Your privacy is important to us. It is NIRCOM A.S.I.G Ltd's policy to respect your privacy regarding any information we may collect from you across our website, https://www.nircom.co.uk, and other sites we own and operate.
We only ask for personal information when we truly need it to provide a service to you. We collect it by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used.
We only retain collected information for as long as necessary to provide you with your requested service. What data we store, we’ll protect within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification.
We don’t share any personally identifying information publicly or with third-parties, except when required to by law.
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and practices of these sites, and cannot accept responsibility or liability for their respective privacy policies.
You are free to refuse our request for your personal information, with the understanding that we may be unable to provide you with some of your desired services.
Your continued use of our website will be regarded as acceptance of our practices around privacy and personal information. If you have any questions about how we handle user data and personal information, feel free to contact us.
This policy is effective as of 1 November 2020.
In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, as prospective investor of our Company, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
processing is fair, lawful and transparent
data is collected for specific, explicit, and legitimate purposes
data collected is adequate, relevant and limited to what is necessary for the purposes of processing
data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
data is not kept for longer than is necessary for its given purpose
data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
we comply with the relevant GDPR procedures for international transferring of personal data
TYPES OF DATA HELD
We keep several categories of personal data on our prospective investor in order to carry out effective and efficient processes. We keep this data in secured files relating to each investor and we also hold the data within the company computer systems using protected files.
Specifically, we hold the following types of data:
personal details such as name, address, phone numbers;
proof of your ID such as ID, Passport and/or Deriving License;
proof of your address such as Utility Bill, Bank statement and/or Government official document;
COLLECTING YOUR DATA
You are required to provide several pieces of data to us directly during the due process and ID verification.
In some cases, we will collect data about you from third parties, such as credit agencies, when gathering references or credit reference agencies.
Should you be successful in your application, we may gather further information from you, for example, your bank details and next of kin details.
LAWFUL BASIS FOR PROCESSING
The law on data protection allows us to process your data for certain reasons only.
The information below categorises the types of data processing we undertake and the lawful basis we rely on.
Activity requiring your data
Carrying out checks in relation to your ID
Carrying out checks in relation to your Address
Carrying out checks in relation to your Status as HNWI or Sophisticated Investor
Our legitimate interests
Our legitimate interests
SPECIAL CATEGORIES OF DATA
FAILURE TO PROVIDE DATA
Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract with you.
CRIMINAL CONVICTION DATA
We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us.
WHO WE SHARE YOUR DATA WITH
If you will become a shareholder in the Company, your name and address will be listed on the Company share register.
Employees within our company who have responsibility for compliance and data control will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR.
Data is shared with third parties for the following reasons: Accountants, Law Firm, and Legal Obligations regarding financial due process.
We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
We do not share your data with bodies outside of the European Economic Area.
PROTECTING YOUR DATA
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
We only keep your data for as long as we need it for.
If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for six months once the recruitment exercise ends.
If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for nine months once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data and there will be no consequences of withdrawing consent.
If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.
AUTOMATED DECISION MAKING
Automated decision-making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
You have the following rights in relation to the personal data we hold on you:
the right to be informed about the data we hold on you and what we do with it;
the right of access to the data we hold on you. We operate a separate Subject Access Request policy and all such requests will be dealt with accordingly;
the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
the right to restrict the processing of the data;
the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
the right to object to the inclusion of any information;
the right to regulate any automated decision-making and profiling of personal data.
In addition to the above rights, you also have the unrestricted right to withdraw consent, that you have previously provided, to our processing of your data at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above, please contact Our appointed compliance officer.
MAKING A COMPLAINT
If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
DATA PROTECTION COMPLIANCE
Our appointed compliance officer in respect of our data protection activities is:
NAME: Compliance Manager
EMAIL ADDRESS: firstname.lastname@example.org