Privacy Policy

This policy describes how we use your personal information.

Introduction

Armila Capital Limited (ACL, we, us, our) is committed to safeguarding the privacy of the personal data we collect and process.

This Privacy Policy forms part of our commitment to be open and fair with all individuals whose personal data we process and to provide details around how we process such personal data and what we do with it.

For example, as part of the/our customer on-boarding process we will collect your personal data such as your name, address, telephone number, email address, employment details, financial information and passport details in order to verify your identify and, in some cases, assess your credit worthiness for the product for which you have applied. We do this as part of our legal obligations as a regulated provider of financial services and also to safeguard our business and our customers from fraud and other criminal activity.

If you have any questions, please contact:

Email: diana.wolff@armilacapital.com
Post: Armila Capital Limited, 7th Floor, 20 Berkeley Square, London W1J 6EQ
Telephone: 020 3595 4999

If we change anything important about this policy (the information we collect, how we use it or why we use it) we will highlight those changes at the top of the policy and provide a prominent link to it for a reasonable length of time following the change and prior to the change taking effect.

Who We Are

We are Armila Capital Limited.

Your personal data is collected by Armila Capital Limited. Armila Capital Limited is a company registered in England & Wales. Its company registered number is 8280584. The registered office address is 20 Berkeley Square, London W1J 6EQ.

Armila Capital Limited is authorised and regulated by the Financial Conduct Authority. Armila Capital Limited appears on the FCA Register under firm reference number 603601.

Scope

The scope of this Privacy Policy covers customers’ personal data in respect of the following:

  • Collecting personal data
  • Collecting personal data
  • Retaining personal data
  • Information we share
  • Where your information will be held
  • Your rights
  • Right to object
  • Security
  • Changes to this Privacy Policy
  • How to contact us

1. Collecting Personal Data

We will collect, store and use your personal data to facilitate your applications for services through our website or in person, to allow you to manage the service you have with us (including by submitting instructions online) and for the purposes set out in more detail in this section.

Certain types of personal data are more sensitive than others. “Special personal data” about you includes information about health, disability, race, ethnicity, criminal offences (or alleged offences), political opinions, biometrics or religion. We may collect and receive special personal data about you.

Your personal data may be shared with some third parties as is set out in more detail below.

What personal data we collect How we use your personal data Why we use your personal data
1. Information that you give to us as part of the customer on-boarding process, whether online, in-person or over the telephone including:

  • Your contact details including: your name, address, email address
  • Your bank account details and financial information
  • Your employment details
  • Your date of birth
  • Your national insurance number
  • Your gender
  • Your marital status
  • Your passport details
  • Your signature
  • The product / service purchased
We use this information to:

  • Process your application
  • On-board you as a customer and to help us ensure that our customers are genuine, to check whether our customers are politically exposed persons or are on sanctions lists, and to guard against money laundering, terrorist financing, fraud and other criminal activities
  • Conduct money laundering, financial and credit checks (which may be renewed from time to time)
  • Provide, manage and administer our products and services to you
  • Manage our relationship with you
  • Make payment to you or take payment from you
  • To communicate with you
  • regarding your account and our services
  • To provide advice or guidance about our products and services
  • Collect debts
  • Make necessary disclosures in response to requests, which we are legally required to comply with, to law enforcement or a regulatory authority, body or agency or in the defence of legal claims.
We use your personal data:

  • As it is necessary for the performance of our contract with you.
  • To meet our legal obligations in respect of Anti-Money Laundering laws and “Know your Customer” requirements. For example, if we suspect money laundering or terrorist financing, we must make a disclosure to the relevant authority
  • As it is in our legitimate interest and your legitimate interest that we protect you and ACL against fraud or criminal activity which might negatively impact your account or the products and services which we are providing
  • As it is in our legitimate interests to better understand the needs and concerns of our customers so that we may improve the products and services we offer and the way in which we provide our existing products and services as well as developing new products and services

2. Information that is given to us by you as an organisation as part of the customer on-boarding process, whether online, in person or over the telephone including:

  • Your contact details including: your name, address, email address
  • your position at the organisations, including details of your start date and the role held
  • Details of other positions held by you concurrently or in the past
  • Details of any previous disqualifications from acting as an officer or director of a Company

We use this information to:

  • To help us ensure that our customers are genuine, to check whether our customers are politically exposed persons or are on sanctions lists, and to guard against money laundering, terrorist financing, fraud and other criminal activities
  • Conduct money laundering, financial and credit checks (which may be renewed from time to time)
  • We use your personal data:

    • To meet our legal obligations in respect of Anti-Money Laundering laws and “Know your Customer” requirements
    3. Information when you communicate with us whether in person, through our website or via email, over the telephone, through social media or via any other medium, including:

    • Your contact details (which can include your email address or social media account details, depending on how you choose to communicate with us)
    • The details of your communications with us (including when you sent it, when we received it and where you sent it from, such as our website, post, telephone, email or social media) The details of our messages to you (including information that you may post on our social media platforms)
    We use this information to:

