Segantii Capital Management (UK) Limited (“Segantii” or the “Firm”) is a company registered in England and Wales with company number 08926874. Segantii Capital Management (UK) Limited is authorised and regulated by the Financial Conduct Authority (“FCA”) with Firm Reference Number 778584.
In accordance with the General Data Protection Regulation (“GDPR”), which came into force on 24 May 2016, with application from 25 May 2018, Segantii hereby provides you with the following privacy notice which describes how we collect and use your personal information.
For the purposes of GDPR, the Firm will be the ‘controller’ of the personal data you provide.
Please read the following information carefully in order to understand the Firm’s practices in relation to the treatment of your personal data.
Should you have any questions, please email email@example.com.
What data privacy principles does the Firm adhere to?
- The Firm will process all personal data in a lawful, fair, and transparent manner;
- The Firm collects personal data where it is necessary:
- For the Firm to provide a service to you;
- For you to provide a service to the Firm;
- For the Firm to provide investment advisory services to its clients;
- For the Firm to establish, maintain or terminate contractual relationships,
including those under a contract of employment;
- For the Firm to keep you informed of its products and services; or
- For the Firm to comply with its legal and regulatory obligations, and maintaining
those obligations which arise in connection with any contract or relationship with
- The personal data collected by the Firm will be relevant, and limited to what is necessary in relation to the specific purpose for which your data will be processed;
- The Firm will take all reasonable steps to ensure that personal data is accurate and, were necessary, kept up to date;
- The Firm will maintain personal data in a form that permits identification no longer than is necessary for the purposes for which the personal data has been collected for processing, in accordance with the Firm’s record retention requirements as mandated by the Financial Conduct Authority and to meet its other legal and regulatory obligations;
- The Firm will hold and process person data in a manner that ensures appropriate security;
- The Firm will only share personal data where it is necessary; and
- The Firm utilises service providers based outside of the UK for the processing of personal data where this is necessary to facilitate our services to you. In all cases, we will ensure service providers are compliant with GDPR, or a regime that is deemed equivalent, ahead of transferring any personal data.
What personal data does the Firm collect and why?
In the course of interacting with or providing services to you, the Firm may collect information that is considered personal information (e.g., name, contact details, address, passport number, driving licence).
As a client, contact or employee of Segantii, we will require some personal information in order to verify your identity and have the applicable relationship with you. Some of this information may be required to satisfy legal obligations (e.g., to comply with obligations arising under the money laundering regulations) whereas other information may be required in connection with the provision of services to you. The information collected will vary depending on your relationship with the Firm, but typically includes:
- Personal information: Such as your name, date of birth, passport number or national insurance number; and
- Contact information: Including your residential address, telephone number and email address.
Where does the Firm store my personal data?
The Firm will typically store your personal data electronically within its computer systems.
The Firm has comprehensive policies, procedures and systems in place to ensure your personal data is kept safe and secure, with these including:
- Data encryption;
- Intrusion detection;
- 24/7 physical protection of the facilities where your data is stored;
- Background checks for personnel that access physical facilities; and
- Security procedures across all service operations.
How long does the Firm retain personal data?
As a regulated entity, the Firm is required to maintain its books and records for a prescribed period (five years from either the ceasing of a business relationship, or, in the case of non clients, from the making of a record – or alternatively, for seven years, where specifically requested to do so by the FCA, or such other period as may be required by an applicable regulatory authority). As such, information that falls in scope of either of these requirements is retained in line with the mandated timeframe.
Any information that is outside the scope of this requirement will be retained whilst relevant and useful, and destroyed where this ceases to be the case or where the data subject specifically requests this, and provided that there is no additional legal or regulatory obligation or need to maintain it further.
What are my rights?
Once you have provided your details to the Firm, you have certain rights which apply, depending on your relationship with the Firm, the information you have shared with us and the Firm’s legal and regulatory obligations.
- 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 email the Firm using the address provided. The Firm will provide this information to you within one month (with the ability to extend this by an additional two months where necessary), free of charge. Please be aware that Segantii reserves the right to charge a reasonable fee for the administrative costs of complying with a request should it believe that the request is manifestly unfounded, excessive or if you request multiple or further copies of your data.
- You have the right to request that the information the Firm holds about you is erased under certain circumstances including where there is no additional legal and/or regulatory requirement for the Firm to retain this information.
- You have the right to request that any information the Firm holds about you be provided to another company in a commonly used and machine-readable format, otherwise known as ‘data portability’.
- You have the right to ensure that your personal information is accurate and up to date, or where necessary rectified. Where you feel that your personal data is incorrect or inaccurate and should therefore be updated, please contact Segantii.
- You have the right to object to your information being processed, for example for direct marketing purposes.
- You have the right to restrict the processing of your information, for example limiting the material that you receive or where your information is transferred.
- You have the right to object to any decisions based on the automated processing of your personal data, including profiling.
- You have the right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/concerns/) if you are not happy with the way that we manage or process personal data.
Information for Prospective Employees
In connection with your application to the Firm, we will process and retain certain information about you for the purposes of determining the outcome of your application.
The data that we process and retain may include sensitive information, including (but not limited to) information concerning race, ethnicity, age, credit reference information and criminal record data.
The Firm collects and holds this data for reasonable purposes such as conducting pre employment screening, fitness and propriety assessments, to support the Firm’s diversity and inclusion objectives, as well as to fulfil the Firm’s legal and regulatory obligations.
The Firm will retain this information for as long as it deems reasonably necessary for those purposes and obligations.
Any data falling into the category of sensitive information will be treated with particular care and attention pursuant to the Firm’s obligations under GDPR.
The Firm reserves the right to transfer your data to third party entities which are domiciled in third countries. By applying for a position at the Firm, you agree and understand that some or all of your data that we hold may be transferred to an entity in a third country.
Will I be notified of changes to this notice?
The Firm may, from time to time, review and update this notice. The Firm will maintain the latest version of this notice on its website, and where the changes are deemed material, it will make you are aware of these.
Who should I direct questions to?
If you have any questions, concerns or complaints about the practices contained within this document or how the Firm has handled your data, please email firstname.lastname@example.org.