REClosure

Privacy Policy and GDPR Compliance

I. COLLECTION OF CLIENT INFORMATION

Purpose and Scope of Data Collection:

Personal data is collected by REClosure Limited (“REClosure“) for specified, explicit, and legitimate purposes. The data collected will not be further processed in a manner incompatible with these purposes. It will be adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed. This includes compliance with legal and regulatory obligations, providing our services effectively, and, where applicable, marketing activities.

Sources of Client Information:

REClosure collects personal information about Clients from various sources, including:

  • Application Forms and Questionnaires: These include Client Profile Questionnaires, account forms, and other documentation provided by the Client. Information collected includes name, address, employment details, financial and investment qualifications.

  • Transactional Data: Data related to transactions on the platform, such as account balances, investments, and fees.

  • Interactions with Staff: Any other interactions with REClosure, such as discussions with our staff or communications.

  • Verification Services: We utilise verification services and consumer reporting agencies to assess a Client’s creditworthiness or credit history, generally before establishing a business relationship.

Marketing and Consent:

Opt-In for Marketing Communications:

  • Explicit Consent for Marketing: We value your privacy and autonomy in choosing how your personal data is used. REClosure will use your personal data for marketing purposes such as sending information about our products and services only if you have explicitly consented to receive these communications.

  • Process of Opting In: To receive marketing communications you can provide your explicit consent through checkboxes on application forms, a dedicated subscription page on our website, or other clear methods. This process will be in clear and plain language, separate from other general matters, ensuring that your consent is freely given, specific, informed, and unambiguous.

  • Consent for Multiple Purposes: If we intend to use your data for multiple marketing purposes, we will seek your consent for each purpose separately, ensuring you have complete control over how your data is used.

Management of Consent:

  • Record of Consent: REClosure will maintain records to demonstrate that consent has been given by you, the data subject, for the specific purposes of marketing communications.

  • Withdrawing Consent: You have the right to withdraw your consent at any time. We will provide clear information on how to withdraw your consent e.g., via an unsubscribe link in emails, through your account settings on our website, or by contacting our data protection officer.

  • No Conditional Services: The provision of specific services by REClosure will not be conditional upon your consent for marketing purposes. We ensure that your consent is freely given and that you have the choice to opt-in or opt-out without any impact on the services you receive from us.

Data Accuracy and Verification:

REClosure will take all reasonable steps to ensure and maintain the accuracy of the personal data collected. Clients are encouraged to regularly update their information to ensure its accuracy.

II. DISCLOSURE OF NON-PUBLIC PERSONAL INFORMATION

  • Data Processing and Compliance: Personal information will be processed by the REClosure and other third party delegates, agents and data processors and in accordance with GDPR and applicable Data Protection regulations and guidance in Ireland, where applicable.

  • Purposes of Data Processing: We process personal data for carrying out services on behalf of entities, to comply with legal obligations under company law, anti-money laundering legislation, and other regulatory or tax requirements.

Data Disclosure Practices:

  • Disclosure to Third Parties: Personal information may be disclosed to third parties as necessary to ensure compliance with regulatory obligations. This includes auditors, regulators, or other necessary entities, particularly for anti-money laundering purposes or for meeting other regulatory requirements.

  • Scope of Data Sharing: REClosure, along with our delegates, auditors, legal advisors company/ secretary, and their authorised agents, may share non-public personal information, without a Client’s consent, in specific circumstances:

    – to manage and administer holdings in REClosure and any related accounts on an ongoing basis;

–  when the Client has given consent for specific purposes;

–  for conducting statistical analysis and market research; and

–   to comply with legal and regulatory requirements applicable to either or both REClosure (its                      delegates) and the Client.

Transfers of Personal Data:

International Data Transfers: REClosure generally does not transfer personal data to countries outside of the European Economic Area (EEA) in the normal course of business. If such transfers are necessary, they are carried out with appropriate safeguards in place, ensuring compliance with GDPR and applicable data protection laws.

III. FORMER CLIENTS

The same Privacy Notice applies to former Clients.

  • Continued Privacy Protection: The privacy protections outlined in this Notice extend to our former clients. REClosure are committed to maintaining the confidentiality and security of personal information of our former clients in accordance with GDPR and relevant data protection laws.

