ABACAI LTD – PRIVACY NOTICE

This Privacy Notice sets out how Abacai collects and handles personal data about you, or someone on your behalf, interacts with us in respect of the services we offer, or when you use our website.

We take the privacy and security of your personal data very seriously and will only use your personal data as set out in this Privacy Notice or as we may otherwise inform you from time to time.

Any questions about the contents of this Privacy Notice or Abacai’s use of personal data should be sent to accounting@abacai.co.uk.

RESPONSIBILITY FOR PERSONAL DATA

This Privacy Notice is provided on behalf of Abacai.

References to “Abacai”, “we” and “us” are references to Abacai Ltd of 69 The Saddler Building, 24 Wharf Road, London, England, N1 7GQ.

When personal data is provided to us, Abacai will, in relation to some or all of the personal data, be acting as a “data controller”. The data controller determines how the personal data is used and for what purpose.

THE DATA WE COLLECT

Depending on the nature of our relationship with you, we will collect various types of personal information about you which may include all or some of the following:

  1. (a)  your identification information (which may include your name, ID card and passport numbers, nationality, place and date of birth, gender, photograph and/or IP address and personal information relating to claims, court cases and convictions, politically exposed person (PEP) status, personal information available in the public domain and such other information as may be necessary for Abacai to provide its services and to complete its client due diligence process and discharge its AML/CFT obligations);
  2. (b)  your tax status information (which may include your tax residency, tax ID and tax status);
  3. (c)  your contact information (which may include postal residential and business addresses, personal and business e-mail address and your home, business and mobile telephone numbers);
  4. (d)  your professional and employment information (which may include your level of education and professional qualifications, your employment, employer’s name and details of directorships and other offices which you may hold);
  5. (e)  financial information, sources of wealth and your assets (Which may include details of your assets, sources of wealth, shareholdings and your beneficial interest in assets, your bank details and your credit history); and

(f) IP address (we may collect your IP (Internet Protocol) address to help diagnose problems with our server, and to administer our Site. An IP address is a number that is assigned to your computer when you use the internet. This information does not contain any personally identifiable information about you. Your IP address is also used to help identify you during a particular session and to gather broad demographic data.)

WHERE WE OBTAIN PERSONAL DATA

We collect your personal data from the following sources:

  1. (a)  personal data which you give to us, including but not limited to:
    1. (i)  Such forms and documents as we may request that are completed in relation to the provision of our services;
    2. (ii)  Information gathered through client due diligence carried out as part of our compliance with regulatory requirements; or
    3. (iii)  Any personal data provided by way of correspondence with us by phone, e-mail or otherwise;
  2. (b)  personal information we receive from third party sources, such as:
    1. (i)  entities in which you or someone connected to you has an interest;
    2. (ii)  your legal and/or other professional advisors;
    3. (iii)  other financial institutions who hold and process your personal information; and
    4. (iv)  credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements; and
  3. (c)  personal information received in the course of dealing with advisors, regulators, official authorities and service providers by whom you are employed, engaged or for whom you act.

HOW WE USE PERSONAL DATA

Unless we inform you otherwise then we may hold and process your personal data on the following lawful grounds:

  1. (a)  the processing in necessary to comply with our legal obligations;
  2. (b)  the processing is necessary for our legitimate interests or the legitimate interests of a third party to whom your personal data is disclosed, provided your interests and fundamental rights do not override those interests;
  3. (c)  the processing is necessary for the performance of a contract to which you are a party, or to take such steps, at your request, with a view to entering you into such a contract;
  4. (d)  the processing is necessary in the public interest;
  5. (e)  the processing is necessary to exercise, bring or defend a legal claim; and
  6. (f)  in exceptional circumstances, where we have obtained your consent to processing your personal data for a specific purpose.

