Privacy Notice
At Westminster Capital Limited, we are committed to protecting your privacy and ensuring that your personal information is collected and used appropriately, lawfully and transparently.
This privacy notice explains:
- Who we are
- What personal information we collect
- How we use your personal information
- Who we share your information with and why
- How we keep your information secure
- Your rights
- How to contact us
Who we are
Westminster Capital Limited is regulated by the Jersey Financial Services Commission for the conduct of investment business and funds services business.
What personal information we collect
We collect certain personal information about you, which may include your name, address, phone number and other information. We collect this information about you when you:
- use our website and secure online services;
- contact us about our services;
- apply for and receive our services; or
- register to receive one of our newsletters.
The types of personal information we collect will depend on the purpose for which it is collected but may include:
- your contact details;
- information to verify your identity;
- information about your family, lifestyle and health;
- financial and bank details; and
- information about your employment and education.
We collect personal information directly from you. For example, we ask for personal information at the start of our relationship (eg: when you apply for one of our services) and in subsequent communications in order to check your identity. This is a legal requirement and is important to help safeguard you and us against potential crime.
Where we provide our services to trusts, we may collect personal information about the settlor, beneficiaries and trustees of that trust. Where we provide our services to companies we may collect personal information about the directors, shareholders and beneficial owners of the company. Where we provide our services to charities, we may collect personal information about the trustees or directors of that charity.
Where it is necessary, we collect more sensitive information (such as criminal convictions or detailed health information). If this is the case we will explain what information we require, why it is needed and where required, will ask you for consent.
We may also collect information about you from other sources such as:
- your professional adviser;
- another agent (if you have one);
- external third parties (eg: credit reference agencies to verify your identity); and
- from cookies (Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the website owners). Learn more about information collected through cookies here.
We keep your personal information only as long as is necessary for the purpose for which it was collected, or for legal or regulatory reasons. Personal information will be securely disposed of when it is no longer required in accordance with our Data Retention policy.
Monitoring of communications
Subject to applicable laws, we will monitor and record calls emails’ and other communications relating to clients and related parties dealings with us. We will do this for regulatory compliance, self-regulatory practices, crime prevention and detection, to protect the security of the communications systems and procedures, to check for obscene or profane content, for quality control and staff training, and when we need to see a record of what has been said. This is justified by our legitimate interests or our legal obligations.
How we use your personal information
We process your personal information for the following purposes.
To perform our contract with you and to support and maintain our relationship. This includes the following:
- assessing and processing an application for our services;
- providing our services to you, including the management of our relationship with you and your professional adviser, or any other agent (if you have one);
- carrying out transactions on your behalf;
- monitoring or recording telephone calls with you to resolve any queries or issues or for regulatory reasons;
- record keeping to ensure our services operate within the law and relevant regulatory requirements; and
- providing other services (eg: enhanced due diligence, data hosting, online services, and payments or reporting of any tax or levy).
To comply with legal and regulatory requirements. These requirements include the following:
- confirming your identity for regulatory purposes; and
- detecting and preventing fraud, money laundering, terrorist financing, bribery or other malpractice.
For specific business purposes to enable us to provide you with appropriate services and a secure experience. Such business purposes include the following:
- verifying your identity for security purposes;
- sending marketing communications to you which you have opted into receiving or which we think may interest you based on the services you receive from us or other companies in our group;
- enhancing, modifying and personalising our services for your benefit;
- providing reports and other communications to you where we are required to do so;
- client satisfaction research or statistical analysis;
- audit and record keeping purposes;
- enhancing the security of our network and information systems; and
- maintaining effective management systems including internal reporting to our parent company and other members of our corporate group.
- customer satisfaction research, statistical analysis and wider market research to capture the views and opinions of our customers
- Monitoring and managing the statistical balance of our associates, customers and advisers by statistically reviewing the diversity of different groups to ensure inclusivity.
You have the right to object to us processing your personal information for the business purposes listed above but, if you do so, this may impact on our ability to provide some or all of our services to you.
Who we share your personal information with and why
We share your information with trusted third parties who perform tasks for us and help us to provide our services to you. We may also share your information with agencies where required by law, court order or regulation.
