Data & Privacy Notice

Personal data collection and management by Windome Banking Partners SAS

WINDOME BANKING PARTNERS SAS will collect and process the following personal data:

Information that you or someone acting on your behalf provides to WINDOME BANKING PARTNERS SAS or its Affiliates. This includes information about you that you give WINDOME BANKING PARTNERS SAS by filling in forms, signing up for services on our website or by communicating with WINDOME BANKING PARTNERS SAS, whether face-to-face, by phone, videoconferences, e-mail or otherwise. If you are a client or are connected with one of our client’s matters, this may include personal data about you or others that is provided to WINDOME BANKING PARTNERS SAS in connection with the provision of services to that client.

Information WINDOME BANKING PARTNERS SAS collects or generates about you. We will also collect information about you when you use our services or when we otherwise interact or correspond with you. Various technologies to collect and store information may be used when you vist our website. We may, for example, collect information about the type of device you use to access the websites, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our websites, the web pages and the search terms you enter on our websites.

Information WINDOME BANKING PARTNERS SAS obtains from other sources. We might receive information from third parties such as your employer, other parties relevant to the services we are providing (e.g. counterparties in transactions) and others such as regulators and authorities.

Uses of your personal data

Personal data may be stored and processed by WINDOME BANKING PARTNERS SAS in the following ways and for the following purposes:

to provide WINDOME BANKING PARTNERS SAS’s products and services, including processing instructions and providing confirmations, advice and statements to our clients;
verify your identity (including for fraud prevention purposes), assess your ability to meet your financial commitments (if any) and manage WINDOME BANKING PARTNERS SAS’s relationship with you and/or the client to whom you are connected;
to contact you in connection with your work with WINDOME BANKING PARTNERS SAS and the products and services that Windome Banking Partners SAS provides to you or a client to whom you are connected;
to perform the contract with you or a client/supplier to whom you are connected (including performing WINDOME BANKING PARTNERS SAS’s obligations and exercising Windome Banking Partners SAS’s rights);
to engage in marketing and business development activity and to advise you or a client to whom you are connected of other products and services similar to those which you or a client to whom you are connected receive from WINDOME BANKING PARTNERS SAS and/or its Associates;
to engage in Community Investment projects where you choose to participate;
to notify you about changes to WINDOME BANKING PARTNERS SAS service;
to carry out financial risk assessments, risk mitigation activities and for risk reporting and risk management;
to comply with WINDOME BANKING PARTNERS SAS legal and regulatory obligations. This includes reporting to the relevant authorities, complying with anti-money laundering obligations and tax reporting obligations;
to use it to prevent and respond to actual and potential fraud or illegal activities;
to use it to look into any complaints or queries you or a client/supplier to whom you are connected may have.

WINDOME BANKING PARTNERS SAS is entitled to use personal data in these ways because:

Consent – we may (but usually do not) need your consent to use your personal data. You can withdraw your consent by contacting us (see below).
Performance of a contract – we may need to collect and use your personal data to enter into a contract with you or to perform our obligations under a contract with you or a client to whom you are connected.
Legitimate interest – we may use your personal data for our legitimate interests, some examples of which are given above.
Compliance with law or regulation – we may use your personal data as necessary to comply with applicable law/regulation.

Disclosure of personal data to third parties

WINDOME BANKING PARTNERS SAS may from time to time disclose personal data to its AffiliatesAffiliates in the circumstances described below:

to provide the services or perform its obligations in connection with your contract or the contract of a client/supplier with whom you are connected;
for the management and administration of the WINDOME BANKING PARTNERS SAS business;
for the management and administration of internal policies and procedures within WINDOME BANKING PARTNERS SAS

Where personal data is disclosed to its Affiliates, WINDOME BANKING PARTNERS SAS will take steps to ensure that the personal data is accessed only by those persons who need to do so for the purposes described in this Privacy Notice.