Your personal data may be processed for the following purposes:

  1. (a)  facilitating the performance of our services including the administration of our business, clients and/or our service providers;
  2. (b)  communicating with you as necessary in connection with our services;
  3. (c)  monitoring and recording, including telephone and electronic communications and transactions, for:
    1. (i)  quality, business analysis, training and related purposes in order to improve service delivery; and
    2. (ii)  investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act);
  4. (d)  disclosing your personal information to any bank or financial institution in providing our services;
  5. (e)  to enforce or defend our legal and contractual rights or those of third party service providers;
  6. (f)  to comply with legal or regulatory obligations imposed on us;
  7. (g)  collecting, processing, transferring and storing customer due diligence, source of funds information and verification data under applicable anti-money laundering and terrorist financing laws and regulations; and
  8. (h)  liaising with or reporting to any regulatory authority (including tax authorities) with whom we ae either required to cooperate or report to, or with whom we decide or deem it is appropriate to cooperate.

SHARING PERSONAL DATA

We may share your personal data with third party service providers including, but not limited to:

  1. (a)  our insurers, banks, auditors, and legal professionals to facilitate our business and the services which we provide; and
  2. (b)  tax authorities to comply with applicable laws and regulations or where requested by such tax authority.

There may also be circumstances where Abacai is obliged by law to disclose personal data, including to law enforcement agencies and applicable regulators.

The third party service providers to whom your personal information may be transferred are based in the United Kingdom.

RETENTION OF PERSONAL DATA

Your personal information will be retained for as long as required:

  1. (a)  for the purposes for which the personal information was collected;
  2. (b)  in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations; and/or

(c) as required by data protections laws and any other applicable laws or regulatory requirements.

INACCURATE OR AMENDED INFORMATION

Please let us know as soon as possible if any of your personal information changes (including your correspondence details). Failure to provide accurate information or to update information when it changes may have an impact upon our ability to provide services.

INDIVIDUAL RIGHTS

Individuals whose personal data is processed by us have certain legal rights in respect of the information. These include:

  1. (a)  the right to request access to personal data;
  2. (b)  the right to obtain information about the use of personal data;
  3. (c)  the right to require rectification (correction) of errors in personal data without undue delay;
  4. (d)  the right to have personal data erased without undue delay in certain circumstances;
  5. (e)  the right to restrict the processing of personal data in certain situations; and
  6. (f)  the right to receive personal data in a structured, commonly used and machine-readable format and transmit that data to a third party.

If an individual wishes to exercise any of these rights and Abacai has transferred that person’s data to a third party, the Company will communicate that request to the relevant third party unless it would be impossible or involve disproportionate effort for Abacai to do so.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at accounting@abacai.co.uk.

RIGHT TO WITHDRAW CONSENT

In the limited circumstances where an individual has provided their consent to the collection, processing and transfer of personal information for a specific purpose, that individual has the right to withdraw consent for that specific processing at any time.

To withdraw consent, please contact accounting@abacai.co.uk. Once we have received notification that the individual has withdrawn consent, we will no longer process information for that specific purpose or purposes, unless we have another legitimate basis for doing so in law.

UPDATES

This Privacy Notice is under regular review and may be updated periodically and without prior notice to reflect changes in Abacai’s personal information practices.

ACKNOWLEDGEMENT OF PRIVACY NOTICE

By using our services and/or our website you acknowledge having received and read this Privacy Notice. Your continued use of our services and/or website following any changes to this Privacy Notice means you continue to acknowledge and remain happy with its content and our use of your personal data for the purposes and manner set out therein.

CONCERNS OR QUERIES

Any questions about the contents of this Privacy Notice or Abacai’s use of personal data should be sent to accounting@abacai.co.uk.

Issues or concerns individuals have regarding their personal data can also be brought to the attention of the applicable supervisory authority in your country, where you live or work, or the location where the data protection issue arose.

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© Abacai 2020. Company number: 11674768. Registered address: 69 The Saddler Building, 24 Wharf Road, London, N1 7GQ. Terms & Conditions | Privacy Policy