Privacy Policy

 

Introduction and Purpose

The General Data Protection Regulation (“GDPR”) governs the controlling and processing, such as the use or holding, of personal data, which is essentially any information about identifiable living individuals, and also gives those individuals certain rights and remedies in respect of that information.

The purpose of this notice is to supply you with the required information at the time of providing us with your personal data. This will lay out the essentials such as the what; where; when; and how in relation to the personal information collected. This should help you feel more confident about the privacy and the security of your personal information.

Please read this Privacy Notice carefully. By visiting our website or using any of our services, you indicate your agreement to our use of your personal information as set out in this Privacy Notice.

Identity and contact details of the Data Controller

South River Asset Management Ltd (“South River”) company number 04195976 whose registered office is at Atlas House, 1 King Street, London, EC2V 8AU, is the Data Controller and is committed to protecting the rights of individuals in line with the GDPR.

Contact details of the Data Protection Officer

South River’s Data Protection Officer can be contacted through info@southriveram.com. This individual has oversight responsibility for the usage and processing of personal data.  Any questions relating to data security should be directed to the Data Protection Officer.

Information we collect about you

When do we collect information?

We will collect information from you when you register with us, apply to use any of our services, become our client, or contact us in person, by telephone, by email or by post. We also collect information from you when you provide feedback or complete a contact form on our website.

We may collect information about you from fraud prevention agencies and other organisations when we undertake checks such as identification verification checks, as explained further below.

What information will we collect and why?

We may collect the following information depending on the service provided:

  • Your contact details, such as your name, address, telephone number and email address;
  • Your date of birth, nationality, country of birth, country of residence, employment status and tax identification number (i.e. National Insurance Number);
  • Passport details, driving licence and utility bills;
  • Details of the services you request from us;
  • Any records held by financial crime prevention agencies, on the Electoral Register and by providers of utility services; and
  • Details of your employment status, income and source of wealth.

In some cases, you are not obliged to provide any personal data to us, but if you have requested information or a service from us, we will not be able to provide it without certain information, such as your contact details. Before we can begin providing you with our services, we need to obtain certain information about you, so that we can verify your identity in order for us to meet our obligations under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 and any other applicable legislation and for the purposes of crime prevention and fraud prevention. You are obliged to provide this information and if you do not provide it, we will be unable to provide you with our services.

We also collect information from you when you voluntarily complete customer surveys, provide feedback or complete a contact form on our website.

Cookies

Our Website makes use of cookies. placed on your computer’s hard drive. Cookies can remember which websites you have visited, help analyse web traffic or personalise your online experience.

You can use your browser settings to manage cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to block cookies if you prefer. At present, the only non-essential cookies used by this website are first party cookies from Google Analytics. We do not use any third-party cookies.

We use Google Analytics to measure the effectiveness of our website and marketing strategies and tailor content towards our visitors. The information collected may identify your ISP domain, but it does not identify you personally. Google holds this data and makes it available to authorised users to access. Other less intrusive tracking technology, such as session cookies, is used by this website, to help manage traffic on our servers. These cookies do not collect any personal information about the user and are deleted from our system when your session on our website expires.

We may also use traffic log cookies to identify which pages are being used. Again, these cookies do not collect any personal information from your PC, but help us to analyse data about web page traffic and improve our website in order to tailor it to customer needs.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

Automated Processing

South River does not make use of automated processing or decision making.

How will we use your information?

We use information held by you in the following ways:

  • To process your application to use our services;
  • To undertake checks such as identification verification checks with fraud prevention agencies to enable us to comply with our anti-money laundering obligations and for the purposes of crime prevention and fraud prevention;
  • To comply with our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
  • To help protect your information and prevent unauthorised access to it;
  • To deal with any queries, complaints or problems reported by you;
  • To generate statistics relating to use of our website, such as the popularity of certain features or services. We do not use personally identifiable information for these purposes;
  • To provide you with information about other services we offer that are similar to those that you have already engages us to provide, or enquired about. In such instances SRAM will only do so where we have received explicit consent from you to do and for each separate method of communication. You may opt out of receiving this information when we collect details or at any time by contacting us using the contact details below;
  • if required to do so by law and to the extent necessary for the proper operation of our systems, to protect us/our customers, or for the enforcement of any agreement between you and us;
  • to notify you of changes to our services; and
  • to help improve the services we provide to you.

Unless otherwise stated in this Privacy Notice, the legal basis for our use of your personal data will be that this information is required for one or more of the legitimate interests described above.

How will we protect your information?

We take appropriate security measures (including physical, electronic and procedural measures) to help protect the confidentiality, integrity and availability of your personal information from unauthorised access and disclosure.

Who would we disclose your information to?

We may disclose your information to:

  • Businesses that are legally part of the same group of companies within South River, or that become part of that group;
  • Our brokers, dealers, IT providers, services providers and agents in order to provide and maintain the provision of the services;
  • Our appointed auditors, accountants, lawyers and other professional advisers (e.g. compliance consultants), to the extent that they require access to the information in order to advise us;
  • Fraud prevention agencies and other organisations to allow us to undertake the checks set out below. We will supply details of such agencies on request;
  • The regulators, the Financial Conduct Authority, or any relevant regulatory authority where they are entitled to require disclosure;
  • Meet applicable law, the order of a Court or market rules and codes of practice applicable to the circumstances at the time;
  • Investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law;
  • Relevant tax, payments and customs authority, who may pass this on to tax authorities in other jurisdictions. The tax regulations require us to collect information about each investor’s tax residency;

We will not lend or sell your information to third parties.

Data retention

We are committed to only keeping your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this notice, and for as long as we are required or permitted to keep it by law.

