Processing activity |
Legal basis for processing |
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AML/KYC: fulfilling our regulatory compliance obligations, including ‘Know Your Client’ checks; and confirming and verifying your identity (including by using credit reference agencies); and screening against government, supranational bodies (including but not limited to the European Union and the United Nations Security Council) and/ or law enforcement agency sanctions lists as well as internal sanctions lists and other legal restrictions. |
The Processing is necessary for compliance with a legal obligation; or
The Processing is necessary in connection with any contract that you may enter into with us, or to take steps prior to entering into a contract with us; or
We have a legitimate interest in carrying out the Processing for the purpose of protecting against fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). |
Client on-boarding: on-boarding new clients; and compliance with our internal compliance requirements, policies and procedures. |
The Processing is necessary in connection with any contract that you may enter into with us, or to take steps prior to entering into a contract with us; or
We have a legitimate interest in carrying out the Processing for the purpose of on-boarding new clients (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). |
Provision of products and services to you: administering relationships and related services; performance of tasks necessary for the provision of the requested services; communicating with you in relation to those services. |
The Processing is necessary in connection with any contract that you may enter into with us, or to take steps prior to entering into a contract with us; or
We have a legitimate interest in carrying out the Processing for the purpose of providing services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). |
Marketing / Prospecting: communicating with you via any means (including via email, telephone, text message, social media, post or in person) subject to ensuring that such communications are provided to you in compliance with applicable law; and maintaining and updating your contact information where appropriate. |
We have a legitimate interest in carrying out the Processing for the purpose of conducting marketing and prospecting (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). |
Operation of our Sites: operation and management of our Sites; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our Sites. |
The Processing is necessary in connection with any contract that you may enter into with us, or to take steps prior to entering into a contract with us; or
We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). |
IT operations: management of our communications systems; operation of IT security; and IT security audits. |
The Processing is necessary for compliance with a legal obligation; or
We have a legitimate interest in carrying out the Processing for the purpose of managing and operating our IT systems and ensuring the security of those systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). |
Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations. |
The Processing is necessary for compliance with a legal obligation; or
We have a legitimate interest in carrying out the Processing for the purpose of providing a safe and secure environment at our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
The Processing is necessary to protect the vital interests of any individual. |
Financial management: sales; finance; corporate audit; and vendor management.
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We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). |
Research: conducting market or customer satisfaction research; and engaging with you for the purposes of obtaining your views on our products and services. |
We have a legitimate interest in carrying out the Processing for the purpose of conducting research and producing analysis (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). |
Security: physical security of our premises (including records of visits to our premises and CCTV recordings); and electronic security (including login records and access details, where you access our electronic systems). |
The Processing is necessary for compliance with a legal obligation; or
We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). |
Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law. |
The Processing is necessary for compliance with a legal obligation; or
We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). |
Legal compliance: compliance with our legal and regulatory obligations under applicable law.
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The Processing is necessary for compliance with a legal obligation. |
Legal proceedings: establishing, exercising and defending legal rights.
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The Processing is necessary for compliance with a legal obligation; or
We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). |
Improving our products and services: identifying issues with existing products and services; planning improvements to existing products and services; and creating new products and services. |
We have a legitimate interest in carrying out the Processing for the purpose of improving our products or services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). |
Risk Management: Audit, compliance, controls and other risk management.
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The Processing is necessary for compliance with a legal obligation; or
We have a legitimate interest in carrying out the Processing for the purpose of managing the levels of risk to which our business is exposed (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). |
Fraud prevention: Detecting, preventing and investigating fraud.
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The Processing is necessary for compliance with a legal obligation; or
We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). |