1.1 Our collection of information

We provided you with details required by data protection laws applicable to our processing of your personal information during the application process. This document supplements that information. Data protection laws require us to keep your personal information secure.

The personal information we hold about you is limited to that which:

• you have directly provided to us during application;
• we receive from trusted third parties during eligibility checks;
• we collect during the provision of our contracted services to you; and
• we occasionally obtain from publicly available sources such as social media sites and Government registers.
• personal data includes any information that directly or indirectly identifies you, including your, any photograph that we take of you, any fingerprint we take from you, together with any signature we get from you, as part of our account opening process for the purpose of checking your identity.

Our web application uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyse how you use the application. Neither Swift Max Securities Securities Ltd nor Google will associate your IP address with any other personal information held by Swift Max Securities Securities Ltd or Google. Google has their own GDPR policy which can be found here. We maintain an online presence on popular global social media websites including (but not limited to) Twitter, LinkedIn, Instagram, Facebook and YouTube. By engaging with us on these sites, you are accepting that the webpages are available to the general public and agree to the following:

We also do not use cookies for advertising banners, as we do not run these on our site. Cookies are also used for our website security protection plugin (called iThemes). This plugin reads IP addresses so that it can better secure the site – and offers an IP blacklist/whitelist to protect our site from being hacked. You do have the option to disable cookies in your browser if you so choose. This should not affect the functionality of the Swift Max Securities Safe Deposit Centres website but could affect other sites you may visit.

• social media web pages are not private, please do not share your personal account information on any of the websites, including through the use of private messages;
• although we do always try to read every message sent to us on social media, we cannot guarantee a response to every message;
• any pictures you provide on our social media web pages may be used within our internal newsletters; and
• any information that you provide us with on social media webpages may be retained by the webpage for longer than your relationship with us.

1.2 Legal basis and the purposes we require personal information

To deliver our contracted services (or steps taken on your request prior to entering into a contract) we process and share your personal information for the purposes of safe deposit services:

• Managing your account(s);
• Tell you about important changes or developments to those services;
• Check identities;
• Collect money that you owe us;
• Update, bring together and improve records;
• Respond to your enquiries, complaints and issues;
• Deal with offers, competitions and promotions;
• Evaluate the effectiveness of marketing and for research, training and statistical analysis with the aim of improving services.

To ensure compliance with applicable laws and regulations, we process and share personal information for the purposes of:

• Detecting, preventing and prosecuting crime or terrorism (including CCTV);
• Identification checking and validation.

For our legitimate business interests we process and share personal information for the purposes of: • managing and supporting our staff;

• maintaining our own accounts and records;
• to help improve customer service;
• checking details of job applicants and employees; and
• making or keeping copies of passports, driving licenses or other identification evidence that you provide for our security and business needs.

Where we have your consent we also process and share personal information for the purposes of:

• Introducing you to Ellerton Knight our insurance partner (mysecuritybox) if we think that you may be interested in hearing from them about their products, services or promotions. We may do this by post, by phone, by email or by text as you have told us we can. In order to process and use your personal information, we rely on the following legal bases: (i) processing is necessary for the performance of the services we provide to you; or (ii) processing is necessary for the purposes of the legitimate business interests pursued by Swift Max Securities Securities Ltd; or (iii) you have given explicit consent to the processing of your personal information for one or more specified purposes.

1.3 Who we share personal information with and why

Your personal information (including copies of your identification, photographs, signature and any other personal information that we hold about you) to enable us to process personal information for the purposes previously outlined.

We will not release your personal information to anyone without your permission, unless:

• you have provided your consent;
• Swift Max Securities Securities Ltd is party to a merger or acquisition;
• we have to or are allowed to under these terms and conditions, by law, regulatory bodies or if it is in the public interest;
• HM Revenue & Customs, the Financial Conduct Authority (FCA) or other authorities (whether in the UK or abroad) say we must;
• other organisations, such as fraud-prevention or law-enforcement agencies tell us to so they can investigate or prevent crime or terrorism;

1.4 Retaining your information if you stop using the safe deposit box

At the end of your relationship with us (for example, if you decide to close your account) we retain your information for as long as required to meet our statutory legal and regulatory requirements.

Where retention is based on other reasons we will retain it for no more than 7 years.

