Privacy Policy

Altarius Capital Limited respects your privacy and is committed to protecting your personal data, also referred to herein as Personal Information. This privacy notice will inform you as to how we look after your personal data when you use our services (regardless of where you are) and tell you about your privacy rights and how the law protects you.

We will collect and process all Personal Data that you provide us, be that by filling in forms on the website or by corresponding with us via email or post. This includes information you provide us when you subscribe to any of our services or respond to a promotion or survey. If you contact us, we will keep a record of that correspondence.

By entering your details in the fields requested, you enable us and our service providers to provide you with the services you select. Whenever you provide such personal information, we will treat that information in accordance with this policy. When using your Personal Information we will act in accordance with current legislation and aim to meet current Internet best practice.

The data controller and responsible for your personal data is Altarius Capital Limited (collectively referred to as “Altarius Capital Ltd.”, “we”, “us” or “our” in this privacy notice) with registered office at 28 Irish Town, GX11 1AA, Gibraltar and principal place of business is World Trade Center Gibraltar, Unit 5.26, GX11 1AA, Gibraltar.

Our services are not available to anyone under the age of 18 years and therefore we do not knowingly collect data relating to individuals under this age.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

1. THE DATA WE COLLECT ABOUT YOU

2. HOW WE COLLECT AND USE INFORMATION

3. WHO WE SHARE INFORMATION WITH

4. HOW WE APPLY OUR POLICY

5. HOW THE LAW PROTECT YOU

6. COOKIES

7. INTERNATIONAL TRANSFERS

8. YOUR LEGAL RIGHTS

9. MARKETING

10. CHANGES TO OUR PRIVACY POLICY

11. CONTACTING US

1. THE DATA WE COLLECT ABOUT YOU

Personal Data, or Personal Information, means any information about an individual from which that person can be identified. As defined by the General Data Protection Regulation (GDPR), we are data controllers and have a lawful basis for collecting your personal information where you have given us clear consent to do so.

Please note that we are not able to provide our services if you do not consent to us using your data in the manner set out within this policy.

Please note that we are not able to provide our services if you do not consent to us using your data in the manner set out within this policy.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

· Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth, gender and identity numbers as contained within your provided identity documents.

· Contact Data includes your home address, delivery address, email address, telephone numbers and ID for Skype or other social media and communication platforms.

· Transaction Data includes details about payments/transfers to and from you and other details of products and services you have purchased or contracted through us.

· Technical Data includes internet protocol (IP) address, your login data, browser type and version and other technology on the devices you use to access this website.

· Profile Data includes your username, password and any unique identifier assigned by us.

· Usage Data includes information about how you use and services.

· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

2. HOW WE COLLECT AND USE INFORMATION

We collect personal information on our customers in different ways, including:

· When you apply for our financial products and services.

· When you talk to us on the phone or at the office branch.

· When you use our websites.

· In emails and letters.

· When you research or request forms and in writing or through any other medium.

· In financial reviews and interviews.

· In customer surveys

From time to time, we may use your personal details:

· To verify your identity to confirm your continued eligibility to use our products and services, to protect against fraud and to comply with relevant laws.

· To meet orders or requests for services or information and to keep our records up-to-date.

· To tell you by telephone, post or email about special products and/or services that you may be interested in.

· To enable other people or businesses to carry out our work on our behalf.

· Where you have given us your permission, to pass your information to carefully selected organisations to allow them to tell you about their products and services that may be of interest to you.

3. WHO WE SHARE INFORMATION WITH

To provide you with our service, we share your data with a small number of trusted third-party service providers. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

4. HOW WE APPLY OUR POLICY

In order to put our policy into practice, we use our best endeavours to follow seven guidelines:

1. We will ensure our systems are secure to protect your Personal Information from misuse and follow appropriate physical, electronic and managerial procedures to safeguard it

2. We will respect your privacy in the way that we contact you, whether by post, telephone, email or text message.

3. We will not hold your Personal Information for longer than is necessary to effectively provide you with our services and comply with applicable legislation.

4. We will not sell, trade or rent your Personal Information.

5. We will comply promptly with any instructions from you to update your Personal Information or requests from you to see the Personal Information that we hold on you.

6. We will comply with lawful requests to disclose personal information to certain authorities (e.g. the police).

7. We may monitor and record any telephone calls to ensure we follow your instructions correctly and to improve our service.

5. HOW THE LAW PROTECT YOU

As well as our Privacy Promise, your privacy is protected by law. This section explains how that works. Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside Altarius Capital Ltd. The law says we must have one or more of these reasons:

· To fulfil a contract we have with you.

· When it is our legal duty.

· When it is in our legitimate interest.

· When you consent to it.

When we have a business or commercial reason of our own to use your information, this is called a ‘legitimate interest’. We will tell you what that is, if we are going to rely on it as the reason for using your data. Even then, it must not unfairly go against your interests.

