Privacy Policy
The Boston Merchant Financial Privacy Policy explains how we use personal information that we collect about you (such as your residential address, email or contact numbers) (“your information”), how we share your information and the steps we take to protect your information. Specifically, this policy covers:
• How we collect your information.
• How we use your information.
• Information Sharing.
• Information Sharing Outside of the UK.
• Information Security.
• Cookies.
•Your rights.
• How to contact us.
Before you register and open an account with us you should read over this Privacy Policy. When you register with BMF or ask us to provide you with any of our products or services, you agree that we may handle your information in accordance with this Privacy Policy.
Please note that there may be revisions of this Privacy Policy from time to time by posting a new version on our website. You should check our website periodically for any changes which may affect you.
How We Obtain Your Information
We may obtain your information when you open an account with us, when you ask us to provide you with any of our products or services, when you communicate with us over the telephone, when you write to us and when you visit our website. We use cookies to collect information about your use of our website.
How We Use Your Information
We use your information to enable you to open an account with us and, once your account opening process with us is complete, for the administration of your account, to contact you, to update our records about you, and to respond to and process your queries and requests.
Our products and services
We use your information so we can supply you with our products and services which you use and to meet our contractual obligations to you. We also use your information to notify you about changes or developments relating to our products and services which you use.
Prevention and detection of crime
Boston Merchant Financial Limited and our products and services are subject to the Money Laundering Regulations 2007 and regulation by HM Revenue and Customs.
We may be required by the Money Laundering Regulations 2007, by HM Revenue & Customs, by the FSA or other regulatory bodies, by the police or other law enforcement agencies, by a court or otherwise by law to use your information in the detection, prevention or prosecution of crime, tax evasion or fraud.
Marketing
We may use your information to send you information concerning our products or services which you use and our latest products or services which we think may be of interest to you. This may include information concerning promotions or offers which could benefit you.
If you do not wish to receive this information from us, please tell us at registration. If you change your mind after registration, please contact us to let us know by using our contact details found at the end of this Privacy Policy or, if we have sent you this information by email, by following the instructions in our email.
Monitoring
We monitor and record our telephone calls with you and use any transcripts of them:
• so we can be sure we fully understand the instructions you give us and our obligations to you.
• so we have a clear record of the products and services you have requested.
• for the purposes of the prevention or detection of money laundering or crime, including fraud.
• for the purposes of training and quality control.
Boston Merchant Financial Group
We may share your information with other members of the BMFN group of companies where we need to do so to provide you with any of the products or services you have requested or where you have asked us to do so.
Your instructions
We may share your information with anyone (for example, an agent) who you have told us or who we are otherwise aware is acting on your behalf, or who introduces you to us, or who you have asked us to contact.
Legal requirements
We may have to share your information with a government body or regulatory authority (such as HM Revenue and Customs or the FSA), with the police or other law enforcement agencies (for example, in connection with criminal prosecutions, money laundering or fraud investigations), or with other persons or bodies by order of a court or to meet a legal or regulatory requirement or for other lawful reasons, such as for taxation or audit purposes.
Credit controls or debt collection agencies
We may share your information with credit control or debt collection agencies, for example, if you owe us money and we engage their services to recover it from you.
On a business sale or purchase
If we decide we want to sell our business or receive an offer to buy our business we may have to share your information with a prospective purchaser and their legal, financial or other advisers. In these circumstances, we will take appropriate steps to ensure that your information is properly protected.
Others
We will not normally share your information with anyone else unless we need to do so to provide you with our products or services which you use or unless you have asked us to do so.
You may sometimes ask us about, or we may sometimes ask you if you are interested in, products or services which we are unable to provide but which someone else we know that may be able to provide (for example, travel, furniture removal, haulage or financial services). We will never pass your information unless you have asked us to do so. Please note that we are not responsible for and cannot be liable to you for any products or services offered by third parties as affiliates of Boston Merchant Financial.
Information Sharing Outside of the UK
The nature of our products and services means that we may need to share your information with people or businesses based in countries outside of the United Kingdom, including in the EEA and outside the EEA. The EEA (or “European Economic Area”) comprises the EU member states, Iceland, Lichtenstein and Norway.
The countries to which we may need to send your information would normally be obvious to you. For example, if you have instructed us in connection with a purchase of a property in France then we will usually be dealing with people or businesses based in France (which may include banks, lawyers and estate agents) that are connected with the purchase in order to fulfill our contractual obligations to you. In many instances we will be dealing with people or businesses which you have asked us to deal with or who you already know or who already know you.
Information Security
General
We use your information only in accordance with this Privacy Policy and take all steps reasonably necessary to ensure we keep your information secure, for example by:
• encrypting our online service via a secure 128-bit VeriSign service.