1.5 Your rights over your personal information Under the General Data Protection Regulation (from 25th May 2018)

You have new, clearly described rights over your personal information that we process. You can exercise your rights by contacting us by post or phone using the contact details provided or by visiting one of our stores. We do need to confirm your identity before processing your request(s). If you cannot give us satisfactory proof of your identity we have the right to refuse a request. Rights to access a copy of your personal information You can request a copy of the personal information that we hold about you. This is generally known as a ‘Data Subject Access Request’ and we normally have 1 month to respond. To obtain a copy of your information please contact the ‘Data Controller’ at 162 Pentonville Road, Harrow, Middlesex, HA3 0QA.

Right to request rectification of your personal information We take reasonable steps to keep your information accurate and current but you can also ask us to change any information we hold about you to keep it accurate, complete and current. However, please remember that it is your responsibility to tell us about any updates to this information. Right to request erasure of your personal information (“to be forgotten”) In certain circumstances, you have the right to ask us to erase the personal information we hold about you, for example, if you withdraw your consent to our processing of your personal information, your personal information is no longer necessary for the purposes it was collected for, or your personal information has been processed unlawfully. Where there are legitimate reasons that we must retain some of your personal information after you have requested its erasure, appropriate organisational and technical controls will remain in place. Such reasons include for compliance with a legal obligation to which we are subject, for reasons of public health or for statistical and historical research purposes, or for the establishment, exercise or defence of legal claims.

1.6 Right to request restriction on our processing of your personal information

You can request that we restrict our processing of your personal information where:

• you contest the accuracy of the information we hold (restricted until it has been verified);
• it was processed unlawfully but you do not wish us to erase it just restrict our processing; or
• we no longer need the personal information but you need us to retain it for the establishment, exercise or defence of a legal claim.

Where a restriction is in place we can continue to store your information but only otherwise process it with your consent or for the establishment, exercise or defence of legal claims, for the protection of another individuals rights or for important public interest reasons. We will inform you prior to the lifting of any restriction. Right to raise an objection to our processing of your personal information Where our processing of your information is performed on the basis of ‘Legitimate Business Interest’ or ‘public interest’ then you can request we stop the processing. We can continue to process your information for the establishment, exercise or defence of legal claims and if we demonstrate compelling legitimate grounds which over-ride your interests, rights or freedoms. You can object to our processing of your information for direct marketing purposes and we will cease any processing related to direct marketing.

Right to data portability

In certain circumstances, where technically feasible, you have the right to receive the personal information in a structured, commonly used and machine-readable format and have the right to transmit such personal information to another data controller, if the processing is based on consent and is carried out by automated means.

1.7 Right to withdraw consent for optional processing

You may at any time withdraw consent for any optional uses of your information to which you have previously consented.

1.8 Right to lodge a complaint with a supervisory authority.

If you are ultimately dissatisfied with our use or management of your personal information, you have the right to lodge a complaint with a EU Data Protection Supervisory Authority. That authority should be located either where you live, where we are based, or where you feel issue you wish to complain about took place. In the UK the relevant Data Protection Supervisory Authority is the Information Commissioners Office (ICO).

1.9 Any further uses of your information in future

If we determine that your personal data is to be used for a purpose not already notified to you we will provide you with further information prior to processing for that new purpose. We will tell you in writing about any changes and allow you 30 calendar days to raise any objections before we make any change. If you have not given your permission for the change to be made, please be aware that it may affect the services we can provide to you and in some instances we may need to close your account (or accounts).

1.10 Where you may see a record or an impact from our activities Law enforcement, fraud prevention and other agencies

If you give us false or inaccurate information and we identify or suspect fraud or other criminal activity, we may pass details to fraud prevention agencies.

Law-enforcement agencies may also access and use this information. We and these other organisations may access and use your personal information to prevent fraud and money laundering, for example, when:

• checking details of job applicants and employees.

If you ask, we will provide you with details of the relevant fraud-prevention agencies.

You must tell us if your name or contact details change. We will not be responsible if we fail to contact you because you have not given us your latest details. It is important to give us a correct email address and mobile number. You should make sure that the arrangements for receiving mail at your address are safe. We may charge you if you do not provide up-to-date contact details and we have to pay costs in trying to find you.

Address:
UK Address:
Beacon Tower, Colston Street
Bristol
United Kingdom
BS1 4RD