Privacy Policy
Introduction
This website is operated by Baron Securities Limited. Baron Securities is a private limited company with registered number 16628167, whose registered office is at Berkeley Square House, Mayfair, London W1J 6BD. Baron Securities Limited is authorised and regulated by the Financial Conduct Authority (FRN: 1048573). Baron Securities Limited is referred to as “Baron”, “we”, “us” and “our” in this Privacy Policy.
We respect your privacy and are committed to protecting your personal data. This Privacy Policy describes how we process your personal data when you visit our website (regardless of where you visit it from) and your privacy rights. It also describes how we use cookies. “Personal data” is any data that can be used to identify you or that Baron can link to you and which Baron has in its possession or control.
This Privacy Policy aims to give you information on how we collect and process your personal data through your use of our website. Baron is the data controller in respect of your personal data, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
Personal information we may collect
We may collect and process data from the below listed information with respect to persons connected with the investment services we provide. As well as collecting personal data from our clients, we may also process personal data about relevant persons connected with the investment services.
We may collect this information from a number of sources, including directly from you, via our affiliates, delegates, partners, service providers, professional advisors, or third-party entities with whom we undertake due diligence checks upon you. In doing so, we will ensure that the information we collect is proportionate to our stated purposes.
Where relevant, we may collect and process personal information related to persons related to you. In such circumstances, it is your responsibility to ensure you have permission from that third-party for us to collect their information and you remain responsible for ensuring that the third-party understands how their information is being used.
Individuals connected with our investment services
We may collect and process your: personal details, including your name, address, email and telephone/fax numbers, date of birth, nationality; employment details, including your employers name, your position or title and your corporate contact details; information on your financial circumstances, including your profession, income, assets and liabilities, as well as sensitive and/or criminal data. We do this where we believe that there is a genuine likelihood that you may be interested in a service or product that we are offering or because you have expressed an interest in a similar offering in the past.
Individuals connected with our partners and service providers
We may collect and process your: contact information, including your name, address, position, email and telephone/fax numbers; financial details, including relevant details for invoicing and billing; and KYC documentation, if and where required under relevant Anti-Money Laundering or Counter Terrorism Financing (“AML/CTF”) legislation.
Our legal bases and purpose for holding your personal information
Unless specifically stated otherwise in a Privacy Notice provided to you, we use your personal information in the following ways and based upon the following lawful bases:
Individuals connected with our investment services
- To achieve our legitimate interests. In doing so, we ensure that:
- Your rights and interests are considered and protected and there is a minimal privacy impact upon you;
- We can demonstrate that we use your data in a proportionate manner, and you would not likely be surprised or likely to object to our usage;
- We can lawfully disclose personal data to third parties where we can demonstrate that this disclosure is justified;
- To comply with our legal or regulatory obligations. For instance, under the UK Financial Conduct Authority Conduct of Business rules and/or relevant AML/CTF legislation;
- Based upon reasons of substantial public interest; and
- Where your personal information is public information by your own actions.
Individuals connected with our partners and service providers
- To fulfil our contractual obligations to you to facilitate the provision of goods or services. This includes where you have asked us to do something before entering into a contract, for example to provide a quote;
- To comply with our legal or regulatory obligations;
- Based upon reasons of substantial public interest; and
- Where your personal information is public information by your own actions.
Individuals connected with our website
- To achieve our legitimate interests. This may include electronic communications between us; the provision of investment information to you; details in order for us to manage and improve our website; for us obtaining and recording details relating to your visit behavior on our website;
- To comply with our legal or regulatory obligations;
- Based upon reasons of substantial public interest; and
- Where your personal information is public information by your own actions.
When we may disclose your personal information
We may disclose your personal information with the following category of recipients, and based upon the legal bases and purposes set out above:
- Service providers (execution and settlement brokers, banks, corporate service providers).
- Our partners and service providers (IT, accountants, lawyers, insurance).
- Credit reference agencies, other third parties conducting background checks in the context of employment, or client, counterparty, or due diligence.
- Any law enforcement, court, regulator or other government authority for us to comply with a legal obligation laid down by UK or EU law. This includes the provision of information relating to any affiliate of the Firm.
- A prospective buyer of our business, including where we intend to sell part of our business or merge with another third party.
Your rights as a data subject
You have the right to:
- The right to be informed;
- The right of access;
- The right to rectification;
- The right to erasure;
- The right to restrict processing;
- The right to data portability;
- The right to object; and
- Rights in relation to automated decision making and profiling.
Further details of your rights can be found at the ICO website, however, please note that your rights are subject to our overarching legal responsibilities:
https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/
International transfers
We may share your personal data and potentially to service providers located outside of the UK and/or EU.
Whenever we transfer your personal data out of the UK and/or EU, we ensure a similar degree of protection is afforded to it by ensuring that we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data or, if applicable, we will ensure an alternative lawful transfer mechanism is in place, as required by applicable data protection laws.
How long we retain your personal information
We reserve the right to retain your personal information for as long as we reasonably believe it to be necessary in order to facilitate our legitimate interests, in order for us to comply with our legal or regulatory obligations, where based upon reasons of substantial public interest, or where your personal information remains public information by your own actions. For further information, please contact the relevant data controller.
Our responsibilities when we make changes to our Privacy Policy
We may make changes to our Privacy Policy at any time and may do so without expressly notifying you of these changes. However, should the legal bases or purpose for processing your personal information changes then we shall expressly notify you.
Our data controllers and how to contact us
Questions or individual data requests relating to this Policy should be addressed to the relevant data controller. For the purpose of the data protection legislation, the relevant data controllers are:
| Data controller | Responsible for |
|---|---|
|
Firm name: Baron Securities Ltd Registered number: 16628167 Address: Berkeley Square House, Berkeley Square, London W1J 6BD |
All investment and business administration activities related to our regulated activities. |
Our Cookie Policy
A cookie is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. We only use cookies that are required for the essential operation of our website. These cookies are typically deleted from your device once the browsing session is terminated.
You can choose to block cookies that we may deliver to your device through settings on your web-browser; however, in doing so you may not be able to access or utilise all aspects of our website.
How to complain
If you have any concerns about our use of your personal information, you can make a data protection complaint to us:
- Email: info@baronsec.com
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO. Further information is available on the ICO’s website: ico.org.uk/make-a-complaint.