Privacy Notice

Privacy Notice

"We", "our" or "us" means Winterflood Securities Limited and its subsidiaries, each of which are part of the Marex Group. For the purposes of data protection laws, we are the Data Controller in respect of your personal data. We collect and use your personal data as described below and are responsible for ensuring that we use your personal data in compliance with the applicable data protection laws.

 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 at DPO@marex.com in the first instance. Alternatively, our Data Protection Officer can be contacted using the details set out in the “Contact us” section below. 

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 

We use the information about you that you provide to us, including the information that you provide when filling in fields in a contract (or related application) or when registering to use sections of our website(s) (such as your name, address, e-mail address, phone number, job title, your preferences for receiving email communications from us) and any other information or updates to your information that you provide to us when corresponding with us (by phone, e-mail or otherwise).

Information we collect or generate about you 

When you submit information to us, we may use this information to interact with and provide services to you or your employer and to carry out our obligations arising under or in connection with a contract. 

We may also receive information from other sources for the above purposes. 

Our websites use cookies and similar tools to automatically gather certain statistical information such as the number and frequency of visitors and their IP addresses. This information is used as aggregated statistical information about users, providing usage by IP address. We do not identify individual users from this type of data and it does not involve the processing of personal data about you. By using our website, you agree that we can use cookies. Visit www.allaboutcookies.org to learn about how you can manage cookies on your device. 

We may record, monitor and retain any and all communications (which may include the recording, monitoring and retention by a third party appointed by us), including facsimile, email, telephone conversations and other electronic communications with you, for the purposes of providing services to you or to your employer and/or otherwise in order to comply with applicable law. 

We generate data for internal analysis and research. 

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:

• to provide you with services you request or services requested by your employer or other services reasonably ancillary thereto, and to carry out our obligations arising under or in connection with a contract;
• to administer and maintain user access to our services and/or websites;
• to communicate with you in relation to the services we provide to you or to your employer;
• to comply with our obligations under applicable laws;
• to monitor and improve our websites and services; and/or
• for internal analysis and research. 

Legal basis for processing your personal data 

We process your personal data pursuant to the following legal bases: 

i. where necessary to comply with a legal obligation (for example anti-money laundering, know-your-customer and counter-terrorist financing checks and the prevention and detection of fraud and other financial crime);
ii. where necessary for the performance of a contract with you or to take steps at your request to enter into a contract.
iii. where necessary for the purpose of our legitimate business interests which includes:

• the provision of services to you or your employer, the sending and receiving of communications in relation thereto and/or carrying out obligations arising in connection with a contract;
• contacting you with email updates in relation to services;
• generating data for internal analysis and research (including monitoring and improving our websites and services);
• marketing Winterflood’s products and services, including event invitations and the sending of branded merchandise; and
• keeping a record of what individuals are interested in hearing about from us; 
  or 

iv. where you have separately consented for us to use your personal data to send you specific email updates and communications (by opting-in to such email updates/communications). 

You have the right to object to processing under (ii) by contacting us using the details set out in the “Contact us” section below, and you may cancel your subscription under (iii), at any time by using the ‘unsubscribe’ link within the communications you receive from us or by emailing us at DPO@marex.com and requesting the same. 

Please note that any instructions to unsubscribe from communications will not affect any processing pursuant to (i) in relation to 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 ours, as the same terms are defined in the Companies Act 2006) and to third party service providers in the circumstances described below:

• in relation to our legitimate business interests (as above);
• to facilitate the administration and maintenance of user access to our services and/or websites;
• to conduct and/or improve our business development activities; and
• to ensure the safety and security of our data (and that of third parties, including data vendors and other data sources). 

We will take steps to ensure that the personal data is accessed only by persons that have a need to do so and for the purposes described in this Notice. We may also share your personal data with third parties:

• if we sell any of our business or assets, we may disclose your personal data to the prospective buyer for due diligence purposes;
• if we are acquired by a third party, personal data held by us about you will be disclosed to the third party buyer;
• to third party agents or contractors (for example, the providers of our electronic data storage services) for the purposes of providing services to us; and
• with your consent, to our affiliates who may wish to offer you products and services which may be of interest to you. 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. 

Transfer of personal data outside the United Kingdom 

We may transfer your personal data abroad in connection with the provision of services to you. This may include countries outside the UK and/or the European Economic Area. 

We require everyone we work with to keep your personal data confidential and secure, including implementing appropriate safeguards for cross-border transfers. 

How long we keep your personal data 

We only keep your personal data for as long as it is required for the: 

• purposes described above;
• to meet our legal or regulatory obligations;
• for the exercise and/or defence of any legal claims. 

Your rights 

You have a number of rights in relation to the personal data that we hold about you. 

These rights include:

the right to object to our processing of your personal data where we process your personal data pursuant to our legitimate business interests. Please note that there may be circumstances where you object to our processing of your personal data but we are legally entitled to refuse that request;

• the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
• the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
• in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
• the right to request that we rectify your personal data if it is inaccurate or incomplete;
• the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
• the right to request that we restrict our processing of your personal data in certain circumstances. Please note that there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request;
• the right to object to the processing of your personal data for direct marketing purposes; and
• the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us. 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 Information Commissioner, the data protection regulator, or by visiting 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. 

Contact us 

Please contact us if you have any questions about this Notice or personal data that we may hold about you, by email at DPO@marex.com