Clear Treasury (UK Trading) Limited ("We" or "Us") are committed to protecting and respecting your privacy.
When we say "You" or "Your" this includes the personal data of any of your directors, partners, other officers, shareholders and authorised signatories that you give us or that we may collect from other sources. When you give us this data you must ensure that you have obtained the consent of the individuals concerned.
This policy together with our Terms of Business sets out the basis on which any personal data we collect from you, or that you provide to us, or that we obtain elsewhere will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Who we are
For the purposes of the General Data Protection Regulation (GDPR) we are the data controller and can be contacted at:
Clear Treasury (UK Trading) Limited
London EC2M 4QP
Telephone: 020 7151 4875
Our Data Protection Officer is the Head of Compliance and can be contacted at the same address and telephone number.
Purpose of processing
We collect information from you and about you in order to be able to provide the products and services that you have requested us to provide in accordance with the contract you have agreed to [https://www.cleartreasury.co.uk/terms-of-business/]. We may also contact you with regard to other products and services provided by the Clear Treasury Group of companies.
The lawful basis for processing
For our customers there are two lawful bases for us processing your personal data:
- you have a contract with us [https://www.cleartreasury.co.uk/terms-of-business/] and we need to process your personal data to comply with our obligations under that contract…
- and/or we have a legal obligation under the Money Laundering Regulations 2017 to process your personal data
Information we may collect from or about you
We may collect and process the following personal data about you:
- Information you give us.
You may give us information by filling in application forms on our website sign up (our site) or by communicating with us by phone, e-mail or other medium. The information you give us may include: –
- Full name
- Date of birth
- Email address
- Telephone number
- Copies if identity documents containing a photograph e.g. passport or driving licence
- Copies of bank statements containing financial information or copies of utility bills
- Information we collect about you.
With regard to each of your visits to our site we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- Information we receive from other sources.
In order to comply with our obligations under the Money Laundering Regulations we may verify your identity electronically using the services of a business partner. The information we receive may include residency information including presence on an electoral register, telephone services, information obtained from credit reference agencies, details of directorships held, any county court judgements and media articles.
Disclosure of your information
We may share your personal information with any member of our group, which means our parent company and its subsidiaries.
We may share your information with selected third parties including:
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you and to verify your identity and address in accordance with our obligations under the Money Laundering Regulations 2017 Analytics and search engine providers that assist us in the improvement and optimisation of our site.
Where we store your personal data and for how long
All information you provide to us is stored on our secure servers within the European Economic Area ("EEA").
We will keep your personal information for a minimum of 5 years after our business relationship with you ends. This is in order to comply with our obligations under the Money Laundering Regulations 2017
Access to information
Under the GDPR, you have the right to obtain:
- confirmation that your data is being processed;
- access to your personal data; and
- other supplementary information
Generally we will provide a copy of the information free of charge, however we may charge a ‘reasonable fee’ when a request is manifestly unfounded or excessive, particularly if it is repetitive. We may also charge a reasonable fee to comply with requests for further copies of the same information. The fee will be based on the administrative cost of providing the information.
We will provide the information without delay and at the latest within one month of receipt of your request. We may extend this period by a further two months where requests are complex or numerous. If this is the case, we will inform you within one month of the receipt of your request and explain why the extension is necessary.
Right to rectification
Under the GDPR you have the right to have inaccurate personal data rectified, or completed if it is incomplete. You can make a request for rectification verbally or in writing.
We will respond to a request within one calendar month.
Right to erasure
Under the GDPR you have the right to have personal data erased in certain circumstances, for example if the personal data is no longer necessary for the purpose which we originally collected or processed it for. The right is not absolute and only applies in certain circumstances, for example we will not erase the data if we need to keep it to comply with a legal obligation such as the Money Laundering Regulations 2017.
You can make a request for erasure verbally or in writing. We will act upon the request without undue delay and at the latest within one month of receipt of your request. In most cases we will not charge a fee to comply with a request for erasure unless the request is manifestly unfounded or excessive in which case we may charge a “reasonable fee” for the administrative costs of complying with the request.
If you have a complaint about the way your personal data is being handled you may contact us at the address or on the telephone number above. Alternatively you may contact the Information Commissioners Office via make a complaint or on 0303 123 1113.