Privacy Notice for Clients and Potential Clients
This Client Privacy Notice explains how IQE Limited and it’s subsidiaries, such as IQE Securities Sponsor Services Limited and Ridgeway Associates Limited (“IQE”, “we”, “our”, “us”) collects and processes your personal data when you are, or about to become, a client of IQE. This Client Privacy Notice forms part of the Terms and Conditions between you and IQE.
We have developed a business infrastructure and appropriate policies and procedures to protect and maintain the confidentiality, integrity and security of personal data you may provide to us.
Contact details of IQE Data Protection Officer is:
IQE Limited Data Protection Officer, DPOIQE@iqe.im
2nd Floor, St Mary's Court, Hill Street, Douglas, Isle of Man IM1 1EU
Telephone Number: +44 1624 689594
Personal Data Collection
To provide services to IQE clients or prospective clients we may need to know personal data of individuals such as officers, controllers and contractual relationships with IQE clients and personal data of individuals such as prospective officers, prospective controllers and prospective contractual relationships. Personal data we collect is kept securely.
Use of Personal Data
IQE Limited is licensed and regulated by the Isle of Man Financial Services Authority and as such has a duty to act as a Data Controller and/or Data Processor.
IQE Securities Sponsor Services Limited is approved by The International Stock Exchange as a Listing Member to act as Sponsor or Listing Agent and as such has a duty to act as a Data Controller.
We will only use your personal data for a lawful purpose. Typically we will use your personal data in the following ways:
- Where we need to comply with a legal or regulatory obligation;
- Where it is required to perform the contract we have or may enter into;
- Where it is necessary for our legitimate interests, or those of a third party;
- We may process your data to provide administration, accounting or audit services to the Company/Trust or for the performance of a contract with you or to enter into a contract;
- To send you additional information about our services.
Disclosing Personal Data to Third Parties
We require third parties to treat your personal data in accordance with Data Protection law.
We will disclose your personal data where we have your consent to do so or it is necessary for the performance of a contract.
We may disclose your personal data to enforce or apply our Terms and Conditions to our clients.
We have obligations under law to provide personal data to the regulator and for some matters, to law enforcement agencies and auditors.
We have a duty to verify information which you provide to us and we may use third parties to do so.
We may disclose your personal data to a prospective seller of any business IQE may buy, or to a buyer of any business IQE may sell, or to an acquisitor of IQE business.
We may disclose your personal data to affiliate companies of IQE which provide services to IQE.
International Transfers of Personal Data
If we are required to transfer any personal data outside the EEA or approved adequate jurisdictions we will employ reasonable measures to ensure that the personal data is treated as securely as it would be within the EEA or adequate jurisdictions.
Reasonable measures may include, but are not limited to:
- Your express consent
- Model contracts
- Binding corporate rules
- US/EU privacy shield
- Password protection
We may use your Personal Data to assist us to identify what may be of interest to you. You will only receive marketing communications from us if you have requested information or you expressly consented to receiving such marketing information. IQE will not share your personal data with any company other than IQE and its subsidiaries for marketing purposes.
If you wish to receive marketing information tick your consent to receive occasional communications on IQE's Individual Client Due Diligence Form, or by entering and submitting your e-mail address on the sign up to our newsletter field on our website www.iqe.im
If you change your mind and you no longer wish to receive marketing information you can unsubscribe via the website www.iqe.im or by e-mail request to DPOIQE@iqe.im
If you do not wish to receive marketing information do not tick your consent to occasional communications on IQE's Individual Client Due Diligence Form.
IQE has security measures in place to protect your data and prevent accidental loss, unauthorised use or access. Access to your personal data within IQE is restricted to those with a business need to know.
We send e-mails encrypted by Opportunistic Transport Layer Security however we would encourage you to password protect documents containing personal data when sending to us by e-mail as such transmission may not be secure.
IQE has procedures in place to deal with an actual or suspected personal data breach and will notify you and any applicable regulator in accordance with our legal requirement.
We will only retain your personal data for as long as it is required to do so by law or other obligations and for the purposes it has collected the information.
We may retain anonymised personal data for statistical or research purposes indefinitely. You would not be identifiable from any anonymised information which we might retain.
You have rights under data protection legislation regarding your personal data.
You may have certain rights in respect of your personal data, to access, request correction or erasure, object to or restrict processing, request transfer or withdraw consent.
If you think we hold information about you which you believe is incorrect please contact IQE Data Protection Officer.
You can find out if IQE hold any personal information by making a 'Subject Access Request'. To make a Subject Access Request send a written request to the Data Protection Officer at the above address. We may need to ask for verification of your identity or additional information to process a Subject Access Request.
You will not have to pay a fee when submitting a Subject Access Request unless your request is repetitive, excessive or unfounded. If so we may charge a reasonable fee or refuse to comply with your request.
You have the legal right to make a complaint to the Information Commissioner's Office in the Isle of Man or to the relevant authority in the jurisdiction of your residence. We would encourage you to contact us in the first instance as we would aim to address any concerns you may have.
A full explanation of your rights and additional helpful guidance can be found at the website of the Isle of Man Information Commissioner's Office. https://www.inforights.im/
Changes to this Client Privacy Notice
This Client Privacy Notice may change from time to time. The current Client Privacy Notice will be on IQE website www.iqe.im if the changes are material we will contact you to advise you. Concerns about the collection or use of your personal data or requests to exercise your legal rights should be addressed to the Data Protection Officer at the contact details above.
IQE Data Protection Officer is responsible for oversight of this Client Privacy Notice.