Sinnamas Investment Bank & Capital Trust endeavors to maintain the highest standards of confidentiality and to respect the privacy of our clients and associated persons, our employees, and other individuals whose personal data we collect and process. Our commitment to privacy includes being transparent about the nature and extent of that processing and the rights that may be available to you with respect thereto.
WHAT DATA DO WE COLLECT ABOUT YOU?
The categories below describe the Data collected about you and the sources from which we collect.
Personal information for individuals: first name, last name, country, country of tax residence, national identity number, birthdate, contact details, bank details;
Information about investing entities: [name, country, registration number, legal address, tax residency, bank details]; information about representative: [first name, last name, national identity number, country of tax residence, birth date, contact details]; details of beneficial owners owning more than 25% of the shares of the legal entity.
Transactional information: records of payments made to and received from us, records of invested funds, investments, net annual return, available funds;
Information provided voluntarily by filling in forms on our Site, by registering an account, by contacting us through “Contact Us” section on our Site (which may from time to time include requesting information from us or submitting comments) and/or when you meet with us.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
Device and Online Identifiers
Sources: You; devices associated with you; third-party information providers.
Description: IP address; session ID (session start time).
Internet, Browser, and Network Activity
Sources: You; devices associated with you; third-party information providers Description: clickstream/online website tracking information; data related to user activity, e.g., browser visits, page views, visits, and unique visitors data; and cookies or other similar technologies.
Description: Region, country, and city
Sources: You; devices associated with you; third-party information providers
WHY DO WE COLLECT YOUR DATA?
We collect and process information about you for the purposes of complying with our legal duties and for other legitimate purposes. We may use your Data, collected from direct interaction, automated forms and third parties to:
Ensure that content from our Site is presented in the most effective, responsive and compatible manner for you and for your computer or device;
Respond to your requests for information and other communication or correspondence you may submit to us;
Provide you with general information on our Site and to provide you with personalized services;
Provide marketing information and special offers with your consent;
Enable you to login to the Site and our web platform, using your email address, username and the password that you have chosen;
Provide you with information about your registration or accounts;
Provide you with the information or services that you request from us;
Carry out statistical analysis, customer surveys and market research;
Allow you to participate in interactive features of our Site, when you choose to do so;
Carry out activities necessary to the running of Sinnamas Investment Bank & Capital Trust, including systems testing, network monitoring, staff training, improving technical systems and IT infrastructure, and quality control;
Notify you about changes to our Site, services or policies;
Legal obligations and identity checks in order to comply with the applicable laws and international agreements;
In order to conclude and execute a contract with the Client; ensuring the accuracy of the data by checking and updating internal and external data sources and to be able to fulfill the obligations of the contract between the user and Sinnamas Investment Bank & Capital Trust;
For the interests of the client and/or Sinnamas Investment Bank & Capital Trust; and to know the quality of the services provided; and to provide evidence of commercial transactions and other commercial communication;
To prevent the abuse of dishonest use of services and to provide proper provision of services. To sanction and control the access to digital channels, to prevent unauthorized access and to ensure information security.
BASIS OF PROCESSING
For some processing activities, we consider that more than one lawful basis may be relevant – depending on the circumstances.
The following are the basis for the processing of your personal data:
It is necessary for the purposes of our contract with you or to take steps for entering into our contract with you;
It is necessary to comply with our legal obligations;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
Consent, where the personal data relates to the person supplying it to us and has been supplied to us voluntarily.
DISCLOSURE OF YOUR DATA
We consider your Data to be private and confidential. From time to time, we may collect and share your Data with third parties, including third-party service providers or other entities. We may access and/or disclose your Data if required to do so by law or in good faith and belief that such action is necessary to: (a) conform with the law or comply with legal process served on us; (b) protect and defend our rights or property including, without limitation the security and integrity of our network and systems; or (c) act under exigent circumstances to protect the personal safety of users of our services or members of the public.
We may share your information with the following types of entities:
We use third-party service providers who work for us in the provision of our services, for example, communications, marketing, IT service providers, verification agencies and other business support companies. In providing the services, your Data will, where applicable, be processed by the service provider on our behalf. Data disclosed for these purposes may include device and online identifiers, information about your internet, browser, and network activity, and location data.
Other entities related to legal process and emergency situations:
We may disclose your Data to third parties as permitted by, or to comply with, applicable laws and regulations. Examples include responding to a subpoena or similar legal process, protecting against fraud and cooperating with law enforcement or regulatory authorities. Data disclosed for these purposes may include device and online identifiers, information about your internet, browser, and network activity, and location data.
HOW LONG WILL WE USE YOUR DATA FOR?
We keep your personal data for as long as it is necessary to do so to fulfill the purposes for which it was collected as described above, including for the purposes of satisfying any legal, accounting, or reporting requirements. This may mean that some information is held for longer than other information, for example, we may need to retain some Data for up to ten years. The criteria we use to determine data retention periods for personal data includes the following:
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
PRIVACY AND THE INTERNET
The following additional information will be of interest to you as a visitor to this Site:
“Clickstream” data (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences) may be collected by Sinnamas Investment Bank & Capital Trust itself, or by our service providers, using cookies, web beacons, page tags, or similar tools that are set when you visit the Site or when you view an advertisement we have placed on another website. Clickstream data and similar information may be shared internally within Sinnamas Investment Bank & Capital Trust and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with the Site; and as otherwise permitted by applicable law or regulation. This information may be processed by us for the purposes described above, or on our behalf by other entities, solely in accordance with our instructions.
This Site is not currently configured to respond to “do not track” signals or similar mechanisms.
LINKS TO OTHER WEBSITES
Sinnamas Investment Bank & Capital Trust may make available on this Site third party applications such as content linking or sharing facilities or links to and from other websites and web platforms. Information collected by providers of such applications is governed by their privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those third-party applications.
We will use appropriate technical and physical security measures to protect your personal data which is transmitted, stored or otherwise processed by us, from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access.
Access is only granted to Data on a need-to-know basis to those people whose roles require them to process your personal data. In addition, our service providers are also selected carefully and required to use appropriate protective measures.
As effective as modern security practices are, no physical or electronic security system is entirely secure. The transmission of information via the internet is not completely secure. Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to the Site. Any transmission of Data is at your own risk. Once we receive your Data, we will use appropriate security measures to seek to prevent unauthorized access. We will continue to revise policies and implement additional security features as new technologies become available.
HOW CAN YOU CONTACT US?