Silk Invest Privacy Notice
Who We Are
Silk Invest gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.
Silk Invest ’s registered office is at 30 Churchill Place, E14 5RE, London, United Kingdom and we are a company registered in England and Wales under company number 06603042. We are registered on the Information Commissioner’s Office Register; registration number ZA352221, we Authorised and Regulated by the Financial Conduct Authority (firm reference number 485161) and act as the data controller and data processor when processing your data. Our designated Chief Compliance Officer is Marco Novello, who can be contacted via email at compliance@silkinvest.com.
Information That We Collect
Silk Invest processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
The personal data that we collect include any of the following: –
• Name
• Date of Birth
• Home Address
• Personal Email
• Business Email
• Home Telephone Number
• Mobile Telephone Number
• National Insurance Number
• Passport Number
• Driver’s License Number
• Tax records
• HMRC Records
• Special Category Data (i.e. health/medical information, details about religion, sexuality etc)
We collect information in the below ways: –
Website/online services/e-mail
Employment CVs
Application Forms
References etc
How We Use Your Personal Data (Legal Basis for Processing)
Silk Invest take your privacy very seriously and will never disclose, share or transfer your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.
The purposes and reasons for processing your personal data are detailed below: –
• We collect your personal data in the performance of a contract or to provide a service and to ensure that orders are completed and can be sent out to your preferred address
• We collect and store your personal data as part of our legal obligation for Investment communication, clients and Investors relations legacy, business accounting and tax purposes.
Your Rights
You have the right to access any personal information that Silk Invest processes about you and to request information about: –
• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Sharing and Disclosing Your Personal Information
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. Silk Invest may use a third-
party to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this
privacy notice, the data protection laws and any other appropriate confidentiality and security measures.
Silk Invest
Human Resources: HR Online Portal a Bright HR Company
We use HR online Platform to carry out Human Resources function for Silk Invest. They act in the capacity of a processor on our behalf. The only information we provide them with is necessary for legal requirements and only relate with our employees
For more information about this please read their Privacy Notice at:
https://w2.hronline.co.uk/legal/DataProtectionPolicy
Managed IT Services
We use Managed IT Services to maintain our IT Infrastructure support, including security and back-ups. They act in the capacity of a processor on our behalf. The only information we provide is necessary for them to carry out IT procedures.
For more information about this please read their Privacy Notice at:
https://manageditservices.co.uk/privacy-policy/
Safeguarding Measures
Silk Invest take your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: –
SSL, TLS, encryptions, restricted access, IT authentication, firewalls, DLP, and anti-virus/malware.
Transfers Outside the EU(if applicable)
Silk Invest utilise some products or services (or parts of them) that may be hosted/stored on our internal database and data’s cloud platform and by so doing our staff in other branches in Morocco, Nigeria, Egypt, Kenya, Pakistan and USA may use this data for day to day business deliverables and which means that we may transfer any information which is submitted by you through the website outside the European Economic Area (“EEA”) for the below purposes: – there is not a specific process or data being transferred but all Silk Invest Offices will have access to shared database as noted.
Therefore, when you provide us with your personal data, the personal information you submit may be stored on servers which are hosted in London but accessible by staff in Morocco, Nigeria, Egypt,
Kenya, Pakistan and USA. Where this is the case and as aforementioned, we will take steps to ensure that those providers use the necessary level of protection for your information and abide by strict agreements and measures set out by Silk Invest to protect your data and comply with the relevant data protection laws.
Consequences of Not Providing Your Data [if relying on statutory/contractual requirement basis]
You are not obligated to provide your personal information to Silk Invest, however, as this information is required for us to provide you with our services or perform risk analysis (for instance -to avoid money laundering), hence we will not be able to offer some/all our services without it.
Legitimate Interests
As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
We use the legitimate interests’ legal basis for processing children’s personal data and have identified that our interests are investments on children’s behalf.
How Long We Keep Your Data
Silk Invest only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK Law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. As a company in the finance sector, additionally we are required to retain personal data for a minimum of 7 years for only criminal related activities.
Where you have consented to us using your details for direct marketing as a legacy customer, we will keep such data until you notify us otherwise and or withdraw your consent.
Special Categories Data
Owing to the products, services or specific offerings that we offer, Silk Invest sometimes need to process sensitive personal information (known as special category data) about you, health and medical data. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.
Where we rely on your consent for processing special category data, we will obtain your explicit consent through a signature/tick box. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.
Marketing
CONSENT EXAMPLE
Occasionally, Silk Invest would like to contact you with the [specify products/services/promotions] that we provide. If you consent to us using your contact details for this purpose, you have the right to modify or withdraw your consent at any time by using the opt-out/unsubscribe options or by contacting Silk Invest directly via email at compliance@silkinvest.com or through the Post using this address:, 30 Churchill Place, E14 5RE, London, United Kingdom
LEGITMIATE INTERESTS EXAMPLE
Silk Invest will occasionally send you specify services, investment factsheets, periodic investment performance communique and other applicable information by email or post that have been identified as being beneficial to our you as customers, investors, partners, suppliers and workforce and deemed in our interests. Such information will be relevant to you as a stakeholder and they are non-intrusive and you will always have the option to opt-out or unsubscribe at any time as you deem fit.
Lodging A Complaint
Silk Invest only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information please get in touch with us using the following contact information, you also have the right to lodge a complaint with the supervisory authority with contact below if you are not satisfied:
The Chief Compliance Officer
Silk Invest Limited
30 Churchill Place, E14 5RE, London, United Kingdom
020 8088 1040
compliance@silkinvest.com
Silk Invest take your privacy seriously and will only process your personal data with your consent and in accordance with the terms stated in our Privacy Notice. If you consent to us collecting and processing your personal data, please complete tick below: –
Cookie Notice
A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information such as items added in the shopping cart, visited pages or logging in options.
Cookies are widely used in order to make websites work, or to work more efficiently, and our site relies on cookies to optimise user experience and for features and services to function properly.
Most web browsers allow some control to restrict or block cookies through the browser settings, however if you disable cookies you may find this affects your ability to use certain parts of our website or services. For more information about cookies visit https://www.aboutcookies.org.