Privacy policy

Privacy Policy

Your privacy is important to us. So we've developed a Privacy Policy that covers how we collect, use, disclose, and store your personal information. Please take a moment to read through this policy and let us know if you have any questions.

By visiting www.primebrokerageinc.com you are accepting this policy.

primebroker Limited ("primebroker", "we", "us" or "our") is a Data Controller for the purpose of the General Data Protection Regulation. If you have any questions regarding how we manage your data, please contact us at [email protected] or you can call us on +44 749 077 5298. Our Data Protection Officer is Greg Steel.

 

What data we collect and why

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

primebroker collects your personal data directly from you and from third parties. In all cases primebroker must have a valid basis to process your personal information.

There are 6 ‘lawful bases’ under the data protection laws, of which 4 are relevant for your personal data and primebroker. These are:

• Consent – you agree to allow us to control or use this data
• Contract – processing is necessary for the contract between you and primebroker
• Legal obligation – processing is necessary to comply with the law
• Legitimate Interest - when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is

We rely on a legitimate interest to send you marketing communications about investment updates, new features, or any of our offers or promotion. These may include, but are not limited to, email, in-app notification, online through social media adverts, or adverts we place on websites you visit. Where you have the right to object to receiving such communications you can do so by clicking ‘unsubscribe’ in any marketing email we may send. Alternatively, you can contact our customer service team via online chat, secure messaging, email at [email protected] or by calling +44 749 077 5298 between 8am and 6:30pm Monday to Friday. You are also able to change or remove your preferences via your online dashboard within the profile section under ‘preferences’.

 

Information you give us

You may give us personal information about you by filling in forms on our website www.primebrokerageinc.com (our "Site") or by corresponding with us by phone, e-mail, post or instant chat. You may also provide personal information when you register to use our Site; subscribe to our services or contribute into a Junior ISA where you are not the registered contact; enter a competition promotion or survey; or when you report a problem with our Site.

The information you give us may include your name, address, date of birth, e-mail address and phone number, financial information, personal description, photograph, and other information which may be considered personal in that it may be used to identify you.  

By completing any of our forms on our Site you are signifying your explicit consent to primebroker collecting such information.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

Information we collect about you

When you visit our Site we may automatically collect the following personal information:    

Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.  We collect this personal data by using cookies, and other similar technologies.  Please see our Cookie Policy for further details.

Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

 

How we look after children’s data

We understand the importance of taking extra precautions to protect the privacy and safety of children. We will only collect necessary personal data of any child in relation to the application and administration of a Junior ISA, and only with express parental or guardian permission. Such data may include their name, date of birth and address.

The section “Your rights” within this Privacy Policy also apply to children and their personal data that we may hold.

 

Information we receive from other sources

We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, lead generation agencies) and may receive personal information about you from them.

 

How we use your personal information

 

  

Groups of Personal Information

We use different kinds of personal information, and we group them like this:

Type of personal information	Description
Financial	Your financial situation including but not limited to details of income, debts and savings.
Contact	Where you live and how to contact you.
Socio-Demographic	This includes details about your work or profession, nationality and where you fit into general social or income groupings.
Transactional	Details about payments to and from your accounts with us.
Contractual	Details about the products or services we provide to you.
Locational	Data we get about where you are, such as may come from your mobile phone or the address where you connect a computer to the internet.
Behavioural	Details about how you use our products and services.
Technical	Details on the devices and technology you use.
Communications	What we learn about you from letters, emails and conversations between us.
Special Category Data	The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so. Things like:   Racial or ethnic origin Genetic and bio-metric data Health data including gender Criminal convictions and offences Criminal records of convictions and offences Religious, political or philosophical beliefs
Social Relationships	Such as your marital status.
Open Data and Public Records	Details about you that are in public records, such as the Electoral Register, and information about you that is openly available on the internet.
Usage Data	Other data about how you use our products and services.
Documentary Data	Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, drivers licence or birth certificate.
Preferences	Any permissions, consents or preferences that you give us. This includes things like how you want us to contact you.
National Identifier	A number or code given to you by a government to identify who you are, such as a National Insurance number.