  • Data Retention for Former Clients: Personal data of former clients will be retained only as long as necessary for compliance with legal obligations, and in accordance with our data retention policy.

IV. PROTECTION OF CLIENT INFORMATION

  • Security Measures: REClosure employs physical, electronic, and procedural safeguards to protect client information. This includes, but is not limited to, encryption of data, secure data storage facilities, and strict access controls.

  • Restricted Access: Access to personal and account information of clients is strictly limited to those employees and delegates who require this information to perform their job responsibilities. Regular training and awareness programs are conducted to ensure adherence to these privacy standards.

  • Data Security in Partnerships: When working with third-party service providers or delegates, we enforce stringent data protection and confidentiality agreements to ensure that they uphold the same high standards of data security and privacy as REClosure.

  • Ongoing Review and Updates: Our security policies and practices are regularly reviewed and updated to address new threats and changes in data protection legislation, ensuring continuous protection of client information.

V. FURTHER INFORMATION

  • Rights to Modify Privacy Notice: REClosure reserves the right to update or modify this Privacy Notice as necessary to remain compliant with the General Data Protection Regulation (GDPR) and any other applicable data protection laws. We are committed to ensuring that our privacy practices remain up-to-date and reflective of current regulations and best practices.

  • Nature of Information in This Notice: The content of this Privacy Notice includes examples and extracts from our comprehensive GDPR policy. These are illustrative and are not intended to be exhaustive. Our full GDPR policy is available upon request.

Rights of Individuals Regarding Data Processing:

  • Purpose and Recipients of Data: Individuals have the right to request information about the purpose of data processing and the recipients of their data.

  • Data Retention Periods: Information regarding the specific retention periods for different types of data is available upon request.

  • Rights to Rectification and Erasure: Individuals have the right to request rectification of inaccurate data or erasure of their data under certain conditions.

  • Right to Object and Lodge Complaints: You have the right to object to the processing of your data and the right to lodge a complaint with the Data Protection Supervisory Authority.

  • Automated Decision-Making and Profiling: Details about any automated processing or profiling using your data will be provided upon request.

  • Sources of Data: Information on the sources from which your data was obtained will be made available if requested.

  • Timely Response to Requests: REClosure will provide the information requested without undue delay. We aim to respond to such requests within one month of receipt, in line with GDPR requirements.

Contact Information for Data Requests: To make a request regarding your personal data, or for any questions about this Privacy Notice or our data processing practices, please contact our Data Protection Officer at info@reclosure.net.

REClosure will provide the information requested without undue delay, and at the latest, within one month of the receipt of the request.

VI. COOKIES

Understanding Cookies:

Definition and Function of Cookies: A cookie is a small piece of data sent from a web server to your web browser, which is then stored by the browser. The cookie is sent back to the server each time the browser requests a page, allowing the web server to identify and track the web browser.

Types of Cookies We Use

 

  • Session Cookies: These are temporary cookies that remain in your browser’s cookie file until you close the browser. We use session cookies to keep track of you while you navigate our website.
  • Persistent Cookies: These remain stored on your computer even after closing the browser. Persistent cookies help our website recognise you as a visitor and remember your preferences for future visits. They will remain until they are either deleted or reach their specified expiry date.

Managing Cookies:

Most web browsers allow you to control cookie preferences. You can set your browser to refuse all cookies or to accept only certain types of cookies. Please note that blocking all cookies might negatively impact the usability and functionality of our website. If you choose to block cookies, some features may not work as intended.

Consent and Control

  • User Consent: We will obtain your explicit consent before using any non-essential cookies. A cookie banner or pop-up will appear when you first visit our website, allowing you to choose whether to accept or reject cookies. The banner will provide information on the cookies used and a link to our Cookie Policy for further details.
  • Granular Consent: Our cookie banner allows you to choose which types of cookies to accept. You can opt for essential cookies only or customise your choices to include or exclude analytics, marketing, or other cookies.
  • Withdrawing Consent: You can withdraw your consent to cookies at any time. This can be done through your browser settings or by changing your cookie preferences on our website.
  • Cookie Policy: Our Cookie Policy contains additional information about the cookies we use, including their purposes and how to manage them. This policy is linked from our cookie banner and website footer for easy access.

Further Information

If you have any questions about our use of cookies, please contact our Data Protection Officer at info@reclosure.net.

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