General Data Protection Regulation (EU) 2016/679

PRIVACY POLICY

Our use of your Personal Information

Belgravia Wealth Management Ltd. ( BWM ) has its registered office at 1 Mapp Street, Belize City, Belize . BWM does not appoint a Data Protection Officer, however this function is fulfilled by the Compliance Officer who can be contacted at :

Compliance Officer
Belgravia Wealth Management Limited
Place Cornavin 7
CFF – Cornavin Railway Station, 1st floor
CH – 1201, Geneva
Switzerland

What information do we collect?

We collect Personal Information from you such as full name, date of birth, passport number, bank account details and other information to enable us to provide you with information and/or services. Full details of the information we collect can be found in our document entitled General Data Protection Regulation (EU) 2016/679 – Data Collection, a copy of which is available on request.

We will retain a copy of your Personal Information throughout the time you remain a Client of ours or for as long as we are required to retain it by a separate statutory or regulatory obligation.

Legal Basis

The legal basis for the collection and sharing of personal data by BWM is Contract, except when you ask us to obtain information from other sources prior to becoming a client, in which case the legal basis for the collection and sharing of your data is Consent.

When might we share your Personal Information with others?

We may disclose your Personal Information to companies directly associated with BWM for the purposes of arranging and/or servicing your holdings through BWM, and to financial and other institutions with whom you have asked us to arrange and/or service accounts or where you already hold accounts arranged either through ourselves or a different company and which you have asked us to take over servicing on an ongoing basis .

Additionally, we may share your Personal Information for the following purposes:

• In order for us to provide information or services to you

• Where we are required to do so by a relevant Court, or to comply with other legal, statutory and/or regulatory obligations including accounting and taxation requirements

• To prevent and/or detect crime

• For credit reference purposes or

• Where you specifically give us permission to do so

We may transfer your data outside the EU/EEA. When we do this, we will only do it to the extent necessary to provide information and/or services to you, and your data will be transmitted using end–to–end encryption.

Monitoring

If you communicate with us electronically, including by e–mail, telephone , fax, Skype or other similar VOIP provider, we may monitor and/or record this communication in order to protect the interests of our business and our customers. This includes for the purposes of maintaining customer service quality standards, detection of and/or prevention of crime, and is to ensure that BWM representatives comply with legal obligations as well as BWM policies and procedures.

Cookies

The BWM website uses cookies. These are small text files that are stored on your computer or in your browser and allow us to monitor how visitors use o ur site so that we can update it from time to time. The website does not store or capture personal information about you when you visit it, however it does record information such as the number of visits to the site. This information is anonymous and no individual visitor can be identified from it.

You can disable and delete cookies by changing the settings in your browser.

We will collect personal information about you if you send us an e–mail enquiry via the ‘contact us’ facility on our website or if you contact us via some other means. We will only use that information to respond to your enquiry and will not share it with any other organisation(s) unless you specifically give us your consent to do so.

Requests for access to Personal Information (Subject Access Requests)

You may request details of the Personal Information which we hold and process about you. We reserve the right to charge an administration fee reflecting the work and material costs involved in relation to any requests for access to personal information. You may make such a request verbally or in writing to the Compliance Officer at the address shown above. Alternatively, you can email us atcontact@belgraviawealth.comfrom an email account we know to be your own.

 Requests to delete Personal Information

If you ask us to do so, we will delete from our records all the Personal Information which we hold about you unless we are prevented from doing so by a statutory or regulatory requirement which compels us to retain the information for a certain period. If this is the case, we will tell you why we are not able immediately to delete your records and when this restriction will no longer exist. You may make such a request verbally or in writing to the Compliance Officer at the address shown above. Alternatively, you can email us at contact@belgraviawealth.com from an email account we know to be your own.

Information updates

It is important that the information we hold about you is accurate and up-to- date. Please contact us if your Personal Information is or becomes inaccurate and/or out – of – date and provide us with the new information, so that our records are accurate and up-to-date. We may also contact you proactively from time to time to verify the information we hold, or to ask you to send us more recent information. We may also ask you to provide us with documentary evidence to substantiate the information provided.

Contacting us

If you do not want us to use your Personal Information in the manner set out in this Privacy Policy, need to advise us of any changes to your personal information, or would like any more information about the way in which we collect and u se your Personal Information, please contact us using one of the methods outlined above . Alternatively, you can email us at contact@belgraviawealth.com from an email account we know to be your own.

Complaints

If you have a complaint concerning our use of your Personal Information, please contact our Compliance Officer using the details on the first page of this Privacy Policy. Alternatively, you can email us at contact@belgraviawealth.com from an email account we know to be your own. If you are not satisfied with our final response to your complaint , you have the right to lodge a complaint with a supervisory authority.

Changes to this Privacy Policy

This Privacy Policy will change from time to time, and you should check our website on a regular basis for any updates.