Equiniti Financial Services Limited (EFSL)

• To manage and operate your account with us to facilitate the provision of products and services, this includes retaining records of your instructions and telephone calls and keeping your account records up to date.
• To complete any transaction that you instruct us to undertake, and any legal obligations we have in relation to the transactions. As part of account opening, we are legally obliged to confirm your identity before we can accept your application.
• To provide you with transaction records / confirmation notices and statements as required by the service.
• To respond to any complaints and / or data rights that you invoke.
• To notify you about changes to our service and to send you service emails relating to your account.
• Processing our fees, charges, and any interest due on your accounts. Enforcing or obtaining settlement of debts owed to us or in relation to investments made on your behalf.
• For certain types of accounts, we also define our customers to facilitate the calculation of fees.
• To keep our websites and portals secure and permit you safe access to our services.
• To comply with the Financial Conduct Authority and Financial Crime regulations.

• Contractual
• Consent
• Legal Obligation
• Legitimate Interests

• Identifying if any of our products or services may be of interest to you and making suggestions and recommendations to you about them.
• To administer any prize draws that you are offered and elect to enter as an incentive to operate your account, for example as part of electing to receive dividends by BACS rather than by cheque.
• To ask you if you wish to hear from other entities within the Equiniti Group that offer complimentary financial services such as foreign exchange services.

IMPORTANT

You can withdraw from EFSL marketing and/or prize draw offers at any time. Please contact us if you wish to update your preferences.

EXCEPTIONS

In limited circumstances, and dependent upon the account that you hold, you many receive marketing communications from the company which you hold shares in. This marketing will be clearly marked as issued by the company, however, another part of the
Equiniti Group may assist in the delivery of those messages. In these instances, you will need to opt out of marketing with the company concerned using the details contained within the message as they are not EFSL marketing messages.

• Consent

Understanding our customers:

We can place you into groups of customers with similar interests, account patterns and preferences. These are called customer segments. We can also use a customer insight technique which analyses past observations to predict future behaviour. This is called propensity modelling. These activities are used to predict how we can best deliver our service to you as well as tailor our product or service offerings and contact you efficiently and effectively with information that is relevant to you.

• Legitimate Interests

Common examples of when we do this are noted below:

• Account Opening: We are required to check that you meet the requirements of the account you have selected, to do this we can use, and validate, personal data about you such as your age, residency, nationality and financial position.
• Account Pricing: We can analyse the transactions you have undertaken in a predetermined period to calculate what we charge for some products and services.
• Credit checks: We use credit reference agencies for account purposes including confirming your identity or implementing trading limits. The decisions we make are based on the information you have supplied, that we already hold and from the credit reference agencies who separately hold information about you, or from policy decisions taken by Banks, card and payment processing centers. This includes rejecting trades if they fall outside of your agreed trading limit. To resolve any issues arising you may have to speak to these agencies directly.

You can ask to have one of our staff to review any automated decision about you at any time.

• Contractual
• Legitimate Interests

Financial crime and money laundering:

We analyse your personal data for financial crime, money laundering and fraud risk purposes in accordance with UK and EEA regulations which are placed upon us. This can include:

• Confirming your identity (Credit Reference agencies – see above).
• Verifying your bank details.
• Using fraud prevention agencies. We study and learn about how you use our products and services and use this information to better detect fraud or unusual activities. We do this with fraud prevention agencies.
• Analysing our databases, investigating, detecting and report financial crimes as well as taking measures to prevent financial crime.
• Developing and improving our financial crime controls.

• Contractual
• Legal Obligation
• Legitimate Interests

• To identify service improvements such as when troubleshooting, undertaking data analysis, testing new products, using your personal data for research, statistical and survey purposes.
• To ensure that content from our websites is presented in the most effective manner for you and for your device.
• To develop and manage our products, brands, and services and to calculate how we should structure any fees and charges.
• How we manage and work with other companies in the delivery of your products and services.
• To study how you and our other customers use our products and services.
• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, which can be based on your activity on our website(s) or the website of another Equiniti Company or third parties’ websites. We can do this ourselves or appoint an agency to do this on our behalf.

• Contractual
• Consent
• Legal Obligation
• Legitimate Interests