Privacy Policy


Claremont Group Ltd takes your privacy very seriously and adhere to the principles of the Data Protection Act 1998. This Privacy Policy details how Claremont Group Ltd collects, manages and discloses your personal information and ensures that it remains confidential and secure. Your use of this website constitutes acceptance of the terms of this Policy. Any changes to our Policy will be incorporated in an updated version on this page and your subsequent use of the website constitutes acceptance of those changes.

Claremont Group Ltd is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

What we collect

We may collect the following information:

  • your name
  • contact information including email address and contact number.
  • demographic information such as postcode, preferences and interests.

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

  • Internal record keeping.
  • We may use the information to improve our products and services.
  • We may periodically send promotional emails about new products, special offers 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 contact you by email, phone, or mail. We may use the information to customise the website according to your interests.

Security

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 we collect online.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

  • whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
  • if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at [email address]

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please email admin@claremontwealth.com

If you believe that any information we are holding on you is incorrect or incomplete, please email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

3rd Party Information

In order to verify and allocate commissions/monitor the success of referrals/maintain client records, we may share and receive information about your trading activity from third party companies such as TTT Moneycorp Limited, Currencies Direct, Money Mover, Currency Cloud, Ebury & GC Partners.

Ebury Partners UK Limited (“We”, “Us” or “Our”) are committed to protecting and respecting your privacy.

As part of Our normal business operation We collect certain personal information from Our clients. This policy sets out the basis on which We process any such personal information that We collect or that you provide to Us. Please read this policy carefully to understand Our practices regarding your personal information.

By visiting www.ebury.com, online.ebury.com or bos.eburypartners.com (“Our sites”) you are accepting and consenting to the practices described in this policy.

For the purpose of the General Data Protection Regulation (the “Regulation”):

Data Controller

Data Protection Officer
Ebury Partners UK Limited,
100 Victoria Street,
London, SW1E 5JL.
Telephone: +44 (0) 20 3872 6670
Email: info@ebury.com

Data Protection Officer

Ben de la Salle, Ebury Partners UK Limited, 100 Victoria Street, London, SW1E 5JL.
Telephone: +44 (0) 20 7197 9900
Email: dpo@ebury.com

You may contact Our Data Protection Officer directly with any enquiries relating to Data Protection.
You have the right to lodge a complaint with your Supervisory Authority. For the purpose of Our processing the lead Supervisory Authority is:

Lead Supervisory Authority

Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
Telephone: +44 (0) 303 123 1113
Email: casework@ico.org.uk
Website: https://ico.org.uk

We may collect and process the following data about you:

Information you give Us.

  • You may give Us information about you by filling in forms on Our sites or by corresponding with Us by phone, e-mail or otherwise. This includes information you provide when you register to use Our sites, subscribe to Our services, place an order or transact on Our sites or report a problem with Our sites. The information you give Us may include your name, address, e-mail address and phone number, financial and credit information.
  • You may give Us information relating beneficiaries, shareholders, trustees and directors to enable us to deliver Our services. This may be through filling in forms on Our sites or by corresponding with Us by phone, e-mail or otherwise. You must obtain appropriate consent before disclosing such information to Us. The information you give Us may include their name, address, e-mail address and phone number, financial and credit information.

Information We collect about you.

  • With each visit to Our sites We may automatically collect the following information:
    technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from Our sites (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call Our customer service number.

Information We receive from other sources.

  • We may receive information about you if you use any other websites We operate or other services We provide. This data may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. Where this is the case We will ensure this will be in full compliance of the Regulation.

Cookies

We follow the “Implied Consent” basis for processing cookies. The first time you visit Our sites We will inform you of the cookies We use and that by continuing to browse Our sites you are implying your consent for Us to use cookies.

A cookie is a very small text file placed on your computer, that allows Us to distinguish you from other users of Our sites. These cookies help Us to provide you with a good experience when you browse Our sites. We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of Our sites. They include, for example, cookies that enable you to log into secure areas of Our sites.
Analytical/performance cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around Our sites when they are using them. This helps Us to improve the way Our sites work, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to Our sites. This enables Us to personalise Our content for you, by remembering your preferences (for example, your choice of language or region).