• providing you with password protection and a log-in process designed to protect against certain well known viruses.
• making our online service automatically log you out after several minutes of non-use.
• disabling your access after multiple failed log-in attempts.
• maintaining our servers in multiple secure locations and having our online service penetration tested regularly by external experts.
Information security outside of the UK
All countries in the EEA have similar standards of legal protection for personal information. For this reason, we will not normally take further steps to ensure your information is protected when we share it with other people or businesses based in the EEA.
Where we share your information with people or businesses based outside of the EEA, if they are based in a country approved by the Information Commissioner (at the time of writing our Privacy Policy, this includes Switzerland, Hungary, Canada, Argentina, Guernsey and the Isle of Man) or are a signatory to what is known as the “Safe Harbour” regime (which applies to certain companies in the USA), then we will not normally take further steps to ensure your information is protected.
Where we share your information with people or businesses based outside of the EEA and they are neither based in an Information Commissioner approved neither country nor a signatory to the Safe Harbour regime, we will normally take appropriate steps to ensure that your information is suitably protected.
Your instructions
Where we share your information with people or businesses which you ask us to deal with or who you already know or who already know you, wherever they are based, we will not normally make any further enquiry concerning them or take any further steps to ensure your information is protected.
Worldwide Web
The Internet is not a secure environment.
While we take reasonable measures to keep your information secure, we cannot guarantee your online data security. We are not liable to you for any loss of data, injury or harm which occurs to you as a result of the transmission of your information over the Internet, unless this occurs as a result of our own negligence or willful misconduct.
Cookies
Cookies are harmless text files that web servers can store on your computer’s hard drive when you visit a website and allow a server to recognize you when you revisit. They are commonly used by companies providing online products and services.
There are two main types of cookie: “transient” cookies (which can recognise you as you move between pages, exist only for your visit and are deleted on exit) and “persistent” cookies (which can store and re-enter log-in information so you don’t need to remember them and stay on your machine until their expiry or deletion).
We use both types of cookies to try and make using our website as straightforward as possible and help us maintain standards. For example, we use cookies to: gather journey information, help ensure your privacy, store your log in details or other information required for tools provided for you to use, store details of your preferences, and generally to evaluate the performance of our products and services and enhance your customer experience. We use cookies that we create and cookies that are created by third parties (for example, by those who supply products and services to us so we can provide you with our products and services, such as hosting services).
You are not obliged to accept cookies that we send to you and you can modify your browser so that it will not accept cookies. You should follow the instructions in your browser (usually located within the “Help”, “Tools” or “Edit” facility) to enable or disable cookies. However, please note that in order to view and/or use some of our products and services, and to enable some of the protection we provide for your financial and personal information, cookies are required on your browser. Disabling the use of cookies may therefore affect our ability to provide you with our products and services, the effectiveness of our products and services or our ability to properly protect you.
Further information concerning cookies and how to manage them to suit your preferences can be found by visiting:
http://www.allaboutcookies.org or http://www.cookiecentral.com
Your Rights
We are required to handle information which we hold about you that is capable of identifying you (either alone or with any other information we may hold about you) in accordance with the Data Protection Act 1998 (“the Act”), which regulates the use of “personal data” in the United Kingdom.
You have the right under the Act to ask us in writing for details concerning the “personal data” we hold about you, including a description of that data, the purposes for which it is being used and to whom that data has been or may be disclosed. We may charge you an administration fee for providing you with this information.
You can find out more about the Act and your rights by visiting the website of the Information Commissioner at www.ico.gov.uk The Information Commissioner's Office can also be contacted by telephone on 08456 306060.
How to Contacts Us
If you have any questions about our Privacy Policy or your information, please contact us in writing by
Email at dataprotection@bmfn.co.uk or by post to the Compliance Officer
Boston Merchant Financial Ltd
9 Wimpole Street, London, W1G 9SR
Boston Merchant Financial Ltd, a company registered in England with Company No. 7621635, and a registered office at 9 Wimpole Street, London, W1G 9SR, London, United Kingdom
Email:info@bmfn.com
www.bmfn.com
Tel: +44 (0)xxx xxx xxxx
Fax: +44 (0)xxx xxx xxxx
Boston Merchant Financial is authorised and regulated by the Financial Services Authority (FSA) under the Payment Services Regulations 2009 for the provision of payment services reference number xxxxxx. The address of the FSA is 25 North Colonnade, Canary Wharf, London E1F 5HS. Web: www.fsa.gov.uk. Tel: +44 20 7066 1000. Fax: +44 20 7066 1099.
Boston Merchant Financial is a registered money services business with HM Revenue and Customs No. xxxxxx
© 2011 Boston Merchant Financial. All rights reserved.