WINDOME BANKING PARTNERS SAS may also disclose personal data outside of WINDOME BANKING PARTNERS SAS and its Affiliates, as follows:

to third party agents, service providers or contractors, bound by obligations of confidentiality, who will only use personal data on WINDOME BANKING PARTNERS SAS behalf for the purposes described in this Privacy Notice;
to third parties relevant to the services outlined in the contract with you or the contract of a client/supplier with whom you are connected. This may include for example counterparties to transactions, professional advisers, stock exchanges or regulators;
to the prospective counterparty, for due diligence purposes, if WINDOME BANKING PARTNERS SAS or its Affiliates restructure or sell any of its or their business or assets (for the avoidance of doubt, your personal data would only be transferred in such circumstances to the extent that such a transfer was required for the purposes of due diligence and was subject to appropriate security protections e.g. anonymisation and/or confidentiality restrictions);
to the extent required by law, regulation or court order for example if WINDOME BANKING PARTNERS SAS is under a duty to disclose personal data in order to comply with any legal or regulatory obligation; and
in order to establish, exercise or defend WINDOME BANKING PARTNERS SAS legal rights, for example if WINDOME BANKING PARTNERS SAS needs to obtain external legal advice or provide personal data in connection with judicial proceedings.

Transfers of personal data outside the European Economic Area

Personal data may be transferred to, and stored at, a destination outside the UK or the European Economic Area (“EEA”). It may also be stored and processed by staff operating outside of the UK or the EEA, who work for WINDOME BANKING PARTNERS SAS Affiliates or WINDOME BANKING PARTNERS SAS third party agents, service providers or contractors.

Where Windome Banking Partners SAS transfers personal data outside the UK or the EEA, Windome Banking Partners SAS will ensure that it is protected in a manner that is consistent with how personal data will be protected by Windome Banking Partners SAS in the UK and the EEA. This may be achieved in one of the following ways:

the country that Windome Banking Partners SAS sends the data to might be approved by the European Commission or by a relevant data protection authority; or
the recipient might have signed a contract based on “model contractual clauses” approved by the European Commission or by a relevant data protection authority, obliging them to protect the personal data that they receive.

In other circumstances the law may permit WINDOME BANKING PARTNERS SAS SAS to otherwise transfer personal data outside the UK or the EEA. In all cases, however WINDOME BANKING PARTNERS SAS will ensure that any transfer of personal data is compliant with applicable data protection law.

You can obtain further details of the protection given to your personal data when it is transferred outside the UK or the EEA by contacting WINDOME BANKING PARTNERS SAS in accordance with the “Contacting WINDOME BANKING PARTNERS SAS” section below.

Retention of personal data

The duration of holding personal data will vary. will vary. The retention period will be determined by various criteria including:

the purpose for which WINDOME BANKING PARTNERS SAS is using it – WINDOME BANKING PARTNERS SAS will need to keep the data for as long as is necessary for that purpose; and
legal obligations – laws or regulation may set a minimum period for which WINDOME BANKING PARTNERS SAS has to retain personal data.

Rights in relation to personal data

You have a number of legal rights in relation to the personal data that WINDOME BANKING PARTNERS SAS holds about you. These rights include:

the right to obtain information regarding the processing of your personal data and access to the personal data which WINDOME BANKING PARTNERS SAS holds about you;
the right to request that WINDOME BANKING PARTNERS SAS rectify your personal data if it is inaccurate or incomplete;
the right to request that WINDOME BANKING PARTNERS SAS erase your personal data in certain circumstances. Please note that there may be circumstances where you ask WINDOME BANKING PARTNERS SAS to erase your personal data but WINDOME BANKING PARTNERS SAS is legally entitled to retain it;
the right to object to, and the right to request that WINDOME BANKING PARTNERS SAS restrict, its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask WINDOME BANKING PARTNERS SAS to restrict, its processing of your personal data but WINDOME BANKING PARTNERS SAS is legally entitled to continue processing your personal data and / or to refuse that request;
in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that WINDOME BANKING PARTNERS SAS transmit such data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to WINDOME BANKING PARTNERS SAS
the right to withdraw your consent, although in certain circumstance it may be lawful for WINDOME BANKING PARTNERS SAS to continue processing your data where WINDOME BANKING PARTNERS SAS has another legitimate reason (other than consent) for doing so. WINDOME BANKING PARTNERS SAS is not relying on your consent in order to process your personal data for the purposes and in the manner set out in this Privacy Notice; and
the right to file a complaint with the relevant data protection authority if you think that any of your rights have been infringed by WINDOME BANKING PARTNERS SAS.

You can exercise your rights by contacting WINDOME BANKING PARTNERS SAS using the details set out in the “Contacting Windome Banking Partners SAS” section below.

You can find out more information about your rights by contacting the relevant data protection authority. We can, upon written request, tell you which data protection authority is relevant to the processing of your personal data.