Privacy Policy

Introduction
 You will hopefully be very familiar with the General Data Protection Regulation, or GDPR, as it is more commonly referred to. Nevertheless, we would strongly encourage you to read this privacy and cookie policy (“this Policy”) and become familiar with its contents. It explains how Pierre-Circle collects, uses, and shares the information you provide to us and the information we collect about you in the course of operating our business (we refer to this as “Personal Data”). It also sets out how we use cookies on our website and in our communications with you.

What Types of Personal Data Do We Process?
 Building on the explanation above, Personal Data refers to any information that can be used to identify you or be linked to you, which we possess or control. Given the nature of the services we provide, the types of personal data we process can vary greatly. This may include:

The Information You Provide to Us

• Personal details (e.g., your name, date of birth, gender, and employment information)
• Contact details (e.g., your address, email, landline number, and mobile number)
• Identity information (e.g., your nationality, passport details, driver’s license, and National Insurance number)
• Bank details (e.g., your account name, number, and sort code)
• Information regarding other trades you may have with foreign exchange providers, which you provide or input into our system for comparison purposes

Information We Collect About You

• Transactional details (e.g., information about your accounts, trades executed by you, payments made to and from your accounts, and data related to suspicious or unusual activities)
• Communication records (e.g., emails and records of telephone conversations)
• Publicly available information (e.g., details available on websites like LinkedIn)
• Information from investigatory agencies (e.g., anti-money laundering reports, credit reports, external intelligence reports, and other due diligence reports)
• Risk assessment information (e.g., credit risk rating and transactional behavior)
• Information gathered when you visit our websites (for further details, please refer to our Cookie Policy below)

In certain very limited situations, we may collect and/or process special categories of Personal Data. This may include information about your health, racial or ethnic origin, religious, philosophical, or political beliefs, trade union membership, sex life or sexual orientation, genetic data, or biometric data. In such cases, we take extra precautions to ensure that this data is processed only within strict legal guidelines.

How We Collect Personal Data

 We may collect Personal Data at various stages of our interaction with you or in relation to our dealings with you. This can include:

• When you register with us online, subscribe to our services, complete forms (whether in person or on our website), correspond with us (via telephone or email), or provide us with any relevant documents
• From cookies on our website (please refer to our Cookie Policy below)
• From feedback you provide regarding our services and/or website
• From various third parties, including:
  • Our partners (e.g., individuals or companies who refer you to us)
  • Our clients (e.g., if you are a third-party payee and we are making a payment to you)
  • Credit reference agencies (e.g., Equifax and Experian)
  • Fraud prevention agencies (e.g., Cifas)
  • Identity verification agencies (e.g., GBGroup)
  • Government and law enforcement agencies

How We Use Personal Data
 We use your Personal Data for the following purposes:

• To provide foreign exchange and related services to you or our clients
• To engage in marketing and business development activities related to our services
• To fulfill our legal and regulatory obligations
• To establish, exercise, or defend our legal rights or for legal proceedings
• To record and monitor your use of our websites or other online services for business purposes, which may include usage analysis, site performance measurement, and generating marketing reports
• To share with our professional advisors
• To share with a prospective buyer or seller in the event that we buy or sell any business or assets, or if substantially all of our assets are acquired by a third party
• To pursue legitimate business interests, such as conducting business research and analysis, and managing the operation of our websites and business
• To address any complaints or queries you may have
• To prevent and respond to actual or potential fraud or illegal activities

Additionally, we may aggregate and process information to generate statistics, provided that neither you nor any individual can be identified from the resulting analysis and the aggregation, processing, and dissemination of such information is permitted by law.

The Legal Basis for Processing Personal Data
 Now, onto the legal aspects. We will only process your Personal Data where we have a lawful basis to do so. Our lawful basis will be one or more of the following:

• Consent – When we have obtained your consent to use your Personal Data. You can withdraw your consent at any time by contacting us.
• Performance of a Contract – If we need to collect and use your Personal Data to perform a contract to which you are a party or to take steps at your request before entering into a contract.
• Legitimate Interests – We may use your Personal Data when necessary for the pursuit of our legitimate interests, such as providing foreign exchange and related services or for general business purposes.
• Compliance with Law or Regulation – We may process your Personal Data when necessary to comply with applicable laws or regulations.

