Privacy Notice
Last updated: 01 November 2024
We are committed to protecting and respecting your privacy. This notice sets out how we look after your personal data and tells you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below:
2. The types of data that we collect
3. How we collect your personal data
4. How we use your personal data
5. Providing your personal data to others
6. International transfers of your personal data
8. Retaining and deleting personal data
1 . Introduction
"We", "us", "our" and “Multrees” refer to Multrees Investor Services Limited. We are incorporated in England (company number 07225386) with our registered offices at One Carter Lane, London EC4V 5AN.
Multrees is an independent provider of custody, settlement, transactional and investment administration services to investment advisers (Investment Advisers) and their clients (Customers). Multrees is authorised and regulated by the Financial Conduct Authority under firm reference number 526528.
This notice applies when your Investment Adviser has asked us to provide custody, settlement and transactional services for you. It also applies if you are, or you work for, an Investment Adviser, when you visit our website, if we identify you as a prospect, if you are someone who might be interested in what we have to offer or if you supply services to us. These are all situations where we are acting as a data controller with respect to your personal data, that is when we determine why and how your personal data is processed.
This notice does not apply when your Investment Adviser engages us to provide it with investment administration services. In this context we only process data on behalf of your Investment Adviser who is the data controller and we are a data processor. You should view your Investment Adviser’s privacy notice to understand the basis on which they are processing your personal data.
Data Protection Officer
We have appointed a Data Protection Officer who can be contacted at DPO@multrees.com or by writing to:
F.A.O. The Data Protection Officer
Multrees Investor Services Limited
40 Princes Street
Edinburgh
EH2 2BY
European Union Representative
We have appointed Saltire Data Protection Services Limited to act as our representative in the European Union. You can always contact us directly, however, if you wish to contact Saltire Data Protection Services Limited you can do so by clicking this form https://app.saltiredataprotection.eu/enquiry/rs/multrees
Contact us at DPO@multrees.com with any questions in relation to this privacy notice or your privacy rights.
Any changes we make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes.
Our website may from time to time contain links to and from the websites of other businesses. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for their privacy obligations. Please check their privacy notices before you submit any personal data to these websites.
2. The types of data that we collect
Personal information, or personal data, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we collect from various sources as described below:
Identity Data includes first name, last name, identifier such as NI number or national identity number, user ID, title or role, company you work for.
Contact Data includes email address, address, work details, work address and telephone numbers, LinkedIn url.
Background Check Data includes passport and/or driving licence, confirmation of address, date of birth, directorship and/or shareholder details, credit reference checks, and any other data provided as part of checks carried out to comply with our regulatory obligations, including anti-money laundering, financial crime, sanction and know your client checks.
Services Data includes personal information provided to us by you or by your Investment Adviser on your behalf, or by counterparties with whom we undertake transactions on your behalf or generated by us in the course of administering your account or providing you with our custody, settlement and transactional services.
Payment Data includes details of services you have purchased from us, fees paid and payable to us and confirmation of payments that you have made to us and associated bank details.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Usage Data includes information about how you use our website, the electronic platforms we make available as part of our services and email tracking data about whether you open, or click on links within, our marketing-related emails.
Marketing and Communications Data includes your preferences in receiving marketing communications from us.
We may also collect, use and share Anonymised Data and Aggregated Data such as statistical or demographic data for any purpose. Anonymised and aggregated data may be derived from your personal data but is not considered personal data in law if this data does not directly or indirectly reveal your identity. For example, we may aggregate statistics to understand usage of our website and our platforms.
We do not specifically collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We only collect it to the extent it is apparent from other information we collect about you. We may collect information about criminal convictions and offences as part of checks carried out to comply with our regulatory obligations, such as anti-money laundering, financial crime, sanction and know your client checks.
3. How we collect your personal data
We use different methods to collect data from and about you including:
Information provided by your Investment Adviser. If you are a Customer, your Investment Adviser will provide us with the information we need to open an account for you and to provide you with our custody, settlement and transactional services. This will include your Identity Data, Contact Data, Background Check Data and Services Data.
Information you provide. You may give us your Identity Data, Contact Data and Marketing and Communications Data by corresponding with us at industry events, by phone, by email, by filling in forms on our website or by posting comments to our website or LinkedIn page. This includes personal data you provide when:
You email us or you contact us through our website, including through our complaints page;
As an Investment Adviser, you set up user accounts to access our services on behalf of your Customers;
You give us your business card or request information about us or our services to be sent to you;
You purchase our products and services;
You communicate with us to sell us your products or services;
You register to attend events we organise, sponsor or attend; or
You provide us with feedback, including comment on our posts and blogs.
