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Privacy Policy

Online privacy statement

1. Scope

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

2. Responsibilities

2.1 The Data Protection Officer / GDPR Owner is responsible for ensuring that this notice is made available to data subjects prior to Coe Solutions collecting/processing their personal data.

2.2 All Staff of Coe Solutions who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

3. Privacy notice

3.1 Who are we?

Coe Solutions provides clients with financial support through our in-depth knowledge and wealth of experience.  Our services are based on our professional and personalised service and attention to detail, which sets us head and shoulders above the rest.

An overview of our financial services are listed below:

Services Overview

  • Multi-currency IBANs
  • Deliverable foreign exchange
  • Multi-currency card acquiring
  • Patented payments infrastructure facilitating subscriptions to ITOs/STOs with cards
  • Local and cross border payments
  • Services are offered digitally, via our cloud native platform

Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:

The personal data we would like to collect from you is:

Names, Date of birth, Addresses, Telephone numbers, Mobile numbers, Email addresses, Job titles, Business sites/companies, Director(s) details, Company employees’ details, Bank details, Contractual information, Customer ID, Supplier ID The collection of these personal data will depend on the category of customer we have a business relationship with and in line with our AML Policies. See below:

Retail Customers:

For every retail transactions between £5,000 and £7,000 over the counter, it is company policy to input customer’s details (first name, surname, date of birth and nationality) into our trading system.

For every retail transactions over £7,000, collect the following: first name, surname, date of birth, nationality, address, and source of funds in the form of Bank statement, pay slip or letter from an accountant/solicitor.

Wholesale Customers:

At the onset of onboarding a new wholesale customer, we take the following personal data:

Company Director’s details – Name, Date of birth, address, passport details, telephone numbers. We also obtain further data such as directors other affiliations from publicly accessible sources like companies’ house.

Company’s Employees Details – Name, Date of birth, address. We also obtain further personal data from publicly accessible sources such as the UK sanctions list.

Company’s Address – Location of all branches, telephone numbers and email addresses. Further personal data are also from publicly accessible sources such as the UK sanctions list.

The personal data we collect will be used for the following purposes:

  • To fulfil Coe Solutions contractual obligation to its customers
  • To process transactions as requested by the customer
  • To undertake transaction ongoing monitoring as required by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017

Our legal basis for processing for the personal data:

  • Consent: the customer has given clear consent for Coe Solutions to process their personal data for a specific purpose.
  • Contract: the processing is necessary for a contract Coe Solutions has with the customer, or because they have asked Coe Solutions to take specific steps before entering into a contract.
  • Legal obligation: the processing is necessary for Coe Solutions to comply with the law. That is the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (not including contractual obligations).
3.2 Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for Coe Solutions to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

The customer may withdraw consent at any time by an unambiguous indication in form of a statement or by a clear affirmative action, signifying withdrawal of consent to the processing of personal relating to the customer.

3.3 Disclosure

Coe Solutions will not pass on your personal data to third parties without first obtaining your consent and provide you with the reason why the details need to be shared.

3.4 Retention Period

Coe Solutions will process personal data for the duration of its business relationship with the customer and will store the personal data for five (5) years following the end or termination of the business relationship.

According to the HMRC guidance for MSB money laundering supervision, the following is required:

Coe Solutions must keep records of customer due diligence checks and business transactions:

  • for 5 years after the end of the business relationship
  • for 5 years from the date an occasional transaction was completed
  • Coe Solutions should also keep supporting records for 5 years after the end of a business relationship
  • Coe Solutions should keep records from closed branches or agents

The records should be reviewed periodically to ensure, for example, that a fresh copy of expired documents, such as driving licenses or passports are held. This review need only include ongoing relationships.

Coe Solutions are not required to keep customer transaction records that are part of a business relationship for more than 10 years, where a business relationship is ongoing.

After the period above the records must be deleted unless Coe Solutions are required to keep them in relation to legal or court proceedings or any other legislation.

3.5 Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that Coe Solutions refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
3.6 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Coe Solutions, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Coe Solutions data protection representatives.

The details for each of these contacts are:

Contact Name: Information Commissioner's Office Claire Pluckrose
Address: Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Coe Solutions 71 Gloucester Road London SW7 4SS
Email: casework@ico.org.uk claire.pluckrose@coesolutions.co.uk
Telephone: Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number 020 3005 4808
3.7 Privacy Statement

Read more about how and why we use your data here:
https://coesolutions.co.uk/privacy-policy

4. Online Privacy Statement

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

How we use your information

This privacy notice tells you how we, Coe Solutions, will collect and use your personal data for the fulfilment of our contractual obligation to our customers. For example, processing currency transactions, subscriptions to receiving daily rates and updates regarding developments in the fight against money laundering and terrorism.

 

 

 

Why does Coe Solutions need to collect and store personal data?

In order for us to provide you with the services we have offered above, we need to collect personal data for detailed service provision and correspondence purposes. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

 

In terms of being contacted for marketing purposes Coe Solutions would contact you for additional consent.

 

Will Coe Solutions share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Coe Solutions in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you, on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Coe Solutions procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

 

How will Coe Solutions use the personal data it collects about me?

Coe Solutions will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. Coe Solutions is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

 

Under what circumstances will Coe Solutions contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure.

 

 

 

Can I find out the personal data that the organisation holds about me?

Coe Solutions at your request, can confirm what information we hold about you and how it is processed. If Coe Solutions does hold personal data about you, you can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Coe Solutions or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

 

What forms of ID will I need to provide in order to access this?

Coe Solutions accepts the following forms of ID when information on your personal data is requested:

  • Passport
  • Driving license
  • Birth certificate
  • Utility bill (dated within last 3 months)
  • Bank Statement (dated within last 3 months)
  • Birth Certificate
  • Marriage Certificate
Claire Pluckrose
71 Gloucester Road, London, SW7 4SS
claire.pluckrose@coesolutions.co.uk
020 3005 4808