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1. About Us
1.1. This notice applies to the following members of the Capital International Group all of whom are registered with The Isle of Man Information Commissioner as data controllers and who for the purposes of this notice are referred to as ‘the Group’:
1.1.1. Capital International Limited
1.1.2. Capital Treasury Services Limited
1.1.3. Capital Select Limited
1.1.4. Mill Yard Services Limited
In addition this notice applies to following Group companies, based in South Africa, who are not registered with the Isle of Man Information Commission
1.1.9. CILSA Investments (PTY) Limited and
1.1.10. CILSA Solutions (PTY) Limited
and collectively referred to as ‘Group companies’
1.2. Capital International Limited, Capital Treasury Services Limited, Capital Financial Markets Limited and are licensed by the Isle of Man Financial Services Authority.
Capital International Limited is a Member of the London Stock Exchange.
CILSA Investments (PTY) Ltd, trading as Capital International SA (FSP No 44894), and CILSA Solutions (PTY) Ltd (FSP No 6650) are licensed by the Financial Sector Conduct Authority (FSCA) as a Financial Services Provider.
1.3. Unless otherwise indicated our services not targeted at, nor will they be offered or available to the residents of any particular country where their advertisement, offer or sale is restricted or prohibited by law or regulation or where a Group company is not appropriately licensed;
1.4. This Notice should be read in conjunction the Terms and Conditions of Use of the Website and forms part of those terms and conditions;
1.5. We, the Group, are committed to protecting your privacy and personal data. This Privacy and Cookie Notice details the steps we take to protect your personal data It describes the personal data that we collect, the purposes for which we use such information, and your choices regarding our use of it.
1.6. In our capacity as data controller we will securely store and process your personal data which you provide to us from time to time.
2.1 For the purposes of this Privacy and Cookie Notice the following terms shall be thus defined
2.2 “Personal Data” shall be defined as any information or data relating to you as data subject;
2.3 “Data Subject” is an identified or identifiable person to whom personal data relates. An identifiable person is one who can be identified, directly or indirectly in particular by reference to an identification number or to one or more factors specific to their physical, physiological, mental, economic, cultural and social identity;
2.4 “Data Controller” shall be defined as a person who determines the purposes for which and the manner in which any personal data are, or are to be processed
3. Changes to this Privacy Notice
3.1 We may occasionally update this Privacy Notice. When we do, we will revise the “last updated” date at the bottom of the Privacy Notice. Please ensure that you frequently check this Privacy Notice for any updates.
4. Collection of data
4.1 Depending upon your use of our site, we may collect some or all of the following personal data:
i. Information you give us; We receive and store any information you enter on our website or give us in any other way; this may include
• your name,
• company name;
• email address;
• phone number;
• your preferences in relation to the site and our services/products;
• any communication you have with us; and
• any other data that you may submit to us via the site from time-to-time.
You are not required to provide any of this information, but if you do not, we may not be able to provide you the requested services/products.
ii. Automatic information
• We receive and store certain types of information whenever you interact with the Group. For example, like many websites, we use ‘cookies’ and we obtain certain types of information when your web browser accesses the Group website.
• This will include but not be limited to: the IP address used to connect your computer to the Internet,; login; e-mail address; computer and connection information such as browser type and version ; time zone setting; browser plug in types and versions and operating systems.
• We may use browser data such as cookies, Flash cookies, or similar data on certain parts of our website for fraud prevention and other purposes.
• We may also collect technical information to help us identify your device for fraud prevention and diagnostic purposes.
• Most mobile devices provide users with the ability to disable location services. Most likely, these controls are located in the device’s settings menu. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or your device manufacturer.
iv. Co-Branded & Joint Offerings
• We may from time to time offer joint or co-branded products and services.
v. Information You Can Access
• Examples of information you can access easily include: personally identifiable information (including name, e-mail, password, communications and personalised advertising preferences and address book); payment settings (including bank and credit-card information); e-mail notification settings;
5. How is your personal data used?
5.1 Personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the regulations at all times.
5.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (eg by subscribing to marketing emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
• to provide you with personalised visits to our site;
• to analyse your use of our site and gathering feedback to enable us to continually improve our site and your user experience;
• to provide you with access to our corporate literature and information about our services and products;
• to recommend goods, services or promotions which may be of interest to you (but only where you have consented to be contacted for such purposes);
• to develop our offers and the layout of our site to ensure that our services are as useful and enjoyable as possible;
• to contact you; and
• to send out news updates which you have signed up for.
• to improve our offerings and this website,
• to prevent or detect fraud or abuses of our website and
• to enable third parties to carry out technical, logistical and other functions on our behalf.
