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Updated August 2019
We take our responsibilities under applicable data protection law, including the EU General Data Protection Regulation (`GDPR`) and implementing legislation such as the Data Protection Act 2018, very seriously. The purpose of this notice is to inform you of the data relating to you that we collect and use in connection with this website and the uses (including disclosures to third parties) we make of such data.
We are not responsible for the content or privacy practices of any linked sites. Any external links to other websites are clearly identifiable as such.
We wish to be fully transparent on how we process your data and show you that we are compliant with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.
For the purposes of the GDPR the data controller(s) include the following BlackBee affiliated entities:
BlackBee Investments Limited
BlackBee Investments Limited is authorised as a MiFID investment firm and is regulated by the Central Bank of Ireland.
BlackBee Investments Nominees Limited
BlackBee Trustee Services DAC
BlackBee Funds Limited
BlackBee Funds ICAV
APIS Capital DAC
APIS Capital II plc
Drumcondra Series 1 SPV Limited
BlackBee Investments Nominees EIIS 1 Limited
Mid West Care Homes SPV Limited
City Quarter SPV Limited
Who We Are
BlackBee is affiliated to the entities listed above. Our headquarters are located at City Quarter, Lapps Quay, Cork. We also have a satellite office at 3 Fitzwilliam Place, Dublin 2. We can be contacted at 021 206 1710 and email@example.com. We are committed to processing your personal data in accordance with EU data protection laws.
Why We May Collect Your Personal Data
To enter into and for the performance of a contract:
We process your personal information where it is necessary to enter into a contract with you for the provision of a product or service, to assess you for suitability for a product or service or to perform our obligations under a contract with you. This includes:
We use personal information that you provide to us to process your application for a product or service from us and to decide on the terms upon which we can enter into a contract with you, for example, an application for a BlackBee Investment product.
Ongoing Product/Service Management:
In order to manage any product or service provided, we have to process your personal information, for example, administration of BlackBee Investment product by processing payments etc. As part of this management, we may be required to pass some of your personal information to an intermediary or counterparty (e.g. to take a payment by direct debit from your bank account we have to share your personal information with our bank).
Data must be processed in order to complete the investment required.
To Comply With Legal Obligations
In certain circumstances, we must process your personal information to comply with legal obligations. These include:
1. Verifying personal information provided to us to prevent money laundering, financing of terrorism, tax avoidance, and/or fraud. For example, we may ask you for a proof of identity and/or a proof of address as part of our ongoing verification requirements in respect of Anti-Money Laundering legislation;
2. Responding to queries raised by regulatory authorities, law enforcement and/or other government agencies such as the Data Protection Commission, the Central Bank of Ireland, An Garda Siochana, and the Revenue;
3. Providing information requested in the context of a regulatory investigation or inspection;
4. Delivering mandatory communications as required by legislation or regulations;
5. Investigating and resolving complaints;
6. Managing contentious regulatory matters, investigation and litigation;
7. Our legitimate business interests.
Your personal information will also be processed on the basis of our legitimate interests. Where it is processed on this basis, we ensure that there is a fair balance between our legitimate interests and your privacy rights. The following are some examples of when BlackBee processes your personal information for legitimate business interests. Your personal information may not be processed in all cases and if it is, it will always be subject to measures to comply with Data Protection Law.
How We Collect Your Personal Data
We may collect your personal data in a number of ways, including via our network of Appointed Financial Advisers.
For example when you:
Apply for and use our products and services;
Call us, we may monitor and/or record your telephone calls;
Contact and interact with us;
Ask us to contact you;
If a person applies for a joint account with you they may share your personal data with us or if you are a stakeholder in or manager of a business, and the business applies for products or services or enters into an agreement or interacts with us, we may obtain personal data about you to carry out checks against the business. We may also collect information from third parties such as regulatory bodies, law enforcement bodies, financial advisors, research and data analysis partners, public sources – for example, Companies Registration Office.
