This Privacy Notice explains how FTI Treasury collect, use and disclose your personal data, and your rights in relation to the personal data it holds.
FTI Treasury is the data controller of your personal data and is subject to the EU General Data Protection Regulation 2016/679 (the “GDPR”).
You can reach us at the following email address: email@example.com or by phone: +353 1 6360000.
We keep our privacy notice under regular review. This version was last updated on 14th December 2020. If material changes are made to the Privacy Notice, for instance affecting how we would like to use Your Data, we will provide a more prominent notice (including, for certain services, email notification of Privacy Notice changes).
HOW WE COLLECT YOUR DATA
We collect your personal data in a number of ways, for example:
- From the information you provide to us when you meet us
- From information about you provided to us by your company or an intermediary
- When you communicate with us by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication
- You are engaging with us as a potential customer or prospect
- When you complete client on-boarding or and provide client kyc information
- From your agents, advisers, intermediaries, and client banking counterparties
- When you visit our website, register for a training course or request more information, you may be asked to provide some personal data such as your name, telephone number and e-mail address
- From publicly available sources or from third parties.
THE CATEGORIES OF PERSONAL DATA WE COLLECT
We collect the following categories of personal data about you:
- Your name and contact information such as your business address, email address and telephone number (where relevant)
- We log your Internet Protocol (IP) address in order to receive and send information from and to you over the internet
- For clients and to meet kyc and anti-money laundering obligations we may collect biographical information which may confirm your identity including your date of birth, tax identification number and your passport number or national identity card details, country of domicile and/or your nationality and proof of address.
HOW WE USE THAT PERSONAL DATA
- Performance of a contract with you
We process your personal data because it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract. In this respect, we use your personal data for the following:
- To prepare a proposal for you regarding the services you offer
- To provide you with the services as set out in a Service Agreement or Letter of Engagement
- For any purposes for which you provide us with personal data.
We may send you marketing about services we provide, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you.
We may communicate this to you in a number of ways including by post, telephone, email or other digital channels. If you object to receiving marketing from us at any time, please contact us: By email: firstname.lastname@example.org.
- Legal obligations
We also process your personal data for our compliance with a legal or regulatory obligation which we are under. In this respect, we will use your personal data for the following:
- To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws
- As required by tax authorities or any competent court or legal authority
WILL FTI TREASURY SHARE MY PERSONAL DATA WITH ANYONE ELSE?
Other than as set out below, we hold Personal Data on FTI Treasury’s own secure servers in Ireland.
In certain limited circumstances, however, it may be necessary for us to share Your Data with the recipients set out below.
- Where we are required to do so for legal reasons
We will share personal information with companies, organisations or individuals outside FTI Treasury if we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process or enforceable governmental request.
- enforce applicable Terms of Service, including investigation of potential violations.
- detect, prevent or otherwise address fraud, security or technical issues.
- protect against harm to the rights, property or safety of FTI Treasury, our users or the public, as required or permitted by law.
- Where it is necessary in connection with legal proceedings
We may share Your Data with certain third parties where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise our legal rights.
- If we sell our business, go out of business or merge with another company
We have put in place appropriate security measures to prevent Your Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to Your Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process Your Data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- How long will FTI Treasury keep my information?
- Unless otherwise indicated in Section 2 below, we will hold Your Data on our systems for as long as is necessary for the relevant activity for which it was collected. After this time we may retain Your Data for a further period of a maximum of 10 years in order to comply with legal record keeping requirements. In limited circumstances, we may keep Your Data for longer than this if we have identified a legal, regulatory or technical reasons why this is necessary.
- How to access, correct or delete Your Data
You can request access to all the Personal Data that FTI Treasury has collected from you directly or indirectly, by contacting us using the contact details set out above. You can also request that we correct or delete Your Data in the same way.
For EU Residents, for further information on your rights to access, correct or delete Your Data under the GDPR.
YOUR PRIVACY RIGHTS
Under the GDPR (or equivalent local legislation that implements or adopts the GDPR), data subjects have certain rights with respect to their Personal Data, including those set forth below.
- right to request access – you may obtain confirmation from us as to whether or not Your Data is being processed and, where that is the case, access to Your Data
- right to rectification – you have the right to obtain rectification of inaccurate Personal Data we hold concerning you
- right to erasure – you have the right to obtain the erasure of Your Data without undue delay in certain circumstances
- right to restriction of processing or to object to processing – you may require us to restrict the processing we carry out on Your Data in certain circumstances or to object to us processing Your Data
- right to data portability – you have the right to receive Your Data in a structured, commonly used and machine-readable format
- right to withdraw consent – where you have provided your consent to us processing Your Data, you have the right to withdraw your consent at any time. This can be done by emailing email@example.com at any time
- right to lodge a complaint – you may lodge a complaint with the supervisory authority in the EU Member State where you are resident or where you work. For further information on your rights, please see the supervisory authority of your country or EU Member State. The relevant supervisory authorities for Ireland are set out below and the website contains the relevant contact details:
You can find out more about your rights at https://www.dataprotection.ie
YOUR DUTY TO INFORM US OF CHANGES
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
YOUR CHOICES AND OPT-OUTS
You can opt out of receiving marketing emails from us at any time. You can opt out of our marketing emails by clicking the ‘unsubscribe’ link at the bottom of our marketing messages.
Also, all opt out requests can be made by emailing us at firstname.lastname@example.org
Please note that it may take up to 3 days to remove you contact information from our marketing communications lists, so you may receive correspondence from us for a short time after you make a request.