6. With whom is your personal data shared?
6.1 In order to provide services to you Group companies may be required to share personal data. This will be subject to the conditions as set out below.
6.2 We may disclose anonymised data (such as aggregated statistics) about the users of our site in order to describe our web users, traffic patterns and other site information to prospective partners, investors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifying information.
6.3 We may occasionally be required by law, court order or governmental authority to disclose certain types of personal data. Examples of the type of situation where this would occur would be:
• in the administration of justice; or
• where we have to defend ourselves legally.
6.4 Third Party Service Providers: We employ other companies and individuals to perform functions on our behalf. They have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Notice and as permitted by applicable data protection laws.
6.5 When specifically authorised by you
7. The requirements of Data Protection Laws
7.1 We regard the lawful and correct treatment of your personal data by us as very important to our successful operation, and to maintaining confidence between us and our users. We ensure that our organisation treats personal data lawfully and correctly. To this end we fully endorse and adhere to the data protection principles set out in legislation.
In particular, without your consent or first amending this Privacy Notice to reflect any change in our usage of personal data all Group companies will apply the following concepts:
• we will ensure that we will not use your personal data for any purpose that is incompatible with this Privacy & Cookie Notice;
• We will ensure that any processing of your personal data is fair and transparent and sufficient for the uses as set out above;
• we will endeavour to keep your personal data up-to-date;
• we will not retain your personal data longer than necessary unless required to do so by law;
• We will implement appropriate technical and organizational measures to enable inaccuracies to be corrected and minimize the risk of errors;
• Secure personal data in a way that is proportionate to the risk to the interest and right of you as data subject;
• We will operate appropriate technical and organisational processes to protect your personal data against unauthorized or unlawful access or processing and against accidental loss or destruction. The detailed measures we take are described elsewhere in this Privacy Notice;
• we will not transfer your personal data to a country outside the European Economic Area unless sufficient safeguards have been established to protect your personal data to a standard at least equivalent to those, which apply within the EEA.
8. Your rights
8.1 We will look to ensure that all of your rights as defined in the Isle of Man data protection legislation in place from time to time, to include but not limited to the following:
• Right to be informed
• Right to erasure
• Right to data subject access
• Right to restrict processing that is likely to cause or is causing damage or distress;
• Right to data portability
• Right of rectification
• Right to object
• Rights relating to the use of automated decision making and profiling systems based on personal data;
• Right to apply/remove consent for processing of personal data;
8.2 The nature of your rights under the Isle of Man legislation and how they make be invoked is referred to in our full Privacy Notice which can be accessed here.
8.3 If you do not want to receive email or other mail from us, or for us to use personal information that we gather, please contact customer services in the first instance at the address below.
8.4 If you contact us in relation to your rights we will do our best to accommodate your request or objection.
8.5 You can help us to maintain the accuracy of your information by notifying us of any change at email@example.com
8.6 If you are unsure about your rights or are concerned about how your personal data may be processed you should contact the Information Commission’s Office – either by telephone +44 1624 693260 or firstname.lastname@example.org
9.1 Cookies are small files that websites save to your hard disk or to your browser’s memory. The cookies used on our site are listed below. Please note you have the ability to accept or decline cookies. Most Internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your computer. If you do choose to decline cookies, you may not be able to fully experience the features of our site or other websites that you visit. To learn more about cookies and how to disable them we recommend you visit the Information Commissioner’s website here.
9.2 Before Cookies are placed on your computer or device, you will be shown a pop up box requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however, certain features of our site may not function fully or as intended.
9.3 Our site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our site is used. This, in turn, enables us to improve our site and the services offered through it.
10.1 We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.
10.2 We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
10.3 As a condition of employment, employees of all Group entities are required to follow all applicable laws and regulations, including those in relation to data protection law. Unauthorised use or disclosure of confidential client information by a Group employee is prohibited and may result in disciplinary measures.
10.4 It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer.
11.1 As a client the full privacy notice will apply – this can be found by following this link. We will hold your personal data for so long as we are providing services to you and in accordance with the data protection regulations in place in the Isle of Man from time to time. We will endeavor to delete any personal data sooner where it is not necessary for us to hold this, but please be aware that we may hold personal data for longer if we are under a legal obligation to do so or where we have a reasonable belief that it is necessary to do so for business or legal reasons.
12. Links to other websites
Our site may contain links to other websites. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites.
13. How to contact us
If you have questions regarding this notice, us if you would have any queries about, or would like to enforce, your rights set out above (at section 10) or our handling of your personal data, please contact our Data Protection Officer :
• In writing at Capital House Circular Road Douglas Isle of Man IM1 1AG.
• by email at dpo@capital–iom.com
We will promptly address your concern and strive to reach a satisfactory resolution.
Last Update : May 2018