What Personal Data We Collect
Types of information we may collect include:
Name, date of birth, proof of identification (such as driving licence or passport), nationality, PPS number/ tax details. Examples of how we use this information include, to identify you and to comply with our legal and regulatory obligations.
Address, telephone number, email address. Examples of how we use this information include: to manage and administer your product (s) with us, to send you information, which you request, and to respond to your queries and complaints.
Employment details, financial information, bank details, account information and history, details of your transactions, records of our interactions/ correspondence with you. Examples of how we use this information include providing you with products.
Interactions with BlackBee staff:
Whenever a staff member meets you or contacts you, a note of this interaction is recorded on our management system. In addition, we may record telephone conversations to improve services, for training purposes, to resolve complaints and as required by relevant regulations and Central Bank of Ireland Codes of Conduct. However, we will always let you know when we are recording our calls with you.
If You Give Us Information About Somebody Else
You must make sure that if you give us personal data about someone else, you should have a lawful basis for doing so, for example, you have their consent to share personal data with us. Where applicable, you should ensure they read this Privacy Statement and understand how we will use and disclose their information, in the ways described in this Privacy Statement.
How We Secure Your Data
We know how important the security of your personal data is. We use security measures that meet international standards, to protect your personal data against loss or theft, as well as from unauthorised access, disclosure, copying, use or modification, regardless of the format in which it is held.
How Long We Keep Your Personal Data For
We will not hold your personal data for longer than is necessary. We retain your personal data for as long as we need it for the purposes described in this Notice, or to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise between you and us.
To Whom We May Disclose Your Personal Data
We may disclose certain personal data as follows:
1. To our professional advisers, receivers and administrators (where applicable), and service providers (including, for example, information technology systems providers) who may help us provide products or services;
2. Relevant tax authorities;
3. Law enforcement agencies;
4. To the relevant Regulatory/ Supervisory Authority;
5. To any relevant third party in the course of an acquisition, sale, transfer, reorganization or merger of parts of our business or our assets;
6. As required or permitted by law or regulation, where we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of BlackBee Investments, our clients, or others;
7. To credit reference agencies;
8. To courts, governmental and non-governmental agencies, regulators and ombudsmen.
9. To any of the entities listed above which are part of the BlackBee structure
10. Third parties within the European Economic Area (“EEA”)
In certain circumstances we may share your information with third parties who will act on our instruction in relation to any processing of your personal information.
1. We may share your information with insurers, solicitors, accountants other consultants who act on our behalf or to obtain advice.
2. We use the services of a number of IT suppliers of systems and technology.
3. We may share your information with third parties to comply with our legal obligations.
Transfer Of Personal Data Outside The European Economic Area (“EEA”)
We may transfer your personal information to organisations in countries outside of the EEA, but we will only do so where:
1. The European Commission has decided that the country or organisation we are sharing your information with will protect it adequately;
2. We have entered into a contract with the organisation with which we are sharing your information to ensure it is adequately protected on terms approved by the European Commission; or
3. The transfer has been authorised by a relevant data protection authority.
You have the following rights as a data subject:
Right of access;
Right to rectification;
Right to erasure;
Right to restrict processing;
Right to data portability;
Right to object.
If you wish to exercise any of these rights or withdraw consent to our processing of your personal data, please fill in a Data Rights Request Form, available here. Consent based processing is generally limited to marketing related activity.
Complaints About Data Processing
If you are concerned about how personal data is processed by us, please do not hesitate to bring such concerns to the attention of the BlackBee Compliance Department at firstname.lastname@example.org. You have the right to complain to the Data Protection Commissioner. This can be done using the following contact details:
Telephone: 057 8684800
Post: Data Protection Commissioner, Canal House, Station Road, Portarlington, R32 AP23, Co Laois
If you wish to contact BlackBee please refer to the Contact Us section of our website.
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