Kyte Broking Limited
Collection and Processing of Personal Data
Personal Data collected
Names, addresses, dates of birth, email addresses, telephone numbers, position, occupation, passports and other national identification documentation, proof of address documentation, beneficial ownership, Politically Exposed Person and Relevant Close Associates information, sanctions hits and adverse media information, monitoring information including records of telephone, Bloomberg and Outlook communications and information pertaining to Data Subject access requests.
Methods of collection
Direct requests during the customer on-boarding (or KYC refresh) stage, during the ordinary course of the customer business relationship, via third party service providers such as on-boarding platforms and public registers and via KBL affiliate entities.
Purpose of processing
Provision of brokerage and advisory services, business and contractual purposes, compliance with legal and regulatory obligations (in particular, with respect to Anti-Money Laundering and Counter Terrorist Financing legislation, MiFID II, EMIR) and to establish and exercise applicable legal rights.
Legal basis for processing
KBL processes the Personal Data of Data Subjects on the basis that:
processing is necessary for the performance of contracts; and/or
processing is necessary for compliance with legal and regulatory obligations and requirements ; and/or
processing is based upon consent of the Data Subject.
Disclosure of Personal Data
KBL may disclose Personal Data to other entities and individual exclusively for legitimate purposes including:
internal business purposes
third party service providers including contract and KYC platform providers
Government, regulatory and law enforcement agencies
Storage and retention
Personal Data is stored by KBL is stored for a period no longer than that which is necessary to meet the purpose for which it was collected.
Transfers outside the European Economic Area
KBL may transfer Personal Data to a third country (being a jurisdiction outside the EEA (or the United Kingdom in the event that the United Kingdom is not a member of the EEA)) where the European Commission has acknowledged that the relevant third country ensures an adequate level of protection or where applicable and appropriate safeguards and/or derogations are in place.
Data Subject rights
Under GDPR, you have a number of rights afforded to you with respect to Personal Data. These rights include rights to access, rectification, erasure and restriction. In addition, you have the right to request for a transferrable copy of certain data to be transferred to another entity and you may also withdraw your consent with respect to KBL processing your Personal Data. Withdrawal of consent will not affect the lawfulness of processing based upon consent prior to such withdrawal.
The General Data Protection Regulation (EU) 2016/679
Any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law
Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
The natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller
If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please email: DB.GDPR@KyteBroking.com .
You can find out more information about your rights by contacting the data protection regulator in your jurisdiction, the Information Commissioner’s Office, or by searching their website at https://ico.org.uk.