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which We have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of Our sites.

How We use your information

Information you give to Us. – We will use this information:

  • to carry out Our obligations arising from any contracts entered into between you and Us and to provide you with the information, products and services that you request from Us;
  • to provide you with information about other products and services We offer;
    • where you are an existing customer, We will only contact you with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you.
    • where you are a new customer, We will contact you only if you have consented to this. If you do not want Us to use your data in this way, please tick the relevant box situated on the form on which We collect your data.
    • You may withdraw this consent at any time by using the links provided at the bottom of marketing emails from Us, or by contacting Our DPO.
  • to notify you about changes to Our service;
  • to respond to any enquiry you have made through Our sites, or via phone, e-mail or otherwise.
  • to comply with legal obligations We are subject to as a data controller and regulated business
  • where required to protect your vital interests or that of another natural person
  • where performing tasks carried out in the public interest or in the exercise of official authority invested in Us

Information We collect about you. – We will use this information:

  • to administer Our sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve Our sites to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of Our services, when you choose to do so;
  • as part of Our efforts to keep Our sites safe and secure;
  • to measure or understand the effectiveness of advertising We serve to you and others, and to deliver relevant advertising to you;

Information We receive from other sources. – We will use this information:

We may combine this information with information you give to Us and information We collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information We receive).

Information We disclose about you

We may share your personal information with any member of Our group, which means Our branches, Our representative offices, Our subsidiaries, as defined in section 1159 of the UK Companies Act 2006. Any such sharing will be made in full compliance with the Regulation.
We will never sell your personal data without your consent. We may share your information with selected third parties. Where this is necessary, We are required to comply with all aspects of the Regulation.The following are the types of organisations We may share some of your personal information with:

  • Business partners, suppliers and sub-contractors for the performance of any contract We enter into with them or you.
  • Analytics and search engine providers that assist Us in the improvement and optimisation of Our sites.

We may disclose your personal information to third parties:

  • In the event that We sell or buy any business or assets, in which case We may disclose your personal information to the prospective seller or buyer of such business or assets.
  • If Ebury Partners UK Limited or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
  • If We are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply Our Terms of Use or Terms and Conditions and other agreements; or to protect the rights, property, or safety of Us, Our group companies, customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where We store your personal information

The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for Us or for one of Our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. When these transfers are needed, they will be done in full compliance of the Regulation.

All your personal information will be afforded a high level of protection wherever it is processed and no matter whether it is held by Us, or Our contractors or agents.

All information you provide to Us is stored under Our control. Any payment transactions will be encrypted. Where We have given you (or where you have chosen) a password which enables you to access certain parts of Our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect your personal information, We cannot guarantee the security of your data transmitted to Our site; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

Should you have particular concerns about a method of data transmission, We will take reasonable steps to provide an alternative method.

Your rights

You may contact Our Data Protection Officer, dpo@ebury.com, to exercise your rights. When exercising your rights We will always inform you of any lawful reason that may require Us to continue processing your data.

You have the right to request from Us information about whether we process your personal information, and ask questions about how We collect, store and process that information.

You have the right to access free information about the personal information We hold about you, whether this is transferred to a third country or international organisation and the associated safeguards.

You have the right to receive any personal data We hold about you in a commonly used and machine-readable format.
Where information We hold is not accurate or is incomplete, you have the right to request We correct such information and We will do so without undue delay.

You have the right to request that We delete any data We process about you, where there the processing is no longer necessary.

Where you have previously provide consent for Our processing of your data, you have the right to remove that consent and for Us to stop processing your data specific to that consent. You also have the right to object to Our processing of your data.

External Sites

Our site may, from time to time, contain links to and from the websites of Our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

Retaining your Data

The period for which We will retain your data is dependent upon any statutory retention periods We are required to adhere to as a regulated organisation. After the expiration of that period, personal data shall be securely deleted, as long as it is no longer required for the fulfilment of any contract, initiation of a contract or in relation to other legal proceedings.

Changes to Our privacy policy

This policy was last updated on 20/09/2018. Any changes We may make to Our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to Our privacy policy.