    • Answer any issues or concerns
    • Monitor customer communications for quality and training purposes
    • Develop new services which are based on the information you provide
    • Improve our services based on the information and feedback you provide and the information and feedback provided by others
    • Personalise our service to you to take account of the information and feedback you have provided
    • Make necessary disclosures in response to requests which we are legally required to comply with, to law enforcement or a regulatory authority, body or agency or in the defence of legal claims
    We use your personal data:

    • As it is necessary for the performance of our contract with you.
    • To meet our legal obligation to communicate with you regarding certain matters concerning your finances
    • As it is in our legitimate interests to better understand the needs and concerns of our customers so that we may improve the products and services we offer and the way in which we provide our existing products and services as well as developing new products and services
    4. Information that we collect from third party partners and corporate customers which includes:

    • Fraud prevention agencies
    • KYC (Know Your Customer/ KYB (Know Your Business) Providers
    • Financial Crime Prevention Providers
    • Compliance Providers
    • Payment processing companies
    • Your other financial services provider(s)
    • Your professional advisors
    • Other entities in our group
    • Publicly available sources such as the electoral roll
    We use this information to:

  • On-board you as a customer and to help us ensure that our customers are genuine, to check whether our customers are politically exposed persons or are on sanctions lists, and to guard against money laundering, terrorist financing, fraud and other criminal activities
  • Conduct money laundering, financial and credit checks (which may be renewed from time to time)
  • Verify our customers’ credit histories
  • Perform continual monitoring of your account(s) for fraud and crime prevention and detection purposes
  • Conduct internal risk assessments to determine whether we can provide you with our products or services
  • Provide, manage and administer our products and services to you, including opening and managing your account
  • Manage and administer our IT systems
  • Make payment to you or take payment from you
  • We use your personal data:

    • As it is necessary for the performance of our contract with you. For example, we will use your account details provided by your other financial services providers to transfer amounts in accordance with your instructions
    • To meet our legal obligations in respect of Anti-Money Laundering laws and “Know your Customer” requirements. For example, if we suspect money laundering or terrorist financing, we must make a disclosure to the relevant authority
    • As it is in our legitimate interest and your legitimate interest that we protect you against fraud or criminal activity which might negatively impact your account or the products and services which we are providing
    5. Information that we collect incidentally from other sources such as public sources, or from individuals representing organisations, including:

    • Information available in the media
    • Information presented on our social media or wider social media platforms including Facebook, Twitter and LinkedIn
    • Information collected by security systems
    • Contact details of individuals working for organisations
    • Other personal information regarding such individuals
    We use this information to:

    • Maintain market awareness
    • Build and maintain social media branding
    • Provide security to our premises
    • On-board you as a customer and to help us ensure that our customers are genuine, to check whether our customers are politically exposed persons or are on sanctions lists, and to guard against money laundering, terrorist financing, fraud and other criminal activities
    • Build relationships with other organisations
    • Provide marketing communications to these individuals
    • Improve our services and develop new services based on the preferences and behaviours of these individuals
    We use your personal data:

    • As it is in our legitimate interest to remain aware of updated market practice to ensure that we are offering a service which is competitive and meets the expectations of our customers
    • As it is in our legitimate interest to enhance our brand awareness and reputation which will help us to become more successful and to offer a greater variety of products and services to our customers.
    • As it is in our legitimate interest to monitor the areas around and within our premises to safeguard our employees, customers and members of the public against wrongdoing or criminal activity
    • To meet our legal obligations in respect of Anti-Money Laundering laws and “Know your Customer” requirements. For example, if we suspect money laundering or terrorist financing, we must make a disclosure to the relevant authority
    6. Shareholder and investor data. We collect and process personal data relating to our shareholders and investors which includes:

    • Your contact details including: your name, address, email address, identity document
    We use this information to:

    • Maintain an accurate record of our past and current shareholders
    • Communicate with our shareholders

    We use your personal data:

    • To meet our legal obligations in respect of corporate law

    2. Collecting Special Categories of Personal Data

    We have identified here the types of special categories of personal data and criminal data we may collect or receive, how we will use it and why we will use it.

    What special categories of personal data we collect How we use your special category personal data Why we use your special category personal data
    1. Special Categories of Information and Criminal Data that you give us or that we receive from you, your organisation or from third parties:

    • Passport details which may disclose details of your racial or ethnic origin (and nationality)
    • Information relating to criminal activity that is provided to us from third party organisations providing screening services
    • Other special categories of personal data which you provide to us whether in person, by telephone, in writing, by email or by some other form of communication
    We use this information to:

    • Process your application
    • On-board you as a customer and to help us ensure that our customers are genuine, to check whether our customers are politically exposed persons or are on sanctions lists, and to guard against money laundering, terrorist financing, fraud and other criminal activities
    • To make suspicious activity reports which include detailed information about transactions that are or appear to be suspicious to the relevant authorities or regulators
    • Conduct money laundering, financial and credit checks (which may be renewed from time to time)
    • Conduct internal risk assessments to determine whether we can provide you with our products or services
    • Provide, manage and administer our products and services to you
    • Respond to your questions, queries and / or complaints
    We use your personal data:

    • Where you have manifestly made this information public
    • Where the processing is necessary in connection with legal claims
    • Where we have collected your explicit consent for a particular processing purpose
    • Where the processing is in the substantial public interest. For example, we process special categories of personal data in connection with our background checks, Suspicious Activity Reports and sanction screening in order to prevent or detect unlawful acts

    3. Retaining Personal and Special Category Personal Data

    We will keep your information for as long as you are a ACL customer and for a period of time after you stop being a customer of ours.