We retain copies of our customer contracts in order to enable us to deal with any legal issues and the information provided to us for identification verification checks, financial crime and anti-money laundering checks (as required by law) for 5 years after termination or expiry of our contract with you. We retain details of complaints for 5 years from the date of receipt.

We shall keep records of the following for 5 years:

  • call recordings, electronic communications and minutes of face-to-face meetings;
  • suitability and appropriateness assessments;
  • periodic statements (for example, valuations); and
  • all orders and transactions in financial instruments on your behalf (including information about your identity).

South River retain copies of all records aforementioned for a maximum of 7 years.

Transferring information overseas

We may share your personal information with our service providers and this may involve transferring it to countries outside the European Economic Area (EEA) whose data protection laws may not be as extensive as those which apply to us. Where we do so, we will ensure that we do this in accordance with the Acts and take appropriate measures to ensure that the level of protection which applies to your personal information processed in these countries is similar to that which applies within the EEA. Such measures may include only transferring your data to jurisdictions in respect of which there is a European Commission adequacy decision or, where this is not the case, by using model clauses which have been approved by the European Commission.

We may transfer your personal information between businesses that are legally part of the South River group of companies for the purposes of providing our services to you as follows:

  • from our businesses based in the United Kingdom to our businesses based in Guernsey on the basis that the European Commission has given a formal decision that Guernsey provides an adequate level of data protection similar to that which applies in the United Kingdom and EEA.

Your rights

You have a key right to learn and have access to what personal information is held by South River and able to ask us for details on this.

When we receive such a request we will endeavour to provide you with these details without delay and at the latest within one month of receipt. We may extend the period of compliance by a further two months where requests are complex or numerous. In such instances {#acronym} will inform you within one month of the receipt of the request and explain why the extension is necessary.

When South River receives a subject access request we will provide a copy of the information held free of charge. South River may charge a reasonable fee to comply with requests for further copies of the same information. This does not mean that we will charge for all subsequent access requests rather that South River reserves the right to charge a fee based on the administrative cost of providing the information.

If after reviewing a request the Data Protection Officer believes a request is manifestly unfounded or excessive, particularly if it is repetitive, then South River may charge a ‘reasonable fee’ which will be decided on a case by case basis.  In certain circumstances South River may even refuse to respond to such requests.

You also have the following rights (unless exemptions apply), which can be exercised by contacting us using the details provided below.

The right:

  • To ask us not to process your personal data for marketing purposes;
  • To prevent any processing of personal data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual;
  • To request the rectification or completion of personal data which are inaccurate or incomplete;
  • To restrict or object to the processing of your personal data (from 25th May 2018 onwards);
  • To request its erasure under certain circumstances;
  • In certain circumstances, to receive your personal data, which you have provided to us, in a structured, commonly-used and machine-readable format and the right to transmit that data to another data controller without hindrance, or to have that personal data transmitted to another data controller, where technically feasible (from 25th May 2018 onwards);
  • To be informed about any use of your personal data to make automated decisions about you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; and
  • To lodge a complaint about the way in which your personal data is being used to your Data Protection Authority: The Information Commissioner’s Office (United Kingdom).

When you contact us to exercise any of the rights above, we may ask you to provide some additional information in order to verify your identity, such as your name, your address and proof of identity.

If you would like to lodge a complaint or exercise any of your rights set out above, you can contact us at:

E-mail: info@southriveram.com.

Post: United Kingdom: South River Asset Management Limited, Atlas House, 1 King Street, London, EC2V 8AU

Alternatively, if you would like to contact your Data Protection Authority, please use the contact details below.

United Kingdom: Information Commissioner’s Office

Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time.

The information on this site is not available for private investors and is restricted to Professional Investors.

South River Asset Management Ltd is registered in England and Wales (Number 04195976). South River Asset Management Ltd is authorised and regulated by the Financial Conduct Authority in the UK, with its registered office at 1 King Street, London, EC2V 8AU. The information on this website is directed only to eligible professional investors. Please satisfy yourself that you are eligible to make such investments before accessing this information. You must read the following information before proceeding, as it enables the legal and regulatory restrictions which apply to both the information contained and investment products referred to within this website. To enter this website your browser must have cookies enabled or you will not be aware of important regulatory information. The information on this website constitutes a financial promotion and has been issued and approved by South River Asset Management Ltd for the purpose of Section 21 of the Financial Services and Markets Act 2000  and does not, in any way, constitute investment legal or taxation advice. South River Asset Management Ltd’s details are set out in the FCA register and our FRN number is 197097. You hereby agree that any dispute arising from your use of this website or the information it contains, will be subject to the exclusive jurisdiction of the English Courts. This website is confidential, and no part of it may be reproduced, distributed or transmitted without the prior written permission of South River Asset Management Ltd. Investments may go up or down in value and you may lose some or all of the amount invested. Past performance is not necessarily a guide for the future. Returns from the structured products are at risk in the event of any of the institutions who provide securities for these products default on their financial obligations. Any decision to invest should be based on the information contained in the relevant term sheet or prospectus (and any supplements thereto) of the relevant product which includes information on certain risks associated with an investment.

This website does not disclose all the risks and other significant issues related to an investment in the securities. Prior to transacting potential investors should ensure that they fully understand the terms of the securities and any applicable risks. Neither this website nor any documents contained within it constitutes an offer or solicitation to sell in any jurisdiction in which an offer, solicitation, purchase or sale would be unlawful under the securities law of that jurisdiction. The material contained within is purely for information purposes and its accuracy cannot be guaranteed. By accessing this website you represent that you are permitted by the laws of your jurisdiction of residence to access this site and the information contained herein. This website is not intended for residents of the United States as we are not authorised to sell our products and services in the USA.

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