"We", "our" or "us" means Winterflood Securities Limited and its subsidiaries. For the purposes of data protection law, we are a data controller in respect of your personal data. We collect and use your personal data as described below. We are responsible for ensuring that we use your personal data in compliance with data protection law.
If you have any questions about this notice, about how we process personal data or about your rights over your personal data, you can contact us via email to email@example.com in the first instance. Alternatively, our Data Protection Officer can be contacted using the details set out in the “Contact us” section below.
This notice applies to personal data we receive or otherwise create in connection with the provision of services to retail clients, including any associated services provided via our website(s) at:
It is important that you take the time to read this notice so that you understand how we will use your personal data and your rights in relation to your personal data.
Personal data that we collect about you
We will collect and use the following information about you:
Information you give us
Information we collect or generate about you
If we do not receive this information we may not be able to provide certain services to you.
How we use your personal data
Your personal data may be processed by us for the following purposes:
Legal basis for processing your personal data
We process your personal data pursuant to the following legal bases:
(i) where necessary for the performance of a contract with you or necessary for the performance of a contract concluded in the interests of the data subject (including any actions required in accordance with/pursuant to the WBS Retail Client Terms and Conditions);
(ii) where necessary to comply with a legal obligation (including processing for the purposes of complying with the FCA Handbook; the rules and guidance of HMRC; JMSLG guidance in respect of AML, KYC, CTF, PEP and sanctions checks; the prevention and detection of fraud and other financial crime; and/or requests under the Companies Act 2006, together with any laws, rules and regulations referenced in or analogous to the above and/or amending, supplementing or superseding the same (whether in the UK or EU)); or
(iii) where necessary for the purpose of our legitimate business interests which includes: o the provision of services to you, the sending and receipt of communications in relation thereto and/or carrying out obligations arising in connection with a contract with you;
o compliance with legal and regulatory obligations (including applicable laws, rules and regulations outside of the EU and requests or requirements of competent authorities);
o contacting you with email updates in relation to services;
o generating data for internal analysis and research (including monitoring and improving our services and websites); and
o keeping a record of what individuals are interested in hearing about from us.
You have the right to object to processing under (iii) at any time by using the ‘unsubscribe’ link within communications you receive from us (where applicable) or by emailing us at firstname.lastname@example.org and requesting the same. If you object to such processing, please note that we may no longer be able to provide certain services to you, but we will notify you if this is the case at the time. You should also note that any such objections will not affect any processing pursuant to (i) or (ii) above in relation to the performance of a contract and/or compliance with a legal obligation.
Sharing your personal data
We may disclose your personal data to our affiliates (being any subsidiary undertaking or parent undertaking, or a subsidiary of any parent undertaking of Winterflood Securities Limited, as the same terms are defined in the Companies Act 2006) and to third parties in the circumstances described below:
We will take steps to ensure that the personal data is accessed only by persons that have a need to do so for the purposes described in this notice.
We may also share your personal data with third parties:
These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this notice.
We may also share your personal data with third parties (including, without limitation, regulatory, governmental, judicial and other bodies or authorities of competent jurisdiction) to the extent required by applicable law, for example if we are under a duty to disclose your personal data in order to comply with any legal or regulatory obligation, and to establish, exercise or defend our legal rights.
We do not generally process personal data belonging to children, however we may do so, at your instruction, in relation to the application for, and provision of, a Junior ISA. We will process any such data in accordance with this notice.
Transfer of personal data outside the European Economic Area
The information you provide to us will be transferred to and stored on our secure servers in the European Economic Area (“EEA”). However, from time to time, your personal data may be transferred to, stored in, or accessed from a destination outside the EEA. It may also be processed by staff operating outside of the EEA who work for us or an affiliate or for one of our suppliers.
Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance:
In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.
You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contact us” section below.
How long we keep your personal data
How long we hold your personal data for will vary. The retention period will be determined by various criteria including:
You have a number of rights in relation to the personal data that we hold about you. These rights include:
You can exercise your rights by contacting us using the details set out in the “Contact us” section below. You can find out more information about your rights by contacting the data protection regulator, the Information Commissioner, or by searching their website at https://ico.org.uk/.
Changes to this Privacy Notice
We keep this notice under regular review. Any changes we make to this notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this notice.
Winterflood Securities Limited is a company registered in England and Wales. Our registered address is at The Atrium Building, Cannon Bridge House, 25 Dowgate Hill, London, EC4R 2GA and our company registration number is 02242204.
Please contact us if you have any questions about this notice or personal data that we may hold about you:
You can write to us at: Data Protection Team, Winterflood Securities Limited, The Atrium Building, Cannon Bridge House, 25 Dowgate Hill, London, EC4R 2GA.
You can also contact our Data Protection Officer using the following details: