This Policy sets out the basis on which Ebonstone Limited collects, uses and discloses your personal data and your rights in relation to the personal data that we hold.
Who we are
In this Policy, the terms “Ebonstone”, “we”, “us” or “our” refers to Ebonstone Limited, a company registered and incorporated in England and Wales under company number 8181258, our registered office and details of our nominated Privacy & Data Compliance Officer’s details can be found at the end of this Policy. Ebonstone is registered as a data controller with the Information Commissioner’s Office, with registered number ZA052685, in respect of your personal data and in line with the EU General Data Protection Regulation 2016/679 (“GDPR”) and any locally applicable data protection regulations.
Personal data we collect and hold
We will only collect and hold information that you provide us with whether that be in person, in writing, by telephone, by fax, via our website, by email or any other form of electronic communication or from publicly available sources or third parties. We may collect the following categories of personal data about you:-
- Your name and contact information, such as home address, job title, email and telephone details;
- Biographical information which may confirm your identity including your date of birth, tax identification number, passport or identity card details, country of domicile and/or your nationality;
- Information about your financial situation such as income, expenditure, assets, liabilities and sources of wealth as well as bank account details;
- Information about your reasons and objectives for securing our services;
- Information to assess whether you may represent a money laundering risk.
Processing and disclosure
We will process the personal data you provide us with because it is necessary for the performance of our contract with you or for our legitimate business interests or in compliance with any legal obligations we may be under.
We may use your personal data:-
- To prepare a proposal in relation to the services that we offer;
- To provide you with the services that you request from us;
- To carry out any obligations arising from any contracts entered into between you and Ebonstone;
- To notify you of any changes to our terms and conditions of business;
- To provide you with information which we feel may be of interest or relevant to you, such as alerts, newsletters and updates;
- To deal with any complaints or feedback from you in relation to such service; or
- For any other purpose for which you provide us with your personal data.
As part of our processing of your personal data we may share your data:-
- with our advisers and/or auditors, where it is necessary for the purposes of obtaining their advice or assistance;
- with third parties who undertake background checks on our behalf;
- if we are under a duty to do so in order to comply with any legal obligations, such as compliance with anti-money launder laws;
- as required by tax authorities or any competent court or legal authority;
- in order to enforce our terms and conditions of business; or
- to protect the rights, property or safety of Ebonstone, its employees or clients.
Under GDPR you have the following rights:-
- Right to be informed – you have the right to be informed about the collection and use of your personal data;
- Right of Access – you have the right to request a copy of the personal data that we hold about you;
- Right to Rectification – you have the right to correct the personal data we hold about you if such data is incorrect;
- Right to be Forgotten – in certain circumstances you can ask us to erase your personal data;
- Right to Restrict Processing – where certain conditions apply you can require us to restrict our data processing activities;
- Right of Portability – you have the right to have the personal data that we hold about you, that you provided us with, transferred to another data controller;
- Right to Object – in certain circumstances, you have the right to object to the processing of your personal data;
- Rights related to automated decision making – this relates to decisions solely made by automated means without human involvement process, such as direct marketing communication.
If you have any questions about how we use your personal data or you wish to exercise any of the above rights please contact our Privacy & Data Compliance Officer, as detailed at the end of this Policy.
Retention of Personal Data
We will only retain your personal data for as long as we have a lawful reason to do so. However, where we collect personal data as required by ani-money laundering legislation, including the identification, screening and report we will retain that personal data for between five and seven years after the termination of our contractual relationship unless otherwise required for legal purposes. In most cases we will retain your personal data for a period of seven years after the termination of our contractual relationship with you in case any claims arise out of the provision of our services to you.
Our site may from time to time contain links to and from the websites of our partner networks, advertisers and affiliates and if you follow a link to any of their websites please note that these will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Privacy & Data Compliance Officer
We may communicate with you in a number of ways, such as email, post, telephone or other electronic means. If you object to, or wish to stop receiving, any or all of these types of communications please contact our Privacy & Data Compliance Officer, as detailed below.
Similarly, if you have any question about our website, its content or this Policy please contact our Privacy & Data Compliance Officer, as detailed below.
Ebonstone’s Privacy & Data Compliance Officer is Judith Barrass, she can be contacted on firstname.lastname@example.org or 07824 806606 or you can write to her at Ebonstone Limited, The Old Byre, Sevington, Grittleton, Chippenham, Wiltshire SN14 7LD.