These third parties include:
- other companies within the Westminster Capital group;
- your professional adviser, third party data providers used by your professional adviser and any other party authorised by you;
- those who perform tasks for us to help us provide our services to you (these third parties may be based in countries outside of Jersey);
- those who are able to verify your identity, in line with money laundering or other regulatory or legal requirements;
- organisations, including the police and fraud prevention agencies, to prevent and detect fraud;
- regulatory or governmental agencies or bodies such as the Jersey Financial Services Commission;
- securities, options and futures markets and exchanges on which we may deal in connection with your account with us;
- a clearing house or clearing agent (or to investigators, inspectors or agents appointed by any of them) for the purpose of executing and settling transactions we have entered into on your behalf;
- investment or product providers who ask for that information in order to allow us to make investments on your behalf or to continue to provide our services to you;
- our appointed legal or regulatory advisers or auditors; and
- a prospective buyer (or its advisors), for due diligence purposes, if we are considering a sale of any of our business or assets.
- a third party to conduct market research on our behalf, to help us improve and develop the products and services we provide to you and our other customers.
International transfers
Personal data will be transferred between Westminster Capital Limited in Jersey and third party processors who we use to deliver our services to allow us to provide our services to clients. These transfers will be to businesses in Jersey, the European Economic Area or other jurisdictions who are subject to adequate protections under their data protection laws.
Personal data will also be sent to third parties in jurisdictions requested by our clients in order to facilitate their requirements. Some countries have equivalent protections in place for personal data under their applicable laws, in other countries steps will be necessary to ensure appropriate safeguards apply. These include imposing contractual obligations of adequacy in line with the data protection legislation in Jersey. Where this is not possible Westminster Capital Limited will rely on the client’s explicit consent to provide such information to entities in these jurisdictions which is considered to be obtained on the basis of the client’s instructions to us.
How we keep your information secure
We are committed to ensuring the confidentiality of the personal information that we hold about you and regularly review our security controls and related policies and procedures to ensure that your personal information remains secure.
When we contract with third parties we require them to have appropriate security, privacy and confidentiality measures in place to ensure that personal information is kept secure.
Your rights
You have the right to ask us:
- for a copy of the personal information we hold about you and information about how we process it;
- to update or correct your personal information;
- to delete your information (the “right to be forgotten”); and
- to restrict processing of your personal information where appropriate.
In certain circumstances you also have the right to:
- object to the processing of your personal information;
- object to any automated decision making and profiling; and
- move, copy or transfer personal data (“data portability”).
Information about your individual rights, including how to correct, restrict, delete, or make changes to your personal information, can be found on our website here.
More information about your data protection rights can be found here:
How to contact us
You may give and withdraw consent to the receipt of marketing information and tell us your communication preferences at any time. If you wish to change your preferences regarding the receipt of marketing or other communications from us, please contact [email protected] or telephone + 44 (0)1534 616818.
If you:
- wish to give or withdraw your consent for us to use your data;
- wish to update or correct your personal information;
- have questions about this notice; or
- need further information about our privacy practices,
- raise a complaint about how we have handled your personal data.
please contact our Data Protection Officer by post at Westminster Asset Management, 3rd Floor, Le Gallais Building, 54 Bath Street, St Helier, Jersey, JE2 4SU by email at [email protected] or by telephone on + 44 (0)1534 616818.
If you are not satisfied with our response you can complain to our regulator:
Jersey Office of the Information Commissioner
2nd Floor
5 Castle Street
St. Helier
Jersey
JE2 3BT
Definitions
Legal or regulatory obligations
Means processing personal data where necessary for complying with a legal or regulatory obligation that we are subject to.
Legitimate Interests
Means the interests of our business in conducting and managing our business to enable us to ensure that the best services are provided. We will make sure that we consider and balance any potential impact on clients and related persons (both positive and negative) and their rights before we process personal data for our legitimate interests. We do not use personal data for activities where such person’s interests are overridden by the impact on them (unless we have their consent or are otherwise required or permitted to by law). Clients and related persons can obtain further information about how we assess legitimate interests against any potential impact in respect of specific activities by contacting us at [email protected].