Information we collect about you. We collect the following information:
Services Data when we undertake any of our custody, settlement and transaction services on your behalf;
As you interact with our website and our platforms, we will automatically collect Technical Data about your equipment, browsing actions and patterns and Usage Data about how you interact with our website and other platforms and whether you open, or click on links within, our marketing-related emails. We collect this personal data by using cookies, pixels, server logs and other similar technologies. Please see our Cookie Policy for further details.
· Information we receive from other sources. We will receive personal data about you from various third parties and public sources as set out below:
Background Check Data from governmental and third party identity record databases and credit reference agencies;
Technical Data and Usage Data from analytics providers and from lead generation providers identifying the company IP addresses of website visitors;
Identity Data and Contact Data shared with us by lead generation service providers;
Identity Data and Contact Data which we collect from publicly available sources such as LinkedIn, press articles and publications, personal blogs and other websites.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where you have given your consent to the processing of your personal data for a particular purpose.
Where it is necessary for the performance of a contract with you or to take steps to enter into a contract with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Purposes for which we will use your personal information
The purposes for which we will process your personal information and the lawful basis of processing on which we rely are described below.
| Purpose/Activity | Lawful basis for processing including basis of legitimate interest |
|---|---|
| To carry out anti-money laundering, sanctions, know your client and other regulatory checks | Necessary to comply with a legal or regulatory obligation |
| On the instruction of your Investment Adviser, to onboard you as a Customer, open an account for you and to provide you with our custody, settlement, transaction and associated services | Performance of a contract with you |
| As a Customer to send, via your Investment Adviser, contract notes, custody statements and other information about your assets | Performance of a contract with you Necessary to comply with a legal or regulatory obligation |
| The provision of Customer transaction reports to regulatory authorities as required by law and regulators | Necessary to comply with a legal or regulatory obligation |
| To provide our investment administration services to you as an Investment Adviser, including the handling your Customer’s personal information and the provision of information about your Customer’s assets | Performance of a contract with you Necessary to comply with a legal or regulatory obligation Necessary for our legitimate interests (to provide our services) |
| As an Investment Adviser, to register you as a user of our services and create your user accounts so that you may access our investment administration services | Performance of a contract with you |
| As an Investment Adviser, to administer and support the services you have requested, provide service notifications, manage and support the provision of your services, to manage and collect payments and to exercise our legal rights | Performance of a contract with you Necessary for our legitimate interests (the efficient running of our business and services, to recover amounts due to us and to protect and assert our legal rights) |
To manage our relationship with you which will include:
|
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated, to manage and improve our services and the efficient running of our business) |
| As an Investment Adviser, to send you information about new features or functionality of our services | Necessary for our legitimate interests (so that we can market and sell our products and services) |
| To build a database of contacts and prospective investment advisers who might be interested in our products and services and to inform our marketing and sales activities, including market mapping, client and prospect mapping and analysis | Necessary for our legitimate interests (so that we can market and sell our products and services) |
| To send you our marketing communications and invite you to events and webinars |
Your consent (if your consent is required) Necessary for our legitimate interests (so that we can market our products and services to B2B customers) |
| To follow up sales leads whether sourced by way of demo request, request for information, sign up to our events, by third party lead or from internal research and to enter into negotiations with you to purchase our services |
Necessary for our legitimate interests (to qualify sales leads and to make sales of our products and services to grow our business) Performance of a contract with you |
| To use data analytics to improve our website, platforms, products/services, marketing, user relationships and experiences |
Your consent (to the setting of cookies) Necessary for our legitimate interests (to improve our products and services based on user experience, to keep our websites and platforms updated and relevant, to develop our business and to inform our marketing strategy) |
| To purchase goods and services from you for our business | Necessary for our legitimate interests (to provide and manage our services and the efficient running of our business) |
| To administer, protect and manage our business and website (including troubleshooting, business operational analysis, testing, system maintenance, support, reporting and hosting of data) |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, business performance analysis, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation |
Marketing and Opting out
As an Investment Adviser or a prospective client, you may receive our communications or invitations to our events if you have requested information from us, if you provided us with your details or if we have identified you as someone who may be interested in our products and services and you have not unsubscribed from our marketing communications.