Sharing Information with Third Parties
 In the course of providing services to our clients and fulfilling our legal obligations, we may share your Personal Data with third parties, provided we are legally permitted to do so. This may include sharing with:

• Third-party agents, suppliers, or contractors, who are bound by confidentiality obligations, for the processing of your Personal Data as described in this Policy. This may include IT service providers (e.g., software-as-a-service providers, data room and server providers, and communication service providers).
• Third parties relevant to the services we provide, which may include our counterparties, other professional advisors, service providers, regulators, authorities, governmental institutions, and stock exchanges.
• Designated third parties when we are required by law, regulation, or court order to disclose your Personal Data.

Transfers to EEA
 We may need to transfer Personal Data to countries outside the European Economic Area (“EEA”) (e.g., when reporting to foreign authorities). In such cases, we will ensure that our actions comply with the data security standards outlined in the GDPR. We will also take all reasonable steps to ensure that your Personal Data is stored securely and is not shared or sold to third parties for marketing purposes.

Where Personal Data is transferred to and stored in a destination outside the EEA, it may be processed by staff operating outside the EEA who work for one of our suppliers. These staff may be involved in, among other tasks, providing support services. By submitting your Personal Data, you consent to this transfer, storage, or processing. We will take reasonable steps to ensure that your Personal Data is treated securely and in accordance with this Policy.

Transmission and Keeping Your Information Safe
 Unfortunately, the transmission of information via the internet is not entirely secure. While we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our website. Any transmission of your Personal Data is done at your own risk.

Once we have received your Personal Data, we will implement strict procedures and security features, in line with the standards set by the GDPR, to protect it from unauthorized access.

How Long We Keep Your Information
 We will only retain your Personal Data for as long as necessary to fulfill the purpose for which it was collected. The retention period will depend primarily on:

• The purpose for which we are using your Personal Data. For example, if we collect your data to provide foreign exchange services, we will retain it for as long as we continue to provide those services.
• Legal obligations – We are subject to laws and regulations that set minimum periods for retaining Personal Data. For instance, under the Money Laundering Regulations 2017 and the Companies Act 2006, we must retain Personal Data for up to six years after our business relationship with you ends.

At the end of the relevant retention period, your Personal Data will either be deleted or anonymized to ensure that it can no longer identify you.

What Are Your Rights?
 You have certain rights regarding your Personal Data, and we will make every effort to respect your requests to exercise these rights.

• Access: You can request access to your Personal Data by submitting a Subject Access Request (SAR). After confirming your identity, we will comply with your SAR free of charge within 30 days, unless we find the request to be unfounded or excessive. In such cases, we will explain why we have not processed your request.
• Correction: You can ask us to correct any inaccurate, outdated, or incomplete Personal Data we hold about you.
• Erasure: You can request that we delete or stop using your Personal Data when it is no longer necessary for the purposes for which it was originally collected (subject to our legal or regulatory obligations to retain it).
• Restriction: You may ask us to stop processing your Personal Data if you believe its accuracy is disputed or the processing is unlawful.
• Withdrawing Consent: If we have processed your Personal Data based on your consent, you have the right to withdraw that consent at any time.
• Legitimate Interests: If we process your Personal Data based on our legitimate interests, you can ask us to stop for reasons related to your particular situation. We will comply unless we have a legitimate reason to continue processing your data.
• Marketing: You can opt out of receiving marketing communications. To do so, simply log into your account and update your marketing preferences.

Submitting a Request
 You can exercise your rights at any time by contacting us at support@pierrecircle.com

To protect the confidentiality of your information, we will always ask you to verify your identity before proceeding with any request. If you have authorized a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

If we decide not to process your request, we will explain the reasons for our refusal.