
• send administrative information, such as change of our terms, conditions and policies;
• provide you with information, including reports, regarding our services;
• assist you and answer your requests as a necessary part of the provision of our services to you, and to administer account(s) and manage our relationships; and
• evaluate if we can offer you a service or a product and under which conditions.

C. TO FULFILL OUR LEGITIMATE INTEREST

We use your personal data in order to deploy and develop our services, to improve our risk management, to defend our legal rights and to protect our privacy, safety or property and/or that of our affiliates, yours or others, including:

• to prevent, detect, investigate about fraud;
• to manage our IT infrastructure, customer and third-party configurations and ensure the security of our IT systems;
• to ensure the security of our website;
• to provide customer management and administration;
• to analyse, evaluate and improve our business;
• to develop our business relationship with you and to improve the quality of our services;
• to provide you with marketing information on services that match with your circumstances and characteristics or those of the legal entity that you represent;
• to undertake data analytics to learn more about how you interact with our website; and
• to establish, exercise and/or defend actual or potential legal claims, investigations, or similar proceedings.

D. TO RESPECT YOUR CHOICE IF WE REQUEST YOUR CONSENT FOR SPECIFIC PROCESSING

If we need to carry out further processing for purposes other than those above in Section 4, we will inform you and, where necessary, obtain your consent.

4. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Personal data may be disclosed to third parties in connection with the services we are providing to you. The recipients of any such information will depend on the services that are being provided. To fulfil the aforementioned purposes and subject to any confidentiality restriction we may have expressly agreed with you or any transaction parties, we may disclose your personal data to:

• Mirabaud Group entities (e.g., so that you may benefit from our full range of group services);
• third-party IT service providers, such as TextClever Limited, who perform services on our behalf, such as website development and maintenance;
• financial, taxation, regulatory or judicial authorities, state agencies or public bodies, upon request and to the extent permitted by law;
• to any other persons as agreed with you.

We reserve the right to make personal data accessible to other recipients, as disclosed to you from time to time or if required by applicable laws or requested by a competent authority.

The provision of personal data may be mandatory, e.g., in relation to our compliance with legal and regulatory obligations to which we are subject. Please be aware that not providing such information may preclude us from pursuing a business relationship with, and/or from rendering our services to you.

5. ARE PERSONAL DATA TRANSFERRED OUTSIDE OF OUR JURISDICTION OF INCORPORATION?

In certain circumstances, we may transfer your personal data to another country than the country of establishment of Mirabaud Securities Limited acting as data controller for the relevant personal data processing.

In case of international transfers to a country for which the competent local authority has recognized that it provides an adequate level of data protection, your personal data may be transferred on this basis.

For transfers to a country where the level of personal data protection has not been recognized as "adequate" by the competent authority, we will rely on a derogation applicable to the specific situation or implement appropriate safeguards to ensure the protection of your personal data (such as standard contractual clauses or corporate binding rules approved by competent authorities). To obtain details on the applicable safeguards, please contact us at the address provided under Section 10 below.

6. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

We will retain your personal data for the longer of:

• the period required by applicable law or contractual obligations; or
• such other period necessary for us to meet our operational obligations, such as proper account maintenance, facilitating client relationship management and responding to legal claims or regulatory requests.

Most personal data collected in relation to a specified client is kept for the duration of the contractual relationship with such client plus a specified number of years after the end of the contractual relationship or as otherwise required by applicable law. If you would like further information on the period for which your personal data will be stored or the criteria used to determine that period please contact us at the address provided under Section 10 below.

7. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

Depending on the data protection laws which apply to your situation, you have the following rights:

• To access: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
• To rectify: where you consider that your personal data is inaccurate or incomplete, you can require that such personal data be modified accordingly.
• To erase: you can require the deletion of your personal data, to the extent permitted by law.
• To restrict: you can request the restriction of the processing of your personal data.
• To object: you can object to the processing of your personal data, on grounds relating to your particular situation.
• To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
• To data portability: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party.

Even if you object to the processing of personal data, we are nevertheless allowed to continue the same if the processing is (i) legally mandatory, (ii) necessary for the performance of a contract to which you are a party, (iii) necessary for the performance of a task carried out in the public interest, or (iv) necessary for the purposes of the legitimate interests we follow, including the establishment, exercise or defence of legal claims. We will not, however, use your personal data for direct marketing purposes if you ask us not to do so.

If you require further information, or if you wish to exercise the rights listed above, please contact us at the address provided under Section 10 below.

In accordance with applicable regulation, in addition to your rights above you are also entitled to lodge a complaint with the competent supervisory authority, the Information Commissioner’s Office (www.ico.org.uk)

8. DO WE RELY UPON AUTOMATED DECISION-MAKING OR PROFILING?

We do not use automated decision-making in connection with your personal data. Should we do so in the future, we shall comply with applicable legal and regulatory requirements.

We may automatically process your personal data to assess certain characteristics such as your personal preferences, interests and behaviour based on your use of our services and websites (profiling) in order to provide you with personalized information on our products and services.

9. HOW CAN YOU KEEP UP WITH CHANGES TO THIS PRIVACY POLICY?

We may need to update this Privacy Policy from time to time. We will publish updates of this Privacy Policy on our website and inform you of any material changes through our usual communication channels.

10. HOW TO CONTACT US?

If you have any questions relating to our use of your personal data under this Privacy Policy, please contact our Data Protection Officers as follows:

Mirabaud Securities Limited
10, Bressenden Place
London SW1E 5DH
United Kingdom
Attn: Data Protection Team
msglobaldataprivacy(at)mirabaud-msl.com