You can unsubscribe from our marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing DPO@multrees.com at any time.
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Notice.
5. Providing your personal data to others
Others with whom we may share personal data
We share your personal data with selected third parties, including:
Members of our group, which includes MIS Nominees (Luxembourg) S.A.R.L and IMWS (Nominees) Limited, our nominee entities which may hold your investments. Our nominee entities act as our processors;
Banks and sub-custodians which Multrees uses to hold your cash and investments so that you may hold the investments you or your Investment Adviser on your behalf wishes;
Clearing houses, market exchanges and counterparties with which Multrees enters into transactions on your behalf;
Regulators which require details of all transactions undertaken;
We share limited personal data with the above entities as reasonably required so that we may provide you with custody, settlement and transactional services for your investments. Each of these parties will process your personal data on Multrees’ instruction in accordance with applicable regulatory requirements. Other than our nominee entities these third parties act as controller, their own privacy notices will apply to their processing of your personal data. Please email DPO@multrees.com if you would like copies of the privacy notices.
third party service providers acting as processors who we use to help manage our business and services. Please email DPO@multrees.com for copies of their privacy notices.
insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims.
taxation authorities, regulators, law enforcement agencies and other authorities if required by such authorities or by due process of law.
third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
6. International transfers of your personal data
We will transfer your personal data as instructed by your Investment Adviser in your behalf to any country in which you hold investments, undertake transactions or from where you derive income or profits. If these countries are outside of the UK or EEA, your personal data may not be protected to the same extent as in the UK and EEA.
Your personal information will be processed by us in the UK and the European Economic Area (EEA). Some of your personal data may be transferred, stored and/or processed outside of the UK and the EEA where our suppliers operate from outside of these jurisdictions. In using such suppliers, we ensure a similar degree of protection is afforded to your data by utilising data transfer safeguards prescribed by data protection laws. Please email DPO@multrees.com if you would like details of the appropriate safeguards.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Retaining and deleting personal data
We will keep your personal data required to provide custody related services for the duration of the period in which we are providing such services and for 7 (seven) years from the end of the year in which our relationship with your Investment Adviser terminates.
We will keep the personal data we require to demonstrate compliance with financial regulations (including anti money laundering legislation) for no longer than 7 (seven) years after the end of the year in which our relationship with your Investment Adviser terminates, at which point the personal data will be destroyed.
By exception, Multrees may be required to retain personal data for longer in order to comply with applicable laws and regulations.
With respect to Marketing and Communications Data, we will retain your personal data for so long as you do not wish to unsubscribe from our marketing communications.
Where permissible, we will also delete your personal data on your request. Information on how to make a deletion request can be found in Section 9, Your rights.
Where we no longer need to process your personal data, we will delete your personal data from our systems unless we need to retain a limited amount of information to make sure that we act in accordance with your wishes.
Please email DPO@multrees.com if you would like further details of our retention periods for different kinds of personal data.
9. Your rights
You have certain legal rights with respect to your personal information depending on your location and applicable laws. You may exercise your rights at any time by contacting us at DPO@multrees.com
Your rights if you are resident in the UK or the EEA
Right of access
You have the right to access any personal data we hold about you: we will provide a copy of your personal data that we hold together with details of the purposes of the processing, the types of personal data we hold and the people to whom your personal data has been disclosed.
Right to rectification
You have the right to have inaccurate or incomplete personal data corrected or to restrict the processing of personal data whilst the accuracy is checked.
Right to erasure
You have the right to ask to have personal data we hold about you erased. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with law.
Right to data portability
In certain circumstances, you have the right to have data we hold about you transferred to yourself or another data controller. Note, this right only applies to information that is processed by automated means which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to object
You have the right to:
ask us not to process your personal data for direct marketing purposes
object, on grounds relating to your particular situation, to the processing of your personal data (including profiling) where we are relying on a legitimate interest .
Right to withdraw consent
You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
Right to complain
You have the right to lodge a complaint with the UK Information Commissioners Office or other data protection supervisory authority applicable to you if you are unhappy with the way we are handling your personal data.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Contact Us
If you have any questions or complaints about this Privacy Notice, please send an email to: DPO@multrees.com
Or write to:
F.A.O. The Data Protection Officer
Multrees Investor Services Limited
40 Princes Street
Edinburgh
EH2 2BY