Data Privacy And Information Security Notice

Your privacy and security matter to us and we are committed to protecting your personal information from unauthorized access or use. Banking Circle US collects and maintains certain personal data or personally identifiable information (“PII”) related to its clients (for example, directors, employees, beneficial owners, authorized signors, or trustees) to comply with Customer Identification Program rules, regulations, and laws. If you provide Banking Circle US with PII on your associated persons, the information contained in this privacy notice should be forwarded to those individuals or you should advise them accordingly.

PII includes but is not limited to: name, address, contact details, date of birth, nationality, photograph, signature, job title, and tax residency. It can also include information obtained for the purpose of Know Your Client (KYC) procedures (which can include but is not limited to sanctions checks, criminal convictions and offenses, and politically exposed person checks).

Disclosure of your personal data to third parties

We may from time to time, in accordance with the purposes described above, disclose your PII to other parties, including service providers, courts and regulatory, tax and governmental authorities and third parties in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business. Some of these persons will process your personal data in accordance with our instructions and others will themselves be responsible for their use of your personal data. These persons may be permitted to further disclose the personal data to other parties.

For Transfers of your personal data to the United States

Where personal data is transferred from the EU or any OECD country to the United States (“US”), we will ensure that the transfer is subject to appropriate safeguards or is otherwise permitted under applicable law. Banking Circle US relies on standard contractual clauses which require us to protect the PII.

Retention and Protection of PII

PII stored on Banking Circle US’s network is protected from unauthorized access, treated as confidential, and handled according to the terms of the Banking Circle US Privacy and Information Security Policy, a copy of which is available upon request.

Your Data Protection Rights

You have a number of legal rights in relation to the PII held by Banking Circle US. These rights include the following:
(i) the right to access your data;
(ii) the right to examine and correct your data;
(iii) the right to restrict the use of your data;
(iv) the right to withdraw any consent given to the processing of your data (where applicable);
(v) the right to receive information regarding any entities to whom we disclose your data;
(vi) the right to be forgotten (right of erasure of personal data);
(vii) the right to data portability;
(viii) the right to lodge a complaint with the Office of the Data Protection Commissioner and Applicable U.S. privacy laws in your jurisdiction

You also have the right to object to the processing of your data where we have considered this to be necessary for the purposes of our legitimate interests. Please note that the right for your data to be erased (the “right to be forgotten”) that applies in some contexts is not likely to be applicable to most, if not all, of the personal data held by us, given the specific nature of the purposes for which the data is used, as described above.

If you have any questions or concerns about data privacy, you may contact the Chief Compliance Officer to discuss the management, retention, revision, or deletion of your data. Banking Circle US further attests that should a breach occur, management will promptly act to secure information, mitigate the breach, and notify you, no later than 72 hours after, of any compromised data.

State Privacy Laws

In addition to the federal laws concerning the collection and use of PII that are applicable to financial institutions, some states have privacy laws and regulations that supplement these federal laws and provide additional rights to citizens of those states. Please contact the Chief Compliance Officer for any questions.