DivestiX Capital does not disclose any non-public personal information about you, except as permitted by law. If you decide to close your account, DivestiX Capital will continue to adhere to the privacy policies and practices described in this notice.
How and Why We Obtain Information DivestiX Capital may receive non-public personal information about you (the “Personal Information”) from any of the following sources:
- Your applications or forms (for example, name, address, Social Security number, birth date, assets, and income);
- Transactional activity in your account (for example, trading history and balances);
- Information from consumer reporting agencies;
- Information from other third-party data services (for example, to verify your identity and to better understand your product and service needs);
- Other sources with your consent or with the consent of your broker;
DivestiX Capital may process the Personal Information for the following purposes:
- Managing and administrating any account you may hold with DivestiX Capital on an on-going basis (the “Services”);
- DivestiX Capital will itself (or through a third party, e.g. credit reference agency) process certain information about you or your directors, officers and employees and your beneficial owners (if applicable) to carry out anti-money laundering (AML) checks and related actions which DivestiX Capital considers appropriate to meet any legal obligations imposed on DivestiX Capital relating to, or the processing in the public interest or to pursue DivestiX Capital’s legitimate interests in relation to, the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with DivestiX Capital‘s AML procedures;
- to report tax related information to tax authorities to comply with a legal obligation;
- to monitor and record calls and electronic communications for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution, and to enforce or defend to report tax related information to tax authorities to comply with a legal obligation;
- to monitor and record calls and electronic communications for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution, and to enforce or defend DivestiX Capital and its affiliates’ rights, itself or through third parties to whom it delegates such responsibilities or rights to comply with a legal obligation imposed on DivestiX Capital or to pursue DivestiX Capital’s legitimate interests in relation to such matters or the processing in the public interest;
- to monitor and record calls for quality, business analysis, training and related purposes to pursue the legitimate interests of DivestiX Capital to improve its service delivery;
- to update and maintain records and for fee billing;
- to carry out statistical analysis and market research;
- to provide you with information about products and services which may be of interest to you or to the institution you represent, and which processing is necessary to perform a relevant contract with you, comply with legal obligations and/or which is necessary for DivestiX Capital’s legitimate interests indicated above and/or where the processing is in the public interest;
- to retain AML and other records of individuals to assist with the subsequent screening of them, including in relation to investment in other funds or the provision of other services by DivestiX Capital, to pursue DivestiX Capital’s and (in some circumstances) its clients’ legitimate interests.
On recording you will be informed additionally.
How We Protect Information About You
We take reasonable security measures consistent with applicable law to protect your Personal Information from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. We also implement encryption or Secure Socket Layers connections for the transmission of any Personal Information. As personal Email is generally not encrypted, we request that no Personal Information be sent to us via Email. We will retain your Personal Information as long as an account is active or as needed to provide you Services. You may, at any time, instruct us to remove Personal Information, but you should be aware that it is not technologically possible to remove every record of the information you have provided to DivestiX Capital from our servers. We will also retain your Personal Information as necessary to comply with legal obligations, resolve disputes and enforce our agreements.
User preferences and opt-out choices Email, Direct Mail, Telemarketing, and Third-Party Sharing. You have a right to opt out of:
- Receiving promotional or marketing emails from DivestiX Capital at a specific email address;
- Receiving direct mail;
- Receiving calls;
- Receiving notifications provided as part of the Services;
- Disclosure of your information to third-parties; and
- Use of your information for a materially different purpose from the purpose(s) for which it was originally collected or subsequently authorized.
For opt out request please contact us by email at email@example.com
How We Share Information About You
We may share the personal information that we collect about our customers, prospects, or former customers with their brokers or with:
- DivestiX Capital corporate affiliates, including internal service providers;
- Unaffiliated service providers (for example, printing and mailing companies, liquidity providers, and other entities who may provide services at DivestiX Capital’s direction)
- Government agencies, other regulatory bodies, and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)
- To credit reference agencies in order to carry out money laundering and identity checks and comply with legal obligations;
- To DivestiX Capital affiliates and third party vendors to process the data for legitimate purposes;
- Other organizations, with your consent or as directed by your broker (for example, if you request personalized performance reporting) or as permitted or required by law (for example, for fraud prevention or to respond to a subpoena)
- To competent authorities, courts and bodies as required by law or requested or affiliated for internal investigations and reporting. The disclosure of personal information to the affiliates and other third parties set out above may involve transferring data to the USA and other jurisdictions outside the European Economic Area (EEA). Such countries may not have the same data protection laws as your jurisdiction. DivestiX Capital has put in place the Standard Contractual Clauses approved by the European Commission for such transfers of personal data. Please contact firstname.lastname@example.org should you require more information on DivestiX Capital’s international data transfer solution. Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by DivestiX Capital.
Privacy, security and service in DivestiX Capital’s online operations are just as critical as in the rest of our business. We use firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect DivestiX Capital accounts and systems from unauthorized access.
When you interact with us through online channels (for example, websites and mobile applications) owned and controlled by DivestiX Capital (“DivestiX Capital websites”), DivestiX Capital manages personal information in accordance with all of the practices and safeguards described previously. When you visit DivestiX Capital’s websites, we may collect technical and navigational information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on DivestiX Capital’s websites. We use this information for various purposes, such as maintaining the security of your online session, facilitating site navigation, improving DivestiX Capital’s website design and functionality, and personalizing your experience on DivestiX Capital’s websites. Additionally, the following policies and practices apply when you are online: DivestiX Capital provides information to its clients through electronic means only. These include Email, website and online platform. Kindly note that to receive information electronically from DivestiX Capital, a valid Email address is required. DivestiX Capital provides information through our website, which may not be addressed personally to you.
Cookies and similar technologies
Connecting with DivestiX Capital on social media sites
DivestiX Capital mobile applications
DivestiX Capital mobile applications (“apps”) allow you to access your accounts, trade securities, move money, and access third-party news and research using wireless or mobile devices. Our privacy practices apply to any personal information or other information that we may collect through the apps.
Protecting children’s privacy online
DivestiX Capital websites are not directed to individuals under the age of eighteen (18). DivestiX Capital does not intentionally collect information on DivestiX Capital websites from those we actually know are under 18. We request that these individuals do not provide personal information through the sites.
Access to Your Information
You may access and, if necessary, correct your account information through a variety of media offered by your broker and DivestiX Capital (e.g., statements or online services). Please contact your broker if you require any additional information.
Data Subject Rights
You have the following rights, in certain circumstances, in relation to your personal information:
- Right to access your personal information.
- Right to rectify your personal information.
- Right to restrict the use of your personal information.
- Right to request that your personal information is erased.
- Right to object to the processing of your personal information.
- Right to data portability (in certain specific circumstances).
Where you have provided your consent to processing (e.g. to receive information about products and services which may be of interest to you or to the institution you represent), you may withdraw your consent at any time by contacting DivestiX Capital by Email at email@example.com
DivestiX Capital requires your personal information to comply with AML or other legal requirements. Failure to provide this information means DivestiX Capital may not be able to provide the Services or the service to the institution you represent. You have the right to complain to a supervisory authority.
If you are a former customer, your information is treated in the same manner as current customers' information. DivestiX Capital offers several options for accessing and, if necessary, correcting your account information. You can review your information using your statements, or through our automated telephone or Internet services. You may also write or call us with your request for information. If we serve you through an affiliate, please contact them directly.
How To Complain
We hope that we can resolve any query or concern you raise about our use of your information. Those in Designated Countries (being the European Union, European Economic Area or Switzerland) may contact our Privacy Office or their country’s supervisory authority to complain.