We understand that you trust us with your personal information and we are committed to ensuring you can manage the privacy and security of your personal information yourself.
By “personal information”, as defined under GDPR, Astarte means your personal and sensitive personal data held by Astarte now and in the future. Personal information relates to such information as your name, address, contact details, investment profile and employer’s contact details. Astarte will not store and process sensitive personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.
With respect to the personally identifiable information that ends up in our possession, we commit to giving you the ability to do all of the following by sending an e-mail to firstname.lastname@example.org or calling us on +44 203 696 8260. Our security procedures mean that we may request proof of identity before we reveal information, including your e-mail address and possibly your address.
- You can verify the details Astarte maintains about you.
- You can contact Astarte to change, correct or delete your personal information controlled by Astarte. However, Astarte may retain archived copies of your information as required by law or for legitimate business purposes (as described in GDPR Art.16-17).
- You can also contact Astarte to request the restriction of processing of your personal data (under the conditions described in GDPR Art.18).
- You can request a readable copy of the personal data we hold on you at any time. To do this, please contact us by telephone as we will need to verify your identity. The data will be provided in plain text or CSV format.
Please note, we are constantly reviewing how we process and protect data. Therefore, changes to our policy may occur at any time. We will endeavour to publicise any changes.
More details on your rights follow.
Astarte entities, branches and representative offices may store and process your personal information for the following purposes:
- to provide you with financial services and products
- to manage the services and products that Astarte provides to you
- to conduct Astarte’s business
- to comply with applicable laws including, without limitation, anti-money laundering and anti-terrorism laws and regulations
The lawful basis for Astarte processing your personal information in the ways described above will typically be in order to:
- fulfil a specific purpose towards you after having received your clear and defined consent
- fulfil Astarte’s contractual obligations towards you
- support Astarte’s legitimate business interests, namely conducting and improving our business and services
- comply with a legal or regulatory obligation to which Astarte subjects
In providing you products and services Astarte may disclose your personal information to the following:
- anyone to whom you authorise Astarte to disclose information, including third party providers
- any fraud avoidance scheme in which Astarte participates
- other organisations to make background checks and enquiries about you as part of Astarte’s due diligence process
- any person to whom Astarte proposes to transfer its business, an asset or class of assets
- Astarte’s service providers, agents and associates
- any government entity, regulatory authority or to any other person Astarte reasonably thinks necessary for purposes stated
Your personal information may be transferred to countries or territories outside the European Union and EEA where it will be processed for the purposes set out above. Cross-Border Information Transfers may only take place if the transfer is made to an Adequate Jurisdiction (GDPR Rec.101-116; Art.44,45) or the data exporter has implemented a lawful data transfer mechanism.
Astarte will hold your information for as long as is reasonably necessary for the purposes listed above or as required by local applicable law. Usually we will hold your information for the duration of your relationship with us. Once your relationship with us has ended, information will continue to be held for as long as required by relevant laws and regulations or for twelve years including all papers and files (mainly but not limited to corporate documents and contractual agreements).
You also may request details about your personal information that we hold about you, the purposes for which it is being or will be processed and the recipients or classes of recipients to whom it is being or will be disclosed. To request such details, please send a written request to Astarte’s registered office (https://astartecp.com/contact). Astarte may charge an administration fee of up to the legal maximum at the time of the request.
In addition, you have the right to complain to the relevant data protection supervisory authority in the UK which is ICO (more information can be found on https://ico.org.uk/concerns/) if you have concerns about your personal information. If you have such concerns, we request that you initially contact so that we can investigate, and hopefully resolve, your concerns.