Laurion Group | Privacy Policy
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Privacy Policy

February, 2019

 

 

Part 1. Introduction

 

This Privacy Policy sets the basis on which Laurion Financial Enterprises, SL (henceforth “Laurion Group”), with registered address in Ronda General Mitre, 40 1 Planta 08017 Barcelona, including all companies of its group, collect, process and use personal data. This Policy applies to all companies and affiliated companies of Laurion Group, as well to all its directors, managers, employees, agents and, where applicable, to service providers of Laurion Group.

 

Specifically, this Privacy Policy applies to (a) Laurion Systems, SL, (b) Laurion AM, Sarl and Laurion Financial Enterprises, SL (together “Laurion Group”). Unless otherwise clearly stated, this Policy shall also apply to all affiliated companies and subsidiaries of Laurion Group.

 

This Policy is set by the Operations & Risk Committee, approved by the Steering Committee under the relevant Protocol on the 31st of January of 2018.

 

Laurion Group is committed to protect the confidentiality, privacy and personal information of its stakeholders, and, as such, all stakeholders invited to read this Policy carefully to fully understand how Laurion Group processes, manages and shares Personal Data. Should you have any questions please use the contact details herein. Please refer to our Cookie Policy which sets out the use of cookies and other web tracking technology via our website.

 

Please note this Privacy Policy is an integral part of our Terms of Use and should be read in conjunction with any contractual and pre-contractual information given to potential clients and users of the services and Websites of Laurion Group.

 

 

Part 2. Legitimacy

 

Personal Data shall only be obtained and processed by Laurion Group when it is adequate, necessary and non-excessive in regard to the its purpose. Personal Data shall only be obtained for a legitimate reason and kept by the legally prescribed amount of time.

 

To access the web contents and web services is only permitted to persons who are of age and comply with the requirements that, in due course, are requested by the different business areas. As it stands, Users warrant that all data relayed in the course of their interactions with Laurion Group Websites or services. Furthermore, Users warrant that they shall communicate to Laurion Group any changes in their personal details or situation, to ensure information is accurate and kept up to date, in the course of the relationship.

 

The legal basis for data collection is the interaction and contractual relationship that may occur between Laurion Group and its Users, as per their express consent, in order to establish a service provision relationship. This consent may be withdrawn at any time without affecting the legitimacy of the data conveyed prior to said withdrawal. The withdrawal of consent may imply ceasing the service provision relationship but does not affect the validity of any financial obligations between Laurion and its users, nor the enforceability of the contractual relationship and obligations thereof.

 

 

Part 3. Responsible for Processing

 

The entity responsible for the processing of Data is Laurion Financial Enterprises, SL with registered address at Ronda General Mitre, 40 1 Planta 08017 Barcelona (Spain); please note this entity is responsible for the processing of data for Users of the services of Laurion AM, Sarl and Laurion Systems, SL. Data treatment for Spanish and non-Spanish companies is done under the European Regulation 2016/679 of the European Parliament, of 27th of April 2016. Contact details and further information below:

 

Laurion Financial Enterprises, SL

Ronda General Mitre, 40 1 Planta 08017 Barcelona (Spain)

NIF: B-67252841

Phone: (+34) 938 585 469

compliance@lauriongroup.com

 

 

Part 4. Purpose of Treatment

 

  • To manage information requests, contacts or services contracted by any User from a company of Laurion Group;
  • Prevent and identify any fraudulent activity, as well any money laundering and terrorist financing activities, with the relevant communications to the authorities, as per the KYC & AML Protocol approved under the Corporate Governance Policy.
  • Manage the contractual and pre-contractual relationship with any company of Laurion Group and its affiliates, including information provided to 3rd parties;
  • Remittance of commercial information, advertising and generic information regarding the services and products of its companies, affiliated companies and partner companies;
  • To analyse, treat and quantify data for statistical and historical purposes.

 

Personal Data shall be kept accurately and up to date for the length of the relationship with the User, under the terms of the Law for AML purposes. For the course of the relationship, any company of Laurion Group may access Personal Data, as well as confirm the adequacy and up to date register of the Data. User’s request for data deletion shall be attended within the limits imposed by applicable regulations.

 

 

Part 5. Recipients of Data

 

Personal Data processed by Laurion Group may be communicated by:

 

  • Any company of Laurion Group, for the undertaking of mercantile relationships, including agents, associates and affiliated companies;
  • Third party companies or entities that provide services to Laurion Group companies, for compliance reasons;
  • Third party companies or entities for the fulfilment of legal obligations, including credit worthiness, risk analysis and identity verification;
  • With clear consent, to third party companies associated with Laurion Group, so these companies may remit advertising regarding their services

 

 

Part 6. User Rights

 

Users have the right to:

 

  • Request, in writing, access to any Personal Data that is being processed, except any information that may, for legal reasons, not be available for disclosure;
  • Request, in writing, the correction of inaccurate details or request their deletion when, for instance, details are no longer needed for the purpose they were collected, as per the applicable regulations and Laurion Group Corporate Governance Policy;
  • Oppose, in writing, to the processing of Personal Data, when appropriate;
  • Withdraw, in writing, the consent given, bearing in mind that such withdrawal may reduce the scope of services rendered, and does not imply the cease of any contractual obligations entered into, nor the validity of recoupable payments derived thereof.

 

Complain to the relevant national authority, in case Personal Data processing is not up to mark, in relation with the applicable regulations.

 

When exercising any of the rights on this Part 6, users should send an email to compliance@lauriongoup.com or write to:

 

Laurion Financial Enterprises, SL

Ronda General Mitre, 40 1 Planta

08017 Barcelona

Spain

 

 

Part 7. Our Policy

 

Laurion Group is committed to and insures the confidentiality and security of Personal Data belonging to its Users, by means of adopting all necessary endeavours to ensure they shall not be altered, lost or unlawfully accessed. Laurion Group, via Laurion Financial Enterprises, SL, administers the Privacy Policy of its companies, that shall have the same Privacy Policy on its webpages, as well its documentation and contracts with underlying Users.