Sometimes the data we collect may be special category data for the purposes of applicable data protection laws. Special category data includes information about physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data. We take special care of this data in accordance with applicable data protection laws.

 

Who we share your personal information with

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found at www.cifas.org.uk/fpn.

To provide you with products and services we may share your personal data with the following organisations:

• Winterflood Business Services, who act as our custodian, trading facility and ISA manager
• LexisNexis, who we use to verify your identify and address, and to help combat financial crime
• Other companies within the Aviva Group
• Clearbank Limited, who provide banking services - Clearbank Limited Privacy Notice
• 3^rd parties that introduce you to us
• 3^rd parties we have integrated with and you have given us permission to share data with
• Messaging service companies (Optimove)
• Companies you ask us to share your data with, for example to facilitate ISA transfers
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others
• Analytics and search engine providers that assist us in the improvement and optimisation of our Site such as Google Analytics
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets
• If primebroker or its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions, and other agreements; or to protect the rights, property, or safety of primebroker, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

If you have been invited by a registered contact of a Junior ISA to become a contributor, your personal information such as your identity may be shared with them.  Under no circumstances will we share any payment account information with any other person.

 

Automated Decision Making

primebroker use systems to make automated decisions about you when signing up to primebroker. This is to ensure we are operating in line with relevant regulations and laws on how we conduct our business. We use automated decision making in assessing your suitability to invest with primebroker, and when completing background checks before accepting you as a customer.

 

How long we keep your personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes, and we may also use such data to enable us to respond to any future complaints, or to share information with the Financial Conduct Authority who regulate us.

  

Your rights

Right of access

Commonly known as a "data subject access request" – this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Please send any requests to [email protected].

 

Right to rectification

You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this. 

If you do, we will take reasonable steps to check its accuracy and correct it. You can contact us about this at [email protected] or by phoning +44 749 077 5298.

 

Right to be forgotten

You have the right to request deletion or removal of personal data where there is no compelling reason for its continued processing. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. There may be legal or other official reasons why we need to keep or use your data and we will notify you if any of these reasons are applicable in response to your request. But please tell us if you think that we should not be using it.

Right to portability

You have the right to obtain and reuse your personal data for your own purposes across different services. This allows you to move, copy, or transfer personal data in a safe and secure way from one IT environment to another.

Right to object

The right to object exists where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Right to restrict processing

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right to withdraw consent:

This right exists where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. Please be aware that if you withdraw your consent, we may not be able to provide certain products or services to you. If this is the case, we will tell you.

You are also able to change or remove your  preferences via your online dashboard within the profile section under ‘preferences’. Alternatively, you can contact our customer service team via online chat, secure messaging, email or telephone.

Storing and protecting your personal data

We are committed to ensuring that your information is secure.  In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

We use a secure server. All supplied sensitive information is transmitted via Secure Socket Layer (SSL) technology only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

 

We will only send your data outside of the European Economic Area (‘EEA’) to:

• Follow your instructions
• Comply with a legal duty
• Work with our suppliers who help us to run your accounts and services

If we do transfer your personal information outside the EEA to our suppliers, we will make sure that it is protected to the same extent as in the EEA. We’ll use one of these safeguards:

Where we transfer your data to other countries outside of the UK, we will do so on the basis of:

• Adequacy decisions, where a country has been deemed to provide adequate protections to individuals;
• Standard contractual clauses; or
• Other valid transfer mechanisms or derogations.

How to complain

Please let us know if you are unhappy with how we have used your personal information. You can contact us using by calling +44 749 077 5298 or live chat, or via secure messaging.  

You also have the right to complain at any time to the Information Commissioner’s Office. Find out on their website how to report a concern https://ico.org.uk/. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

If you'd like to find out more about our Cookie Policy, please click here.

 

Last updated: 03 June 2024