PRIVACY POLICY
PRIVACY POLICY
Who we are?
The legal name of the company who holds your personal information – known as the ‘legal entity’ is Smart Volatility Mitigation Inc.
Contacting us regarding data privacy
If you have any queries regarding the topics set out in this privacy notice you can contact us on: [email protected]
Your Legal Protection
Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. The law says we must have one or more of these reasons; carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it.
Smart Volatility Mitigation Inc. does not sell your information to any third parties.
An individual has certain rights regarding his or her personal information, subject to local law.
These include the right to:
- request a copy of the personal information we hold about them;
- request that we supply them (or a nominated third party) with an electronic copy of the personal information that they or you have provided us with;
- inform us of a correction to their personal information;
- exercise their right to restrict our use of their personal information;
- exercise their right to erase their personal information; or
- object to particular ways in which we are using their personal information.
An individual’s ability to exercise these rights will depend on several factors and in some instances, we will not be able to comply with this request e.g. because we have legitimate grounds for not doing so or where the right doesn’t apply to the particular data we hold on that individual. If you or your business partners would like more information on these rights, or wish to exercise them, or to update or correct your information if it changes, or if the personal data we hold about you or your business partners is inaccurate, please contact us on the details above.
Information Gathered
Smart Volatility Mitigation Inc. collects information about you from different places including:
- directly from you
from publicly available sources - when we generate it ourselves
- from other organizations, such as credit reference agencies or passport/ID/Proof of Address verification companies
We’ll only collect your information in line with relevant regulations and law and this may relate to any services you apply for, currently hold or have held in the past.
We will also hold information we collect about you from other sources, this will include:
- the way you are using our services;
- your interactions with us, for example, through our website or emails;
- our own records about any other accounts (including personal accounts) or services you, or your business partners, have with us or other providers;
- where we think it is necessary, our background checks about your shareholders (including beneficial owners), names of suppliers and companies you use or may have contractual or other agreements with, and other related individuals;
- information from credit reference agencies and fraud prevention agencies;
publicly available information about your business which is available online or otherwise; - criminal record checks and information;
employers;
joint account holders, other Directors, Partners, signatories or employees in your business; - people appointed to act on your behalf;
- credit reference agencies (who may check the information against other databases – public or private – to which they have access);
- fraud prevention agencies; and
- publicly available sources, such as media stories
You’re responsible for making sure you give us accurate and up to date information. If you do not provide personal data that we tell you is mandatory, it may mean that we are unable to provide you with the services and/or perform all of our obligations under our agreement with you. If you provide information for another person on your account, you’ll need to tell them how to find the Privacy Notice and make sure they agree to us using their information for the purposes set out in it.
How we use your information
We must have a legal basis to process your personal data. In most cases, the legal basis will be one of the following:
- For the provision of all our services
- For the purpose of submitting regulatory applications to the relevant regulatory body
- To allow us to comply with our legal obligations, for example, obtaining proof of identity to enable us to meet anti-money laundering obligations
What do we use your personal data for?
To provide, manage, improve and personalize our services to you.
Our basis for doing so:
- To perform our duties under our contract with you
- The law requires
- It is in our Legitimate Interest to ensure your account is well managed and you are provided with high a level of service
For the purpose of submitting regulatory applications to the relevant regulatory body:
- It is in our Legitimate Interest to provide you with information about our products and services that may be of interest
- The law requires
To perform our duties under our contract - with you
We have your consent to do so - To perform our duties under our contract with you
- The law requires
- It is in our Legitimate interest to detect, prevent and investigate fraud, money laundering and other crimes and to verify your identity in order to protect our business
- We have your consent to do so
Our basis for doing so:
- The law requires
- It is in our Legitimate Interest to detect, prevent and investigate fraud, money laundering and other crimes and to verify your identity to protect our business
- It is in the Substantial Public interest • The law requires
- It is in our Legitimate Interest to detect, prevent and investigate fraud, money laundering and other crimes and to verify your identity to protect our business
- It is in the Substantial Public Interest
- To conduct Anti-Money Laundering, Know Your Customer, Due Diligence and other Security checks on your clients or employees
What do we use your sensitive personal data for?
For provision of our services such as regulatory applications
Our Anti-Money Laundering, Know Your Customer, Due Diligence and other Security checks may reveal details of criminal convictions or offenses committed by your clients or employees
To comply with regulatory and legal obligations
The law to which you are subject to requires us to cooperate with regulators and law enforcement bodies.
Who can we share your information with?
- It is in our Legitimate interest to protect our business
- It is in the Substantial Public Interest
We may share your information with other entities such as regulators, banks, electronic verification companies, credit reference, DBS and fraud prevention agencies.
How long we’ll keep your information
We’ll keep your information for as long as you have a relationship with us. After the relationship ends, we’ll keep it for a minimum of 5 years or longer where we may need it for our legitimate purposes e.g. responding to requests from regulators.
Changes to the privacy notice
A copy of this privacy notice can be requested from us using the contact details set out above. We may modify or update this privacy notice from time to time.
Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).