Updated 13th May 2024
The Blacktower group (“Blacktower”) is a group of companies of which the data controller (identified below) forms a part. This privacy notice is issued on behalf of Blacktower so when we mention” Blacktower”, “Blacktower group”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in Blacktower.
Who we are and how to contact us
Blacktower Financial Management (International) Limited (“BFMI”) is the controller of any personal data you provide.
Any questions regarding our Privacy Policy should be sent to:
Data Protection Officer
Blacktower Financial Management (International) Limited
PO Box 1354 Waterport Place
Floor 2 Unit 2.3 Europort Road
Gibraltar
GX11 1AA
Questions or requests can also be sent by email to: dpo@blacktowerfm.com
What type of information is collected?
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact data includes billing address, delivery address, email address and telephone numbers.
- Financial data includes bank account and payment card details.
- Transaction data includes details about payments to and from you and other details of products and services you have purchased from us or from a Blacktower Financial Adviser.
- Technical data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. More information on this is contained in our cookie notice.
- Profile data includes your username and password to access our client portal, your interests, preferences, feedback and survey responses.
- Usage data includes information about how you use our website, products and services, and navigate through the website.
- Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
How we collect information from you
We collect information about you when you:
- use our website ‘contact us’ form to enquire about products and services.
- meet with an Independent Financial Adviser (“IFA”) which is part of our network and acts as an appointed representative of Blacktower – at this meeting an IFA may ask you “Know Your Customer” or “KYC” questions which will be recorded onto our client take-on documents including for example our Fact-Find forms, Risk Profile Questionnaires or Client Agreements.
- register to receive one of our newsletters, or attend one of our events.
- call our office to enquire about our services.
- enter into a formal business relationship with an IFA and/or any Blacktower entity.
- other than from information you enter on our website, or provide on our documentation, we may also collect your personal data from documents you provide to us.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into (for example, to provide you with our services or those of an IFA). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
Our basis for processing your personal data
Our basis for processing your data may vary depending on the type of data and the purpose of the processing. The principal bases on which we process data are:
- Identity, Contact, Financial and Transaction Date data – to satisfy our legal obligations and enable the performance of our contract.
- Technical data – our legitimate interest to provide a web site.
- Profile and usage data – our legitimate interest to improve our services.
Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
How we use your personal information
We use personal information about you in connection with the following purposes:
Provision of services and account management:
- to provide you with the information, products, and services that you have requested from us.
- to complete any transaction, you are undertaking with us.
- to manage and operate your account with the chosen IFA as well as any platform providers they recommend, including sending you information relating to your account controlled by Blacktower.
- to meet a legal or regulatory obligation.
Service improvements:
- to ensure that content from our site is presented in the most effective manner for you.
- to administer our site and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- to notify you about changes to our service.
- as part of our efforts to keep our site safe and secure.
Direct Marketing:
- to provide you with information about other services we offer that are similar to those that you already have or have enquired about.
- to provide you with other marketing material such as our newsletter.
- if you do not want your personal information to be used for marketing purposes, please contact us on the above details.
Automated decision-making
Third parties providing services to us or we ourselves may at times make automated decisions while processing your personal data. For more detailed information regarding automated decision making please contact us to request a copy of our “Automated Decision Making and Profiling Policy”.
How long we keep your information for
We retain your information only for as long as is necessary for the purposes for which we process the data.
The main retention periods we use are:
- Financial or banking records, business records and account histories to meet our legal obligations to keep proper business and tax records – 7 years.
- Marketing in accordance with established industry standards for data retention – 3 years.
More detailed information about our retention periods is available on request in our Personal Data Retention Policy.
Sharing your personal information
We may pass your information internally, to our IFAs, business partners, administration centres, third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf, or to enable us to obtain a quote for you or provide you with other related services.
These third parties may include:
- fund managers
- insurers
- insurance brokers
- credit brokers
When we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
We also work closely with various third-party product and service providers to bring you a range of wealth management solutions. When you enquire about or invest in one or more of these products or services, the relevant third-party provider will use your details to carry out their obligations arising from any contracts you have entered into with them. These third-party providers will share your information with us which we will use in accordance with this privacy notice.
We may transfer your personal information to a third party as part of a sale of some, or all, of our business and assets or as part of any business restructuring or reorganisation, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.
Transferring your information to third countries
There may be instances where, as part of the services offered to you by Blacktower, the information which you provide to us may be transferred to third countries.
This may happen if any of our platform providers are located in a ‘third country’. If we transfer your information in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this notice. This may require us to take certain additional steps to ensure that appropriate safeguards are in place if that third country is not deemed to offer an adequate level of protection for your privacy rights, which may include use of contractual safeguards to allow you to be able to enforce your rights and ensure these are preserved. In certain circumstances, we may need to ask you for your explicit consent to such transfers to third countries, and will always do so in writing and giving you full information about why we need your consent and your right to withdraw that consent at any time (together with the consequences of withdrawal).
Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Data Privacy Framework or UK Data Bridge which requires them to provide similar protection to personal data shared with the US. For further details, please either contact us.
If you use our services while you are outside your home territory, your information may be transferred to third countries in order to provide you with those services.
Your individual rights
You have certain rights under applicable legislation, and in particular under relevant data protection law, including the General Data Protection Regulation (“GDPR”). We explain these below. If you wish to exercise any of these rights, you may do so by contacting us on the details above.
Right to be informed
You have a right to be informed about the processing of your personal data (and if you did not give it to us, information as to the source).
Right of access
You also have a right to access information we hold about you. You can exercise this right at any time by contacting us on the above details. We will require proof of identity from you prior to disclosing such information.
Right to rectification
You have the right to have any inaccurate personal information about you rectified and to have any incomplete personal information about you completed.
Right to erasure (‘right to be forgotten’)
You have the general right to the erasure of your personal information.
Under certain circumstances we may be unable to erase data when you request, for example:
- Where retention is necessary for complying with a legal obligation under applicable law
- The establishment, exercise, or defence of legal claims.
Right to restrict processing and right to object to processing
Instead of requesting erasure of data, you have the right to request we restrict processing of your personal information or to object to the processing.
Exercise of these rights may impact the services we can provide and we will explain this to you if you decide to exercise them.
Right to data portability
Where you provided us electronically with your personal data directly, either with your consent or due to a contract we have with you, you have the right to have the personal information we hold about you provided to you or a third party you nominate in a commonly used, machine readable format.
Right not to be subject to automated decision-making
You have the right not to be subject to automated decision making using your personal information. Where any automated decision-making takes place, you may have decisions reviewed by natural persons.
Right to withdraw consent
Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Right to lodge a complaint with a relevant supervisory authority
You have the right to lodge a complaint with the supervisory authority in the country of your habitual residence, place of work, or the place where you allege an infringement of one or more of your rights has taken place.
For further details or if unsure, please contact us.
Third Party Links
This website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. The privacy policies of others may differ significantly from our Privacy Policy.
Review of this privacy notice We may make changes to this privacy notice from time to time. We encourage you to review the privacy notice whenever you access or use our website to stay informed about our information practices and the choices available to you. If you do not agree to the revised privacy notice, you should discontinue your use of this website.