Privacy Policy
Sterling Assets will collect the company’s personal data. This privacy notice intends to show your company how their personal data is processed, for what purposes this will be done and what rights your company has in relation to the personal data that will be collected and used. Personal data is at all times processed in order for Sterling Assets to fulfil its legal obligations. Sterling Assets is committed to ensuring that your privacy is protected at all times. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement. We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. This policy is effective from 22 February 2021. Personal data Sterling Assets complies with its GDPR obligations and ensures that personal data shall be processed lawfully and in a transparent manner in relation to your company; that the personal data shall be collected and processed for the purposes stated; that the personal data shall be accurate and at all times kept up to date; that the personal data shall be kept for no longer than is necessary for the purposes for which it is collected; that the personal data shall be adequately securitised and be protected against loss, unauthorised access or processing, and destruction or damage. Your Company’s personal data will be treated as strictly confidential and will be shared only with Sterling Assets compliance department. Your personal data will only be shared with third parties if consent to do so has been given. Data retention For audit trail purposes, Sterling Assets shall hold personal data for as long as required in order to fulfil our contractual and statutory duties. It should be noted that our business relationship is a contract of continuing obligation that may last for a number of years. This will enable us to comply with the record-keeping obligations under the Money Laundering Regulations 2017. Your Company’s personal data rights Your Company will have the following rights with respect to their personal data:
* The right to access personal data * The right to request that personal data regarding them be corrected if it is found to be inaccurate .
* The right to request that their personal data be erased where it is no longer necessary .
* The right to request that processing is stopped at any time, where relevant .
* The right to restrict processing where there is a dispute in relation to the accuracy or processing of personal data.
* The right to request that Sterling Assets Capital Markets International
Limited provide your Company with their personal data and where possible, transmit that data to another data controller. [applies only where the processing is for the performance of a contract with your Company and the data controller processes the data by automated means].
* The right to object to the processing of personal data [only applies where processing is based on legitimate interest] .
* The right not to be subject to a decision which is based solely on automated processing, including profiling which produces legal effects concerning them or similarly significant affects them The type of data collected and purpose for collection The type of data we collect along with the purpose for collection is listed below:
Personal data type: Purpose:
Personal information such as gender, name, date of birth and address To meet our anti-money laundering (AML) and other regulatory obligations in relation to Know Your Client (KYC) and client due diligence. To verify your identity using our verification processes.
Contact information (email address and phone number) In order to send you correspondence in relation to the services provided and to fulfil our regulatory and compliance obligations
Employment information, financial information, relevant education and trading experience In order to comply with KYC obligations and in order to meet our regulatory obligations relating to assessing the appropriateness of our products and services
Ethnicity, citizenship and social security numbers or national identity and passport numbers In order to comply with KYC and regulatory trade reporting and other AML obligations
Proof of photo ID, address verification In order to comply with KYC and regulatory trade reporting and other AML obligations
Unique device number (IP address) and device information including version of web browser you use When you visit our website, navigate through the pages or fill in any forms, we may collect your unique device number or IP address in order to set up your profile.
Financial sanctions and credit header information In order to perform our electronic AML screening checks and to comply with other fraud detection policies. This may generate further information on your credit history, criminal convictions or political interests leading to us making decisions based on the results of these checks
Lawful basis for processing
The following state the lawful bases for processing.
* Processing is necessary for the performance of a contract with your Company or to take steps to enter into a contract to conduct regulated activities.
* Processing is necessary for compliance with a legal obligation; Who else may have access to your Personal data? Sterling Assets may need to share personal data with third parties as may be required by law, or in order to fulfil contractual obligations.
Where your personal data is shared with third parties, we will ensure that equivalent safeguards are offered in order to protect your personal data. International transfers of Personal Data Transfers of personal data to countries outside of the EEA will be deemed unlawful unless the recipients of personal data in non-EEA countries offer an equivalent level of data protection to that of EEA countries. Use of cookies A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. Contact Details In order to exercise all rights, queries and complaints please contact support@sterlingassets.org
