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Privacy Notice - River and Mercantile Derivatives (Clients)

We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

Who we are

River and Mercantile Derivatives, a division of P-Solve Investments Limited, collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) from 25 May 2018 and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

The personal information we collect and use

Information collected by us

In the course of providing investment advisory and/or investment management services we collect the following personal information when you provide it to us:

  • first name and last name;
  • personal identification documentation and related information including date of birth, place of birth, personal identification numbers, nationality and residential address;
  • contact information including email and telephone numbers; and
  • where specifically requested, employment history, address history, proof of address.

Information collected by other sources

We may also obtain personal information from other sources such as private and/or public compliance databases. The information obtained will likely detail whether you may be a “politically exposed person” or whether you have committed particular crimes, relevant to your participation in financial services.

How we use your personal information

We use your personal information to:

  • carry out “know your client” and anti-money laundering checks, including checking such personal information against databases of individuals who are subject to sanctions, classified as “politically exposed persons” or have committed crimes as referenced above;
  • enter into and contact you with respect to investment advisory and/or investment management agreements; and
  • contact you, with your consent, about new or existing products or other information that we think are relevant to you using the contact information which you have provided.

If you do not wish to receive marketing communications from us about our products and services, then you can select your choices by ticking the relevant boxes situated on the form on which we collect your contact information.You can change your marketing preferences at any time by contacting us by email: marketing@riverandmercantile.com.

Who we share your personal information with

We routinely share your name, address and date of birth with certain of our third party suppliers, including anti-money laundering compliance companies, counterparty banks and your custodian. This data sharing enables us to carry out the required anti-money laundering checks, and for counterparty banks and custodians to carry out their anti-money laundering checks and provide their services directly to you.

Some of those third party suppliers may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.

We will share personal information with law enforcement or other authorities if required by applicable law.

We will not share your personal information with any other third party.

How long your personal information will be kept
  • We will hold your personal information for as long as we provide services to you and will hold personal information in archive after that date to the extent necessary for legitimate business purposes (currently 6 years).

Reasons we can collect and use your personal information

The lawful basis on which we collect and use your personal information includes:

  • in respect of names, the lawful condition for processing is necessary for performance of a contract;
  • in respect of names, addresses and dates of birth, the lawful condition for processing is a legal obligation; and
  • in respect of names, email and telephone numbers for marketing, the lawful condition for processing is consent.

Transfer of your information out of the EEA

We may transfer your personal information to third party suppliers inside and outside the European Economic Area (EEA) for purposes of support and data storage back-up. Any such transfer of your personal information will be subject to appropriate safeguards to protect your personal information, including appropriate contractual protections. In addition, we may disclose your personal information to anti-fraud organisations and law enforcement or regulatory agencies anywhere in the world.

If you would like further information please contact us (see ‘How to contact us’ below). We will not otherwise transfer your personal data outside of the EEA.

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

  • fair processing of information and transparency over how we use your use personal information
  • access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
  • require us to correct any mistakes in your information which we hold
  • require the erasure of personal information concerning you in certain situations
  • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • object at any time to processing of personal information concerning you for direct marketing
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • object in certain other situations to our continued processing of your personal information
  • otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation .

If you would like to exercise any of those rights, please:

  • email, call or write to us
  • let us have enough information to identify you
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
  • let us know the information to which your request relates

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you a right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

Changes to this privacy notice

This privacy notice was published on 10 April 2018 and is effective from 25 May 2018.

We may change this privacy notice from time to time, when we do we will inform you via email.

How to contact us

Please contact us if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact us please send an email to your usual client relationship manager, or call 0203 327 5100.

Download a pdf copy of this privacy notice by clicking HERE.