Part 1. Introduction
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.
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 This consent may be withdrawn at any time without affecting the legitimacy of the data conveyed prior to said withdrawal.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.
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)
Phone: (+34) 938 585 469
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.
Personal Data processed by Laurion Group may be communicated by:
Users have the right to:
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 firstname.lastname@example.org or write to:
Laurion Financial Enterprises, SL
Ronda General Mitre, 40 1 Planta
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.
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.
We may collect, store and use the following categories of personal details:
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.
The information and personal details we collect, store and process is used for the purposes below:
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.
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.
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: