Data Privacy Policy
At Kendall Haywood LTD, we are committed to protecting the privacy and security of your personal data. This Data Privacy Policy outlines how we collect, use, disclose, and protect your information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act July 2023
1. Information We Collect
We may collect the following types of personal data from you:
Contact Information: Name, email address, phone number, mailing address.
Financial Information: Bank account details.
Identification Information: POI (for example passport/driving licence)
Employment Information: Job title, employer name.
Communication Preferences: Your preferences for receiving communications from us.
2. How We Use Your Information
We may use your personal data for the following purposes:
Providing Services: To fulfil our contractual obligations with Currencycloud and deliver the services you have requested.
Communication: To communicate with you regarding our services, updates, and promotions.
Payment Processing: To process payments and transactions.
Compliance: To comply with legal and regulatory requirements.
3. Data Sharing and Disclosure
We may share your personal data with the following parties:
Currencycloud: Third-party service provider who assist us in delivering our services.
Legal Compliance: When required by law or in response to legal process (e.g., court orders, law enforcement requests).
4. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include encryption, access controls, and regular security assessments.
5. Data Retention Period
All data collected by Kendall Haywood LTD in relation to Currencycloud accounts needs to be retained for a period of five years, where this is measured from the date of trade execution or five years from the date that the customer ends its business relationships with Currencycloud.
The data which Currencycloud expects us to keep includes, at a minimum:
1. Customer due diligence information (for OKYC clients).
2. Customer communication information, including phone calls6 and emails.
3. Internal communication pertaining to customers.
4. Information pertaining to customer complaints; and
5. Any other information relating to provision of Currencycloud services to customers.
We are required by our regulators to be able to evidence compliance with a wide range of regulatory rules for this period of five years, so it is very important that we retain and protect in line with UK data privacy rules all data relating to customer interactions for this timeframe and that we can provide it to Currencycloud without delay if requested to.
Phone calls with our customers must be on recorded lines and any third parties providing us with call recording services should be able to provide retention for the five-year period and we should archive recorded calls locally for this time frame.
We also ensure that any third parties providing call recording services are compliant with all relevant privacy rules as the information shared with our customers during phone calls may often be sensitive and confidential.
6. Your Rights
You have the following rights regarding your personal data:
Right to Access: To request access to and receive a copy of your personal data.
Right to Rectification: To request the correction of any inaccurate or incomplete personal data.
Right to Erasure: To request the deletion of your personal data under certain circumstances.
Right to Restriction: To request the restriction of processing of your personal data under certain circumstances.
Right to Data Portability: To receive your personal data in a structured, commonly used, and machine-readable format.
7. Contact Us
If you have any questions or concerns about our Data Privacy Policy or our data practices, please contact us at info@kendall-haywood.com
Changes to this Policy
We may update this Data Privacy Policy from time to time. Any changes will be posted on this page, and the effective date will be updated accordingly.