DB Finser | Privacy Policy — How We Protect Your Data

1. Respecting Your Privacy

We respect the confidentiality of information and the privacy of individuals. This Privacy Policy outlines how DB Finser manages, handles and protects the personal information and data it holds about you, including information and data that DB Finser collects during the course of providing its products and services to you and information and data that DB Finser holds after the relationship is terminated. This Privacy Policy also applies to information and data that DB Finser collects from third parties, including information and data received through credit reporting bodies or agencies.

This Privacy Policy contains information about how you can access and control the information DB Finser holds about you, how you can ask DB Finser to correct your information, and how you can make a complaint if you have concerns about how DB Finser has managed your information.

Any reference to "us", "our", "we", or "it" in this Privacy Policy is a reference to DB Finser as the context requires unless otherwise stated. Similarly, any reference to "you", "your", "yours" or "yourself" in this Privacy Policy is a reference to any of DB Finser's customers, potential customers, shareholders and others, as the context requires unless otherwise stated.

This Privacy Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices, and to make sure it remains appropriate to the changing environment. Any information we hold will be governed by the most current Privacy Policy displayed on our website. In addition, over the course of our relationship with you, we may tell you more about how we handle your information. You should also review those statements as they may contain more specific detail.

2. Collecting Your Personal Information

We collect personal information and data about you in order to perform various functions and activities effectively. If we do not collect your personal information, we may not be able to deal with you or provide you with a product or service. Due to the nature of the products and services that we provide and our associated regulatory obligations, we do not have the option of allowing you to deal with us on an anonymous basis. We also collect your personal information where the law requires us to do so.

We obtain most of the information directly from you through our application or other forms, and from maintaining records of information provided in the course of ongoing customer service. For example, you will need to provide us with your information when you open a trading account, fill in an application form, deal with us over the phone, send us a letter, or use our website.

Information We Collect May Include:

Full name and contact details (address, telephone number, email)
Date of birth and identification documents
Tax file number or other tax identification numbers
Annual income and other financial details
Employment details and occupation
Transaction history and trading activity
Investment experience and objectives
IP address and device information

3. Collecting Information From Third Parties

There may be occasions when we collect personal information about you from a third party. We may collect personal information about you that is publicly available, including information from telephone directories, the electoral roll, or other relevant websites. For example, we may collect personal information about you from:

Credit reporting bodies and other credit providers, to collect information about the products they provide to you and your credit history
Organisations we have an arrangement with to jointly offer products
Marketing companies, to collect information about you so we can provide you with a product or service that may be of interest to you
Brokers and other related entities who may have introduced you to us

We may also collect information and data about how you use our website and other websites to help us better tailor our services to you. For example, we may automatically do this when you click on a link from our website, visit an external website displaying a DB Finser advertisement, or when you log onto our online portal or service. Any disclosure and processing of this information will be in accordance with this Privacy Policy.

4. Collecting Sensitive Information

In this Privacy Policy, "Sensitive Information" refers to personal information about a person's racial or ethnic origin, political opinion, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, genetic information, or health information.

We will not collect, use or disclose sensitive information about you unless we need the information for one of our functions or activities (or when we are legally required to do so) and we have already obtained your consent.

If you provide us with personal information that we have not requested, we will only retain the information that we are otherwise entitled to hold because of the products and services we provide. However, if this additional information is surplus to our requirements but is provided in a manner where it is combined with information that we are required or entitled to retain, you acknowledge that this unsolicited information may be held by us in the same manner as the balance of your personal information.

5. Using Your Personal Information

We may use personal information we collect about you where there is a legal basis to do so, where that information is necessary to carry out obligations arising from agreements between you and DB Finser, or where it is within our legitimate interest to do so.

We may use your personal information for several purposes including:

To consider your request for a product or service
To enable us to provide a product or service
To tell you about other products and services that may be of interest to you
To assist in arrangements with other organisations in relation to the promotion or provision of a product or service
To manage accounts or perform other administrative and operational tasks, including risk management, systems development and testing, credit scoring, staff training, collecting debts, and market or customer satisfaction research
To consider any concerns or complaints you raise against DB Finser and to manage any legal action between you and DB Finser
To prevent or investigate any actual or suspected fraud, unlawful activity, or misconduct
To identify you or establish your tax status under any foreign legislation, regulation, or treaty pursuant to an agreement with any tax authority
As required by relevant laws, regulations, codes of practice, and external payment systems

As part of our service to you, we may use personal information we have collected about you to let you know about products and services, promotions, and other opportunities in which you may be interested. We may contact you from time to time about new or existing products or services. We may also disclose your personal information to related entities or business partners to enable them to tell you about a product or service. Depending on the situation, and where these activities do not arise from our legitimate interests, your consent will be required.

You may contact DB Finser at any time if you do not wish to receive such communications. Please note that we do not use any information received about you through the credit reporting system for marketing purposes.

