Privacy Notice
1. Introduction
2. Who this Privacy Notice applies to?
3. How we collect information
4. The types of personal data we collect
5. How we use your personal data and the legal basis for using that personal data
6. Information we disclose
7. Protecting your information
8. How long will we keep your personal data?
9. Your rights over your personal data
10. Contact us
1. Introduction
Redburn Atlantic is a trading name of Redburn (Europe) Limited and its two subsidiaries, Redburn (USA) LLC and Redburn (France) SA. Each are members of the Rothschild & Co Group ("R&Co.") and each are data controllers for the personal data they collect and hold about you.
We take the privacy and security of your personal data seriously. For the purposes of regulatory disclosure, Redburn Atlantic and its associated entities are committed to protecting and respecting your personal data. We take a proactive approach to the processing of personal data and ensure that all necessary steps are taken to protect the privacy of our users throughout their visiting experience.
If you require any further information, or wish to contact us about how we collect and store your data, our contact details are:
Data Protection Officer
Redburn Atlantic
10 Aldermanbury
London
EC2V 7RF
+44 20 7000 2020
2. Who this Privacy Notice applies to?
This privacy notice explains how we will use the personal data of anyone who:
- Visit the Redburn Atlantic website (redburnatlantic.com)
- Interacts with Redburn Atlantic via the telephone, through e-mail, instant messaging or in person
- Purchases products or services from Redburn Atlantic
3. How we collect information
We receive your personal data through:
- Interaction with you via the telephone, through e-mail, instant messaging or in person
- Registering on the Websites
- Contacting us to obtain information relating to us or our services
- Account applications or other forms that you complete
- Interacting with our websites
- Transactions in your accounts or on your behalf
- Trading tools or other information tools we may make available to you
- Third parties with whom we deal, such as consumer-reporting agencies, to verify information we receive from you and your credit worthiness
4. The types of personal data we collect
We may process the following information about you:
| You as an individual | Full name Date of birth Nationality Passport details National Insurance number or Social Security number Email address Work address Home address Phone number Job title Authentication data Background checks e.g. credit reference, KYC checks Employment information |
| Your financial details | Account applications including signature Bank sort code Bank account number Financial transactions and trading activity |
| Other information | Browser type, versions, plug-ins and operating systems Device identifiers (e.g. IP address) Details of services you have acquired Marketing preferences |
5. How we use your personal data and the legal basis for using that personal data
| Performance of a contract with you | |
| Fulfil the contract of service that you enter into with us (e.g. the use of our products and services) |
We may use your personal data to:
|
| Enable our business and pursue our legitimate interests or those of a third party | |
| Research | We may use personal data to form part of our research activities |
| Corporate access events | We may process your personal data to invite you to corporate access events that you may be interested in presenting at and/or attending |
| Corporate access events | We may process your personal data to invite you to corporate access events that you may be interested in presenting at and/or attending |
| Service improvement | We may process your personal data to tailor the product/services we provided. For example, by monitoring the use of our products/services |
| Website improvement |
We may use your personal data to:
|
| Legal obligations | |
| Compliance | We may process your personal data in accordance with our legal and regulatory obligations, such as but not limited to ‘know your client’. |
6. Information we disclose
Redburn Atlantic may share information internally with Rothschild & Co, within our group of companies, or with third parties for purposes described in this policy. An example of these parties is the company we use to prepare and mail your account statements or to perform our internal auditing. Information collected within the European Economic Area (“EEA”) may, for example, be transferred to countries outside of the EEA for the purposes as described in this policy. We use standard contract clauses approved by the European Commission, adopt other means under European Union law to legitimise data transfers from the EEA to the United States and other countries.
In all cases, Redburn Atlantic will ensure that any transfer of personal data is compliant with applicable data protection laws. Even if you cease to transact business with Redburn Atlantic, we will continue to apply the same protections to your personal data, just as we did when you were an active client.
7. Protecting your information
Your personal data is processed and stored securely. Redburn Atlantic maintains a series of effective controls, including automated and manual controls, ensuring that all data under its control will be retained for at least the minimum periods and for no longer than the maximum periods stipulated under regulatory requirements. This is performed in accordance with Redburn Atlantic’s Data Retention Policy and associated Schedules.
Redburn Atlantic protects the personal data of its clients and customers from unlawful access by third parties by maintaining physical, electronic and procedural safeguards. For example, encryption of data at rest and appropriate access control and physical security measures, such as building access for those locations where such data is stored.
We limit access to your personal data to those employees who are trained in the proper handling of a client’s data and who need access to the information to perform their job functions. These employees are responsible for ensuring that data under their control is maintained in compliance with Redburn Atlantic’s Data Protection Policy, and that the policy requirements are acted upon.
8. How long will we keep your personal data?
Whenever we collect or process your personal data, we only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period (as determined by our Data Retention Policy and associated schedules) your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
9. Your rights over your personal data
You have a number of rights over your personal data processed by us. These include:
- access to, and correction of, incomplete, inaccurate or outdated personal data
- transmission of personal data to you or to another person or organisation
- erasure of personal data
- restriction to our processing of your personal data
- objection to processing personal data
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure. The extent of these rights is limited by law, and we may not act on part or all of your request(s) where the right(s) are not applicable. If we do not act on your request, we will explain our reasons why.
If you wish to make a request to exercise any of your rights under applicable Data Protection laws, or require any further information, please contact us in writing through our Data Protection Officer. In most cases we will respond to your request within one month.
10. Contact us
If you have any questions regarding the processing of your personal data or this Privacy Notice, please contact our Data Protection Officer, who will be pleased to help you at, dpofficer@redburnatlantic.com.
You are also entitled to complain to the Information Commissioner’s Office via www.ico.org.uk.