The law and other regulations treat some types of sensitive personal information as special. This includes information about racial or ethnic origin, sexual orientation, religious beliefs, trade union membership, health data, and criminal records. We will not collect or use these types of data without your consent unless the law allows us to do so. If we do, it will only be when it is necessary:

· For reasons of substantial public interest.

· To establish, exercise or defend legal claims.

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

We use many different kinds of personal information. The groups are all listed here so that you can see what we may know about you, even if we simply get it from seeing which shops you buy things in. We don’t use all this data in the same way. Some of it is useful for marketing, or for providing services to you. But some of it is private and sensitive and we treat it that way.

6. COOKIES

To optimize your experience at our website, we use cookies. Cookies are small computer files that get sent down to your PC, tablet or mobile phone by websites when you visit them. They stay on your device and get sent back to the website they came from, when you go there again.

Cookies store information about your visits to that website, such as your choices and other details. Some of this data does not contain personal details about you or your business, but it is still protected by this Privacy notice.

You may elect to disable cookies and as a result some of the services may not operate the same as if you were to have the cookie function enabled.

7. INTERNATIONAL TRANSFERS

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your Personal Data. These rules are called “binding corporate rules”.

Adequate safeguards may be provided for by:

· A legally binding agreement between public authorities or bodies.

· Binding corporate rules between entities within the Altarius Capital Ltd. Group of companies.

· Standard or ‘Model’ data protection clauses in the form of template transfer clauses adopted by the European Commission.

· Standard data protection clauses in the form of template transfer clauses adopted by a supervisory authority and approved by the European Commission.

· Compliance with an approved code of conduct approved by a supervisory authority.

· Certification under an approved certification mechanism as provided for in the GDPR.

· Contractual clauses agreed authorised by the competent supervisory authority.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. They are as follows:

· Request access to your personal data.

· Request correction of your personal data.

· Request erasure of your personal data.

· Object to processing of your personal data.

· Request restriction of processing your personal data.

· Request transfer of your personal data.

· Right to withdraw consent.

All of these rights can be applied at any time at the request of the interested subject contacting us by email to dataprotection@altariuscapital.com or letter to the following address: Altarius Capital Ltd. Suite 5.26 World Trade Center, 6 Bayside Road. GX11 1AA Gibraltar.

Request erasure of your personal data

You can also ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to erasure’ or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

Object to processing of your personal data

You can object to us keeping or using your personal information. This is known as the ‘right to object’.

Restriction of processing your personal data

You can ask us to restrict the use of your personal information if:

· It is not accurate.

· It has been used unlawfully but you don’t want us to delete it.

· It is not relevant any more, but you want us to keep it for use in legal claims.

· You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.

· If we do restrict your information in this way, we will not use or share it in other ways while it is restricted.

Get a copy of your personal information

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please contact us by the following ways:

– By email: dataprotection@altariuscapital.com

– Contact by post mail: Altarius Capital Ltd. Suite 5.26 World Trade Center, 6 Bayside Road. GX11 1AA Gibraltar.

Depending on the extent of the request, we may make a small charge for this service. We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

How long we keep your personal information

We will keep your personal information for as long as you are a customer of Altarius Capital Ltd. We may keep your data for up to 10 years after you stop being a customer. The reasons we may do this are:

· To respond to a question or complaint, or to show whether we gave you fair treatment.

· To study customer data as part of our own internal research.

· To obey rules that apply to us about keeping records.

We will only use your personal information for those purposes and will make sure that your privacy is protected.

Withdraw your consent

You can withdraw your consent at any time. This will only affect the way we use information when our reason for doing so is that we have your consent. See the section 7 of this document ‘Your Legal Rights’ about more generally restricting use of your information.

If you withdraw your consent, we may not be able to provide certain products or services to you.

9. MARKETING

We would like to send you information about our services that will be of interest and benefit to you. If you have consented to receive marketing, you may opt out at any time. You have a right to stop us from contacting you for marketing purposes.

10. CHANGES TO OUR PRIVACY NOTICE

We keep our privacy notice under regular review to keep it up to date according legislation and best practices. We will inform you as soon as possible any update, as well as we will placed it on this web page.

If you are unhappy with the way in which we are handling your personal information, you have the right to contact us by the ways described below. You also have the right to complain to the regulator, and to lodge an appeal if you are not happy with the outcome of a complaint. In that case, you have the right to contact the Gibraltar Regulatory Authority (GRA) at http://www.gra.gi/.

11. CONTACTING US

If you have any questions about our privacy notice or information we hold about you, you can contact us by the following ways:

– Contact by email, please contact us at dataprotection@altariuscapital.com

– Contact by post mail: Altarius Capital Ltd. Suite 5.26 World Trade Center, 6 Bayside Road. GX11 1AA Gibraltar.