    When you stop being an ACL customer, we will retain your personal data for a period of up to six years. We retain your personal data in this way to enable us to respond to any queries or complaints which you may have in the future and to maintain records in line with our legal obligations to do so.

    In certain circumstances we may also retain your personal data for longer than 10 years if this is necessary in connection with a legal, regulatory or contractual obligation.

    We will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

    In all cases, we will continue to protect your personal data in accordance with the terms of this Privacy Policy. We will also routinely refresh our information to ensure we keep it up-to-date.

    4. Information We Share

    There are certain circumstances where we transfer your personal data to employees, contractors and to other parties.

    • We share your information with certain contractors or service providers. They may process your personal data for us. Service providers include IT suppliers, database providers, backup and disaster recovery specialists and email providers.

      Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your personal data, will only be provided in connection with the performance of their function. They will not be permitted to use your personal data for any purposes other than those outlined in this Privacy Policy.

    • We also share your information with certain third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or services to you or for one of the other purposes set out in this Privacy Policy. These include, our professional advisors (including lawyers, accountants and auditors), UK Financial Services Compensation Scheme, HM Revenue & Customs, anti-fraud databases and agencies, organisations that introduce you to us, third parties associated or linked with your business, organisations that we introduce you to.
    • Your personal data may be transferred to other third party organisations in certain scenarios:
      • If we discuss selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
      • If we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you;
      • If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police; or
      • If we are defending a legal claim your information may be transferred as required in connection with defending such claim.
    • We do not sell, rent or trade any of your personal data.
    • We will not, without your consent, disclose or supply your personal data to any third party for the purpose of their or any other third party’s direct marketing.
    • Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

    5. Where Your Information Will Be Held

    Your information may be transferred outside the European Economic Area.

    Personal data that we collect is predominantly stored in the UK. Your personal data may be stored and processed in and transferred between any of the countries in which we operate, in order to enable us to use the information in accordance with this Privacy Policy.

    We will only transfer data to jurisdictions outside the scope of the European General Data Protection Regulation (GDPR) where the appropriate safeguards set out in the GDPR are in place.

    However, to ensure your personal information is properly protected in line with EU and UK data protection law, the transfer of this information is governed by a contract including Standard Contractual Clauses approved by the European Commission in accordance with Article 46(2) (c) of the General Data Protection Regulation.

    If you would like to obtain copies of the regulator-approved Standard Contractual Clauses please contact us at the e-mail address provided on the first page of this notice.

    6. Your Rights

    You have certain rights in relation to your information. The availability of these rights and the ways in which you can use them are set out below in more detail.

    Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact us at the e-mail address provided on the first page of this notice.

    • Access: you are entitled to ask us if we are processing your personal data and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and certain other information about it.
    • Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected.
    • Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.
    • Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
    • Transfer: you may request the transfer of certain of your personal information to another party.

    If you want to exercise any of your rights, please contact us at the e-mail address provided on the first page of this notice.

    You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually resident, where we are based or where an alleged infringement of Data Protection law has taken place. In the UK you can make a complaint to the Information Commissioner’s Office (Tel: 0303 123 1113 or at www.ico.org.uk).

    7. Right to Object

    You have a right to object to us processing your information in certain circumstances.

    You have a right to object to our processing of your personal data where this is based on our legitimate interests (or those of a third party). You may challenge our reliance on legitimate interests. However, we may be entitled to continue processing your personal data based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes.

    8. Security

    We are committed to keeping your personal data safe. We have physical, technical and administrative measures in place to prevent unauthorised access, loss, misuse or alteration of your personal data.

    We store all personal information on secure servers with relevant access and firewall controls.

    Any personal data sent to us, either in writing or email, may be insecure in transit and we cannot guarantee its delivery.

    9. Changes to this Privacy Policy

    This Policy will be changed from time to time.

    If we change anything important about this Policy (the personal data we collect, how we use it or why) we will highlight those changes at the top of the policy and provide a prominent link to it for a reasonable length of time following the change.

    We will also notify you in advance of the changes taking effect so that you understand what impact our changes may have on you.

    If you would like to access previous versions of this Privacy Policy please contact us at the e-mail address provided on the first page of this notice.

    10. How to Contact Us

    If you have any questions about this Policy, please contact us:

    By email: diana.wolff@armilacapital.com
    By post: Armila Capital Limited, 7th Floor, 20 Berkeley Square, London W1J 6EQ
    By telephone: 020 3595 4999