This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.molybank.com including any information you may provide through our site when you purchase a product or service or sign up to our newsletter.
We need to collect and use certain types of personal information about the people we deal with, such as current, past and prospective clients, suppliers, affiliates, employees, professional contacts and others with whom we communicate.
In addition, we may occasionally be required, by law or via our professional bodies including lawyers and bankers, who provide banking, consultancy, legal, insurance and accounting services to collect, use and share certain types of personal information to comply with the requirements of government departments, agencies and regulators.
Under the Data Protection Legislation, all organisations which handle personal information must comply with a number of important principles regarding the privacy and disclosure of this information.
We believe that the lawful and correct treatment of personal information is critical to our successful operation. We recognise that to maintain our professional reputation and integrity, we must be fully compliant with this legislation.
By providing us with your data, you warrant to us that you are over 13 years of age.
Data Protection Legislation
In the United Kingdom and the European Economic Area (EEA), “Data Protection Legislation” means all applicable data protection and privacy legislation or regulations including The Privacy and Electronic Communications (EC Directive) Regulations 2003 (also known as PECR) and any guidance or codes of practice issued by the European Data Protection Board or the Information Commissioner, together with:
- prior to 25 May 2018, the UK Data Protection Act 1998; and
- from 25 May 2018 onwards Regulation (EU) 2016/679 (the “General Data Protection Regulation” or “GDPR”), as amended by the UK Data Protection Act 2018.
We fully endorse and adhere to the principles of data protection set out in the Data Protection legislation and will:
- fully observe the conditions regarding the fair collection and use of personal information.
- meet our legal obligations to specify the purposes for which we use personal information.
- only collect and process the personal information needed to carry out our business or to comply with any legal requirements.
- ensure that the personal information we use is as accurate as possible.
- ensure that we don’t hold personal information any longer than is necessary.
- ensure that people know about their rights to see the personal information we hold about them.
- take appropriate technical and organisational security measures to safeguard personal information; and
- ensure that personal information is not transferred abroad without suitable safeguards.
Additionally, we will ensure that:
- there is someone with specific responsibility for data protection in the organisation- Amanda Farran - email@example.com
- we regularly review and audit how we handle personal information.
- the ways we handle personal information are clearly described.
- everyone handling personal information understands that they are responsible for following good practice.
- everyone handling personal information is appropriately trained and properly supervised.
- we regularly assess the performance of people who handle personal information.
- anybody wanting to make enquiries about handling personal information knows what to do; and
- Queries about handling personal information are dealt with properly and courteously.
- If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
- It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at firstname.lastname@example.org
The types of personal data we collect and use
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows:
- Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender, National Insurance numbers.
- Contact Data may include your billing address, delivery address, email address and telephone numbers.
- Financial Data may include your bank account details and other financial details.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
Special Personal Data
- We do not collect Special personal data that 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.
- We need to collect the following sensitive data about you - criminal convictions and fraud checks -in order to deliver our service and comply with the financial and legal regulations governing our business. We require your explicit consent for processing sensitive data, so when you submit your details we will ask you to sign a consent form at the same time as our GDPR consent form, so that we may proceed with your application.
Using your personal data: the legal basis and purpose
We will process your personal data:
- As necessary to perform our contract with you and to update our recordsAs necessary for our own legitimate interests e.g. for good governance and managing our business operations and to send you marketing communications (or those of a third party) and your interests and fundamental rights do not override those interests.
- As necessary to comply with a legal obligation e.g. when you exercise your rights under data protection law and make requests; for compliance with legal and regulatory disclosures, for establishment and defence of legal rights; to verify your identity and anti-money laundering checks including criminal records and fraud checks.
- Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at email@example.com
- Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email Amanda Farran , firstname.lastname@example.org
- If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
Subject to applicable data protection law we may share your personal data with:
- Government bodies and agencies in the UK e.g. HMRC and Companies House;
- Sub-contractors and other persons who help us provide our services;
- Professional advisers including lawyers, bankers, and auditors who provide consultancy, banking, legal, insurance and accounting services.
- Service providers who provide IT and system administration services.
- Courts, to comply with legal requirements;
- In an emergency or to otherwise protect your interests;
- Anyone else where we have your consent or as required by law.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
INTERNATIONAL DATA TRANSFERS
We share your personal data with international agents which involves transferring your data outside the European Economic Area (EEA). Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data. The majority of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention periods
- We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
- To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
- By law we must keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
Your rights under applicable data protection law
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- 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.
You can see more about these rights at www.ico.org.uk.
If you wish to exercise any of the rights set out above, please contact firstname.lastname@example.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of the website concerned.