 

The communication of Personal Data from the Users to Laurion Group is voluntary, although refusal to do so may imply loss of access to certain areas or units of business, as well as some services provided by Laurion Group companies. Laurion Group takes all precautionary measures to protect the privacy and safety of Personal Data of its stakeholders.

This Privacy Policy applies to all Users of Laurion Group, including online and offline communication, unless otherwise stated. Should a Website of Laurion hyperlink to another website, Users are urged to confirm what is the applicable Policy, which may not be Laurion Group.

 

Our Policy may be updated/reviewed at any time and without previous warning. Users are advised to check the Policy frequently, to understand any changes that may affect their relationship with Laurion Group and its related Persons. Users are advised to confirm any changes to this Policy, especially prior to the engagement with any rendered service.

Laurion Group constantly reviews and updates the content of this Policy, to ensure its fitness for purpose and compliance with applicable regulations. Such changes may not be communicated to Users, except in such cases where there is a material and substantial change to the contents of this Policy. In such case, Laurion Group shall inform Users via email.

 

Herein, Users may find (a) Content – what information is requested and captured; (b) Purpose –

what we do with the information; (c) Recipients – with whom we share Personal Data; and (d) Safety – how we protect information. This is not an exhaustive list and further elements may be collected as long as legitimate, fit for purpose and under the applicable regulations.

 

 

  • Content – what information is requested and captured

 

  • What information do we collect?

 

We may collect, store and use the following categories of personal details:

  • Contact information such as mobile phone numbers or landline phone numbers, email and residence as well as evidence thereof (if mandatory under the applicable regulation to each business unit);
  • Identification information such as name, surname, date of birth, pictures and identification documents;
  • Browsing patterns and other elements, such as IP address, location and access details.

 

  • How we collect information?
    • By browsing the Websites;
    • By the way of online and offline communications, as per a clear consent of our Privacy Policy, such as emails, phone calls, Website forms, or any other telematic means or face to face.

 

Please note that some information may be compiled automatically as per our Cookie Policy (please refer to our Cookie Policy, an integrant part of our Terms of Business). Additional information shall be requested on a need to know basis and shall always be gathered by clear consent of the User, fit for purpose and safe.

 

Under the legitimate interest of a commercial relationship, and the clear consent given under this Privacy Policy, Laurion Group may access personal information and personal details from our own internal files as well as information stored and processed by 3rd parties, including, but not limited to:

 

  • Files containing information regarding solvency and credit situations;
  • Files and tools to confirm the identity of the User;
  • Files and tools to prevent Money Laundering and Terrorist Financing;
  • Files and tools for PEPs, CARs, individuals running away from justice, or persons with impending legal inhibitions or impediments;
  • Files and tools to prevent, identify and managed fraud and fraudulent attempts.
  • Any other files and tools accessible to the general public, as long as such verification is justifiable and fit for purpose.

 

The initial personal details such as (a) name and surname, (b) date of birth, (c) personal identification number, (d) mobile phone, (e) email address, and (f) additional contact information shall always be provided by a company from Laurion Group. From third parties we may, upon request and based on a legitimate interest, receive further information. Such information may include, but is not limited to, solvency and credit worthiness, anti-money laundering actions or inclusion in any inhibition lists that may impede the business relationship.

 

 

  • Purpose – what we do with the information

 

The information and personal details we collect, store and process is used for the purposes below:

 

  • For communication purposes, including proactively inform of any changes related to companies of Laurion Group, our services, products or mercantile relationship;
  • Prevent, identify and impede fraud and money laundering, or any other illegal or unlawful activity, as well as communicate such events to the relevant authorities;
  • Send commercial information, advertising and promotion of services – within the scope of the applicable regulations to specific products and services;
  • Offer new services; and
  • Analyse historical statistic elements.

 

As a rule, Laurion Group companies store data for the length of the mercantile relationship, unless otherwise required by applicable law. In this sense, anti-money laundering applicable regulations may require data to be stored for a length of time after the mercantile relationship is terminated.  Currently such regulations require Personal Data to be stored for the length of the relationship and for 10 years after the cease of the mercantile relationship. Laurion Group shall store Personal Data for the length of the relationship, unless the User withdraws its consent, and for the strictly necessary time to comply with its legal obligations.

 

 

  • Recipients – with whom we share Personal Data

 

  • With third parties, for the correct provision of services

The recipients of the personal information that is processed by Laurion shall be mainly those employees with the need to access that data, and with sufficient training to manage an protect it correctly. In a case where data needs to be relayed to third parties, Laurion Group shall ensure that the Privacy Policy in place offers the same degree of protection and compliance as our own.

 

  • With third parties, for the correct fulfilment of legal obligations

Users are advised that in compliance of the law related to anti money laundering and terrorism financing, Laurion Group may, under its KYC & AML Protocol and under reasonable grounds, inform the relevant authorities and share with said authorities all client files for the purposes of Compliance. Said communication shall be done by the COO & Compliance of Laurion Group.

 

 

  • Safety – how we protect information

 

Laurion Group, through its Governance Policy and robust corporate governance, guarantees that all personal details and personal data from their users shall be treated with utmost confidentiality, namely by:

  • Ensuring the physical safety of the Personal Data, by technical, administrative and other means;
  • Ensuring constant security updates and training;
  • Restricting access to Personal Data to employees and agents that need to access said information, and that have the proper training;
  • Consistent training and updating of Corporate Governance; and
  • Immediate communication with clients, should we suspect a breach has occurred.