Sigma Treasury Management Limited: General Privacy Policy
(i) How Sigma Treasury Management Limited (“we”, “our”, “Sigma” “us”) use your information
- a) Sigma will collect and process data about our customers, their authorised users and visitors to our website for legal, regulatory, services fulfilment and development, systems analysis, administrative, contractual and legal compliance and governance and management purposes and to enable us to meet our legal and contractual obligations.
- b) Sigma may process personal data including, as appropriate:
- (i) for the purposes of developing our services, responding to enquiries, dealing with any issues, fault reporting, services provision, website development and website usage data and contract administration, invoicing, billing issues and legal claims.,
- (ii) in order to comply with legal requirements and obligations to third parties including with contracts and including any usage data, which by sending it to us you represent you have the full authority and rights to do so.
- c) More detailed information about the data Sigma processes and the purposes we use it for are set out in paragraphs (ii) and (iii) below and we reserve the right to update this policy from time to time and the latest version of it will be available on our website from time to time which shall apply.
- d) If you do not provide this data, we may be unable in some circumstances to comply with our obligations including the provision of products or services and in such circumstances we shall not be deemed in breach of any agreement as a consequence of that.
(ii) What data do we collect and process?
- a) the visitor or customer’s authorised users’ name, company name, business address, contact telephone number(s), email address and (if applicable), domain details, billing address and other information concerning any device used by you when accessing our website and the identity of that device and social media details (if applicable). When a visitor contacts us and/or requests information about Sigma, we will collect the visitor’s email address and all other contact and relevant information so that we may fulfil the visitor’s request. Some information provided to us may, either alone or when connected with other information to which we may have access, individually identify or otherwise comprise of personal data of that visitor, customer or authorised user.
(iii) For what purposes do we collect and use this data?
- a) Administering our systems and website;
- b) Providing and marketing our products and services;
- c) Operating and keeping a records for billing, account management, sales and product and service availability and performance;
- d) Informing our customers and prospects;
- e) Dealing with enquiries, faults and other issues;
- f) Complying with the law, our contracts and obligations (including regulatory obligations);
(iv) How long We will keep this information
- a) We will hold your personal data for as long as we have a lawful basis to do so including to ensure we meet our legal and regulatory obligations and to defend or pursue any legal claims and for our legitimate business.
(v) Our approach to information security
- a) To protect your information, Sigma have policies, standards and procedures in place to make sure that only authorised personnel can access the information, that information is handled and stored in secure and sensible manner and all systems that can access the information have the necessary security measures in place. To accomplish this, our employees, contractors and sub-contractors have roles and responsibilities defined in those policies and procedures.
- b) In addition to these operational measures Sigma also use a range of technologies and security systems to reinforce the policies.
- c) To make sure that these measures are suitable, Sigma perform audits to identify the areas of weaknesses and non-compliance. Additionally, all areas of the organisation are constantly monitored and measured to identify problems and issues before they arise.
(vi) Your rights
- a) When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases your response will be necessary before you can exercise these rights.
- b) The right to access information Sigma holds on you:
- i) At any point, you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we obtained the information from. Once we have received your request we will typically respond within 30 days.
- ii) There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee.
- c) The right to correct and update the information Sigma holds on you:
- i) If the data we hold on you is out of date, incomplete or incorrect, you have to inform us and your data be will be updated.
- d) The right to have your information erased
- i) If you feel that we should no longer be using your data or that we are illegally using your data, you can request the erasure of the data we hold on you.
- ii) When Sigma receives your request we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for our legitimate business or regulatory purpose(s)).
- e) The right to object to processing of your data:
- i) You have the right to request that Sigma stop processing your personal data. Upon receiving the request, Sigma will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data if we have a lawful basis to do so and also to comply with our other rights or obligations or to bring or defend legal claims.
- f) The right to data portability
- i) You have the right to request that we transfer your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request but we may retain copies of personal data where required under e(i) above.
(vii) Consent
- a) Where we need your consent to hold your personal data, we will obtain your consent through your acceptance of this privacy policy or otherwise through our agreement with the customer or you as applicable unless we otherwise have another legitimate basis to process it.
- b) Sigma does not rely on consent for processing your personal data where we otherwise have the legitimate basis to do so.
(viii) Sharing your information
- Where necessary to fulfil our obligations to you or to fulfil our obligations to our customers, and to administer the services, understand your use of our website or services and any billing and collections, and compliance with the law, regulation and any contractual obligations we have (including where we may be acting as a broker or intermediary for anyone else), Sigma may pass your details to third parties and anyone else that we are legally obliged to share that personal data with. These third parties include our customers, our sub-processors, shareholders, other contractors and support services providers which support our services provision or otherwise provide our hosting facilities and our professional advisers, credit reference and debt collection agencies, regulators, licensed regulated entities with whom we have arrangements, banks and other third parties engaged with our business.
(ix) Cookie Policy
We use a number of different cookies on our site. If you do not know what cookies are, or how to control or delete them, then we recommend you visit http://www.aboutcookies.org for detailed guidance. The list below describe the cookies we use on this site and what we use them for. Currently we operate an ‘implied consent’ policy which means that we assume you are happy with this usage. If you are not happy, then you should either not use this site, or you should delete the cookies having visited the site, or you should browse the site using your browser’s anonymous usage setting (called “Incognito” in Chrome, “InPrivate” for Internet Explorer, “Private Browsing” in Firefox and Safari etc.)
First Party Cookies
These are cookies that are set by this website directly.
Google Analytics:
We use Google Analytics to collect information about visitor behaviour on our website. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. This Analytics data is collected via a JavaScript tag in the pages of our site and is not tied to personally identifiable information. We therefore do not collect or store your personal information (e.g. your name or address) so this information cannot be used to identify who you are.
You can find out more about Google’s position on privacy as regards its analytics service at https://www.google.com/policies/privacy/
WordPress:
Our websites runs on the popular WordPress CMS and cookies are used to store basic data on your interactions with WordPress, and whether you have logged into WordPress. We use a session cookie to remember your log-in if you are a registered user and we deem it to be necessary to the working of the website. If the session cookie is disabled then various areas of the site will break.
More information on session cookies and what they are used for at http://www.allaboutcookies.org/cookies/session-cookies-used-for.html
Third Party Cookies
These are cookies set on your machine by external websites whose services are used on this site. Cookies of this type are the sharing buttons across the site allowing visitors to share content onto social networks. Cookies are currently set by LinkedIn, Twitter, Facebook and Google+. In order to implement these buttons, and connect them to the relevant social networks and external sites, there are scripts from domains outside of our website. You should be aware that these sites are likely to be collecting information about what you are doing all around the Internet, including on this website.
You should check the respective policies of each of these sites to see how exactly they use your information and to find out how to opt out, or delete, such information.
Further Information
Please contact us at dataprotection@sigma-treasury.com if you require further information about cookies stored on any of our websites.
(x) Contact details
If you have any queries about this notice, need further information or wish to lodge a complaint you can use the details below to contact the relevant party. In the event that Sigma has been unable to resolve your concerns you can raise the matter with the ICO directly by telephoning them on 0303 123 1113 or engaging in their live chat.
Or contact Sigma Compliance: Ian Langrish
email: dataprotection@sigma-treasury.com
Data Controller: SIGMA TREASURY MANAGEMENT LIMITED, 20th Floor, 125 Old Broad Street, London, EC2N 1AR.
2021 Sigma Treasury Management Limited