6. Sharing Your Personal Information

Depending on the product or service concerned and particular restrictions on sensitive information, when it is necessary, we may need to share or disclose personal information about you to the following organisations:

Any related entities of DB Finser worldwide which provide financial and other services for DB Finser
Service providers and specialist advisers contracted to provide DB Finser with administrative, financial, taxation, insurance, research, or other services
Credit reporting or reference agencies
If you were introduced to DB Finser by a third party, we may disclose personal and account information about you to them, their related companies, and their licensee or authorised representatives
Credit providers, courts, tribunals, and regulatory authorities as agreed or authorised by law
Anyone authorised by an individual, as specified by that individual or the contract

If there is disclosure of your personal information to an organisation not listed above, we will first obtain your free and informed consent. In some circumstances, the nature of the product or service you request may require us to disclose your information overseas. When we disclose your information, including cross-border disclosures, we take measures to ensure your information is treated in accordance with the standards that apply in our jurisdictions and, where applicable, with data regulation legislation.

7. Obtaining Your Consent

We may require your consent to use and disclose personal information about you in particular ways. For example, we need your further consent if we need to use your information for a purpose that is not related to the purpose for which we originally collected it.

Depending on your circumstances, the consent may be express (for example, you expressly agree to the specific use of your information by ticking a box) or implied by some action you take or do not take (for example, your agreement is implied by the fact that you have agreed to your product terms and conditions, which contains information about the use or disclosure of your information).

8. Use of Cookies and Other Tracking Technology

Our website has links to external third-party websites that may benefit you. Please keep in mind that these third-party websites are not covered by this Privacy Policy and are not subject to our privacy standards and procedures.

We use cookies to give you access to certain pages of our website without having to log in each time you visit. We may also use independent external service providers to track the traffic and usage on our website. Cookies are small pieces of text stored on your computer to help us determine the type of browser and settings you are using, where you have been on our website, what you have downloaded, where you came from, and to ensure your information is secure. The purpose of cookies is to provide you with a more relevant and effective experience on our website, including presenting web pages according to your needs or preferences.

Cookies are frequently used on many websites and you can choose if and how a cookie will be accepted by changing your preferences and options in your browser. Please note however that you may not be able to access some parts of our website if you choose to disable cookie acceptance in your browser, particularly the secure parts of the website. We therefore recommend you have cookies enabled to benefit from all the services available.

We are constantly improving the functionality of our website. This may mean a change to the way in which personal information is collected or used. The impact of any technology changes which may affect your privacy will be reflected in updates to this Privacy Policy.

9. Management of Personal Information

DB Finser takes all reasonable precautions to protect your personal information and data from misuse and loss, and from unauthorised access, modification, and disclosure by ensuring that your personal information can only be accessed by people properly authorised to have access.

We train staff who handle your personal information to respect the confidentiality of customer information and the privacy of individuals. We regard breaches of customer privacy very seriously and will impose appropriate penalties accordingly.

Your personal information is stored in a combination of secure computer storage facilities and paper-based files and other records. Irrespective of the format of the information, we take steps to protect the personal information we hold from interference, misuse, loss, unauthorised access, modification, or disclosure. We maintain physical security over our paper and electronic data stores and premises, and maintain computer and network security including firewalls, identification codes, and passwords to control access to computer systems. We continually maintain and monitor our online security systems to ensure our online services are secure and that your personal information is appropriately protected when you use these services.

Your personal information may also be processed by us and our third-party service providers outside our primary jurisdiction, with appropriate safeguards in place to ensure data protection.

10. Protecting Your Privacy

You can help DB Finser protect your privacy by staying informed about our security requirements and contacting us immediately if your contact details change.

We also require you to keep your personal customer information such as passwords and user details confidential and secure at all times. This means you should not disclose your personal user information to any other person. You should contact DB Finser immediately if you believe that your personal user information may have been disclosed to another person, or if you would like to change your password or user details.

11. Accessing Your Personal Information

You have the right to find out what personal information we hold about you, including what information we have obtained through the credit reporting system. You should contact DB Finser if you wish to find out about the personal information we hold about you. Please note that your request should be made in writing for security reasons and we may need to verify your identity before giving you access. We are generally able to deal with your request immediately. However, if the request is complex, it will be dealt with within 14 to 30 business days.

Depending on the complexity of your request, we may need to charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing, and copying any material requested. If the information sought is extensive, we will advise you of the likely cost in advance and can help to refine your request if required.

12. Correcting Your Personal Information

If you believe that the personal information DB Finser holds about you is inaccurate, incomplete, or out-of-date as a result of changes of address or other personal circumstances, you should contact us as soon as possible.

We will promptly update any personal information that is inaccurate, incomplete, or out-of-date. We can update your personal information over the telephone or by email from your registered email address. Please note that we will need to confirm your identity before making any amendments.

Privacy Policy