Conto Direct Privacy Statement

In the course of serving you as a client, Conto Direct will  request personal information  from you to be able to deliver the highest level of service to you. This policy describes:

• What personal information we request from you
• How we use and with whom we share the personal information we gather
• What security procedures we have in place to protect your personal information from loss, misuse, or alteration
• How you can correct or update your personal information

 As used throughout this policy, the term “Conto Direct” refers to Conto Direct Limited and its affiliates worldwide.

Personal Information

The personal information we collect about you comes primarily from the registration forms and materials you submit to Conto Direct during the course of your relationship with us.  By submitting such information, you agree for us to store it and use it to provide you the services you require.

We may also collect indirect information about you from monitoring or other means (e.g. recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance, training, quality control or security purposes. The typical information we collect about you would include:

• Your name, address and other contact details

• Your age, current and previous occupation and marital status

• Residence and immigration status

• Extensive financial information, including source of income, bank accounts and tax matters

• A head and shoulders photograph from your passport or national identity card as required by laws and regulations addressing due diligence and related matters; and

• A personal identifier such as, depending on your country of residence and/or of work, your Social Security Number, National Insurance Number, Tax File Number, etc.

While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

Use and Share of Your Personal Information

Conto Direct will not sell your personal information. We may use your personal information to:

• Manage your contract with Conto Direct, which may include sharing such information internally or externally to prescribed  third parties, as described below

• Contact you or, if applicable (with written confirmation from you), your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your contract

• Provide you with information or advice concerning products and services offered by Conto Direct

• Facilitate our internal business operations, including fulfilling our legal and regulatory requirements

If your relationship with Conto Direct ends, Conto Direct will continue to treat your personal information, to the extent we retain it, as described in this policy.

Conto Direct does not disclose your personal information to third parties, except as described in this policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your contract or facilitate your transactions with Conto Direct, including those that provide professional, legal or accounting advice to Conto Direct. Non-affiliated companies that assist Conto Direct in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that Conto Direct dictates.

We may also disclose your personal information to fulfil your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations.

Information Security: How We Protect Your Privacy

We limit access to your personal information to authorised and trained Conto Direct employees or agents and our service providers are held to stringent standards of privacy.  

We also maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorised access or disclosure.   

Changes and Updates

This policy may be changed without notice to reflect changes in practices or regulations. The revised policy will be effective immediately upon posting to our Web site. This version of the Policy is effective September 1, 2008.

You are entitled to access any personal data about you held by Conto Direct by sending a written request to the applicable individual identified below. You may be required to supply a valid means of identification as a security precaution. We will process your request within the time provided by applicable law. You are also entitled to have Conto Direct modify or delete any information that you believe is incorrect or out of date.

Conto Direct may occasionally contact you by post, telephone, electronic mail, facsimile, etc., with details of products and services that we believe may be of interest to you. If you do not wish to be contacted in this way, please contact:

Yatish Lodhia
Director
Conto Direct Ltd
Clements House,
27-28 Clements Lane,
London EC4N 7AE
UK

email:ylodhia@contodirect.com