Privacy Policy

INTRODUCTION

Claymore Capital Management Limited (“Claymore”), is a registered company in England and Wales under registration number 13168186 with registered address at 4-7 Great Pulteney Street, London, United Kingdom W1F 9NA. Claymore is responsible for your personal information and remains committed to protecting your privacy. Pursuant to the Data Protection Act 2018 [as amended] (”DPA”), we have a legal duty to respect and protect any personal information we collect from you, and we will abide by such duty. Claymore is Authorised and Regulated by the Financial Conduct Authority

We take all safeguards necessary to prevent unauthorised access and we do not pass on your details collected from you to any third party unless you give us your consent to do so or as authorised by law. We are introducing this Privacy Policy to make it easier for you to find out how we collect, use, protect, and disclose your personal information and which rights and options you have in relation to the personal information we hold.

WHAT PERSONAL INFORMATION DO WE COLLECT?

Personal information we may collect include:

• Biographical information such as your photo, name, date of birth, gender, identification number, national insurance number, tax number, biometric identifiers, occupation, country of residence, residence status, and nationality.
• Contact information such as your address, telephone number, email address, website registration.
• Information relating to your employment history, education, family or personal circumstances and interests, where relevant.
• Information relating to your financial position such as bank account details, income, and source of wealth and source of funds.
• Information to understand your needs and objectives or to carry out your instructions.
• Information to assess whether you represent a politically exposed person, money laundering or negative publicity risk.
• Static and moving images of persons.
• Voice recordings of telephone conversations.
• Cookies and other/or tracking technologies to distinguish you from other users of our site and to remember your preferences but you can restrict these at any time. It provides you with an optimum user experience when you browse our site and allows us to monitor its performance on an ongoing basis. This information is aggregated and therefore anonymous.

HOW WE COLLECT PERSONAL INFORMATION

We will only collect information in line with relevant regulations and laws and that relate to services you apply for. You provide us with your personal information entirely voluntarily. However, there may be contractual conditions under which we will not be able to act or process your instructions without you providing the relevant personal information to us. We may have CCTV in operation which will capture footage of you whilst you are on the premises.

HOW WE USE YOUR PERSONAL INFORMATION

We will only use your personal information as allowed by law i.e. carrying out an instruction or agreement, fulfilling a legal obligation because we or a third party recipient have a legitimate interest or as agreed by you. A legitimate business interest to use your personal information may include:

• To comply with our legal obligations, including reporting and/or being audited by regulatory bodies.
• To analyse and improve our services and communication with you.
• To recognise and count the number of visitors and to see how visitors move around our website when they are using it to improve the way our website works.
• For marketing to you, but we do not share personal information with third parties for marketing purposes.
• For the management and administration of our business.
• For insurance purposes.
• Seeking advice on our rights and obligations.
• Protecting the security of our Information Technology and communication systems, website and other systems, preventing and detecting security threats, fraud and other criminal or malicious activities.
• To comply with court orders and or defend our legal rights.
• To detect, prevent or reduce the incidence of crime and create a safer environment.
• To assist with health and safety of employees, service providers and visitors and to assist with serious occurrences, for example, disciplinary investigations.

WHO CAN WE SHARE YOUR PERSONAL INFORMATION WITH

We may share your personal information with:

• Your agents, intermediaries and advisors with your permission.
• Third parties we engage to provide services to you such as agents, advisors, banks, brokers, insurers, or any third party to whom we assign or novate any of our rights or obligations.
• Professional advisors such as lawyers, auditors, accountants, IT software and hardware providers.
• Our data processors.
• Courts, regulators, and law enforcement agencies, where required.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We will keep your information for as long as you have a relationship with us. After it ends, we will keep your information as long as we may have a legitimate purpose or you withdraw your consent (where applicable) and we are not legally required or otherwise permitted to continue storing your data. In particular, we will retain your personal data:

• Where we have collected your personal information as required for anti-money laundering legislation
• To help us respond to queries or complaints
• To help us respond to requests from authorities
• For other reasons such as fighting fraud and financial crime

TRANSFERRING YOUR INFORMATION OVERSEAS

Your information may be transferred and stored as set out in this Policy to countries outside European Economic Area or to countries not approved as providing an adequate level of protection for personal information. This may include countries which do not provide the same level of protection for personal information. When this happens, we will ensure any such transfers are made subject to appropriate or suitable safeguards. Such transfers will occur where you have given explicit consent, or where the recipient has entered into standard contractual clauses.

YOUR RIGHTS

You have several rights relating to your information including to:

• Request a copy of the personal data we hold about you
• Ask us to share your personal date with another party
• Ask us to update incorrect or incomplete details
• Ask us to erase your personal information
• Object to or restrict our processing activities of your information
• Make a complaint
• Withdraw consent

UPDATES TO THIS PRIVACY POLICY

We reserve the right to update and change this Privacy Policy from time to time in order to reflect regulatory changes or changes to the way we process your personal information. In case of such changes, we post the amended Privacy Policy on our website. The changes will come into effect upon publication.

COMPLAINTS AND FURTHER INFORMATION

If you wish to submit a complaint or need further information in relation to this Policy, please contact the Compliance Officer.