Using your information
Data protection law requires us to determine on what basis we collect and use your personal information. If you are an Investment Professional or an Agent and you register on our website we will rely on a condition known as ‘legitimate interests’. This enables us to provide you with our services more effectively and to provide information we consider may be of interest to you. It also enables us to carry out market research and product development.
If you apply to become or you are a Bondholder then our lawful basis will be contract. This is because you will have formed a contract with us in order to invest money in the Bond.
Where do we get your personal data from
What information we collect
The information we collect is not limited to but may include the following:
- • Name
- • Contact information including email address and telephone numbers
- • Demographic information such as full postal address including postcode
- • Personal information for the purposes of carrying out an identity check which may require address history
- • Other information relevant to providing you with our service
- • Electronic identity checks and/or references as part of our Bondholder verification procedure
- • We may monitor and record telephone calls as part of our compliance and training procedures
- • If you invest in our Bond we will also collect details of your bank account including the account number and sort code.
What we do with the information we gather
We require this information mainly for the following reasons:
- • Internal record keeping
- • Proof that you are who you claim you are
- • We may use the information to improve our Bond application procedure
- • We may periodically send promotional emails or other information which we think you may find interesting using the email address which you have provided
- • From time to time, we may also use your information to contact you for market research purposes
- • We may pass your information to a third party if this is required for legal purposes or to prove your identity
- • To contact you as a Bondholder
- • To administer the Bond process
- • To enable the company to comply with any anti-money laundering, regulatory or tax requirements.
- • We may transfer your data outside of the European Economic Area but if we do where appropriate we will ensure that procedures are in place to ensure those to whom the data is transferred provide an adequate level of protection in respect of that data.
Sharing of your personal data
We may share your personal data with:
- • Other group companies and organisations to enable us to administer the Bonds. For example, if you invest in our Bond we will share your information with the Registrar and Receiving Agent, the Security Trustee, our legal or professional advisers, Accountants/Auditors and any organisation as required by law – for example HMRC.
- • We will also share information where appropriate to comply with the US Foreign Account Tax Compliance Act and OECD and any other organisation in any jurisdiction that seeks to implement a similar tax reporting regime.
- • We may also share your information with any organisation with whom we have a legal Introducer’s Agreement.
- • We may conduct an identity check with a reference agency to verify your identity and to prevent financial crime.
- • If you are an Investment Professional or agent we may share your personal data with any organisation with whom we have a legal Introducer’s Agreement.
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 collected online.
Part of these procedures may be to ask you security questions, if you telephone our office, prior to disclosing any information to you. We will not disclose your personal information to any third party other than as required to process an Application for a Bond.
Investment Professionals or Agents can also help to keep information secure by choosing a password that is unlikely to be guessed by anyone and should always ensure that they have logged out of the website before leaving their computer.
Controlling your personal information
Under data protection law you may request details of personal information which we hold about you – a subject access request. If you would like a copy of the information held on you please write to our registered address on the Contact Us section of the website. If you believe that any information we are holding about you is incorrect or incomplete, please write to or email us as soon as possible. We will promptly correct any information found to be incorrect. There will be no charge for a subject access request unless we consider the requests are excessive.
If you are a Bondholder we will maintain the information we have on you for as long as you are a Bondholder to enable interest payments to be made to you and thereafter as long as we are required by law. For other users we will retain the information for as long as you are registered on our website. If at any time you wish to unsubscribe please email firstname.lastname@example.org with ‘UNSUBSCRIBE’ in the subject heading.
All companies processing personal information must be registered with the Information Commissioner’s Office. The Information Commissioner’s Office (ICO) is the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals. The ICO enforces and oversees the Data Protection law, the Freedom of Information Act, the Environmental Information Regulations, and the Privacy and Electronic Communications Regulations. If you have a complaint you have the right to refer this to the ICO. A copy of our registration can be found at www.ico.gov.uk.
Data Protection Officer (DPO)
You can contact our DPO at:
William John Holdings Limited
71-75 Shelton Street
Last updated: 17 December 2019