Bosomeer ‘s long-standing commitment to safeguard the privacy of information our clients entrust to us is essential to our goal to be the world’s first choice for financial services. Protecting the confidentiality and security of client information has always been an integral part of how we conduct our business.  

We pledge to continue to ensure that our global business practices protect your privacy.

We respect your Privacy

Bosomeer collects, holds, uses, verifies and discloses (“processes”) information about individuals which may constitute personal data, under applicable data protection and privacy laws in Europe, Middle East and Africa, as well as Switzerland, Russia (“EMEA”), Asia Pacific.

Please read this Privacy Policy carefully to understand how we process your personal data.

1. What personal data we collect?

We will request sensitive personal data from employees, applicants for employment or individuals wishing to provide services to us. Such data includes information about your racial or ethnic origin, political opinion, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, sexual orientation or practices, criminal record, genetic information, health information or medical history. As with any personal data, we will only collect and process sensitive information where we have a legal basis for such collection and processing, including where required or permitted under applicable law or where we have your consent (where we are legally required to do so).

Of course, you are not required to supply any of the personal data that we request. However, failure to supply any of the personal data that we request may result in our being unable to provide services to you or your company, discuss any other opportunities with you or deal with other matters.

While we make every effort to ensure that all personal data we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal data. To extent permissible under applicable law, we shall not be responsible for the authenticity of any personal data or sensitive personal data or any losses arising from any inaccurate or deficient personal data or sensitive personal data that you supply to us.

2. How do we collect your personal data?

The personal data we collect regarding you comes primarily from information that you submit to us or that is otherwise captured during the course of your relationship with us. For employees or applicants for employment, we obtain personal data about you from your resume or job application form. For individuals employed by a company providing service to Bosomeer, we request personal data about you from your employer. We also collect personal data when we monitor or record our communications with you or through use of certain technology as detailed further below.

3. Personal data obtained from other sources

We also obtain your personal data from our agents or service providers acting on our behalf, from third parties authorized to provide us with such information, such as credit reporting bodies, other credit providers or other agencies used for running due diligence checks, authorized third parties performing identity verification procedures on our behalf and/or from third parties who provide services to you.

The personal data we obtain through these sources include personal details, contact details, identification documents, personal identifier, financial account information, and where permitted by applicable law and only to the extent needed information relating to political affiliations, trade union membership or criminal convictions. Some of this information is publicly accessible and/or reliable and independent databases that we access through an authorized third party to whom we disclose your personal data for the purpose of performing required identity verification procedures.

4. What are the purposes and legal basis for which we use your personal data?

We are not allowed to process personal data if we do not have a valid legal ground. Accordingly, we, our associated firms and/or other persons acting on our or their behalf will only process and use your personal data:

(a) if necessary for our legitimate interests, (in each case provided such interests are not overridden by your privacy interests) or necessary for taking steps to enter into or executing a contract with you for the services or products you request, or for carrying out our obligations under such a contract, such as when we use your personal data including:

• Administer and operate services in accordance with the customer documents

• To provide operational support and development of our businesses including to evaluate customer service, efficiency and cost, as well as risk management purposes;

• To contact you about other services and products we offer (with your prior consent where required by applicable law);

• For monitoring purposes specified section 5 below; and

• For other legitimate interest as listed in (b) to (d) inclusive below.

(b) When dealing with us as an individual, where necessary for taking steps to enter into or executing a contract with you for the services or products you request; or for carrying out our obligations under such a contract, in this case, the provision of your personal data is a requirement necessary to enter into a contract with us, meaning that you are obliged to provide your personal data to us in order to carry out the relevant contract (which otherwise, we will not be able to do), including:

• For recruitment purposes, to confirm your references and educational background and to consider your suitability for any current or future recruitment requirements;

• In case of employees, to carry out the employment relationship, to fulfill our duties as an employer and to make use of our rights as employer; and

• For internal training purposes.

(c) To exercise and defend our legal rights anywhere in the world including in relation to any litigation, disputes or contentious matter we or that of any Associated Firm anywhere in the world are involved in and/or to assist with investigations, complaints, regulatory requests, litigation, arbitration, mediation or requests from individuals;

(d) In order to comply with legal and regulatory obligations and requests, (including any legal or regulatory guidance, codes or opinions), applicable to us anywhere in the world or for the performance of a task carried out in the public interest, including:

5. What monitoring do we conduct?

To the extent permitted by applicable law, we, our associated Firms or any other persons on our or their behalf access, review, disclose, intercept, monitor and/or record (“Monitor”) (i) verbal and electronic messaging and communications (e.g., telephone, facsimile, sms, instant message, email, Bloomberg and any other electronic or recordable communications) with you and your agent (“Communications”) and (ii) your use of technology owned by or made accessible by us, our Associated Firms or any other persons on our or their behalf, including but not limited to systems that facilitate Communications with you or your agent, information processing, transmission, storage and access, as well as remote access (collectively “Systems”).

We will only Monitor Communications and Systems to the extent permissible under applicable law from time to time for the following purposes:

a) to establish the existence of facts (e.g., keeping records of transactions);

b) to ascertain compliance with regulatory or self-regulatory practices or procedures which relate to our business;

c) to ascertain or demonstrate standards which are achieved or ought to be achieved by persons using Systems, including compliance with any terms of use associated with use of Communications and Systems;

d) to prevent, detect or investigate crime, money laundering, fraud, financial crime and/or other breaches of applicable law;

e) to comply with applicable laws and regulations, this Privacy Policy and any applicable policies and procedures;

f) to safeguard against the loss, theft, unauthorised and unlawful collection, use, disclosure, destruction or other processing or misuse of confidential and proprietary information

g) to prevent, detect or investigate unauthorised use of Communications and Systems and/or data (e.g., Monitoring to ensure compliance with the our policies and procedures, including without limitation those relating to information security and cyber security);

h) to ensure the effective operation of Bosomeer Systems (including telephones, email and internet) systems;

i) for security or health and safety purposes;

j) for support and administration purposes;

k) to assist with investigations, complaints, regulatory requests, litigation, arbitration, mediation or requests from individuals; or

l) for evaluating the quality of customer service, efficiency, cost and risk management purposes.

Monitoring is conducted by us using various methods, including: (i) the use of “intelligent” automated monitoring tools; (ii) IT filtering tools which randomly review Communications and Systems; (iii) through random monitoring of Communications and Systems, e.g. by authorised supervisors randomly joining on-going telephone calls on the sales and trading floors; (iv) specific monitoring of key Communications and Systems e.g. in relation to investigations, regulatory requests, subject access requests, litigation, arbitration or mediation or; (v) data tracking, aggregation and analysis tools that pull data from various disparate data sources to draw linkages and/or detect behavioral patterns, interactions or preferences for analysis (including predictive analysis); and/or (vi) using other similar Monitoring technology that may become available from time to time.

We also use cookies and similar technologies to collect information about you when you visit our websites or interact with us on-line e.g. via email or other electronic means. To find out more about how we use cookies and similar technologies, how we process the information obtained through cookies and how to reject cookies, see Our Global Cookies Policy.

6. When do we disclose personal data we collect about you?

You should know that:

• Bosomeer does not sell, rent or trade your personal data; and

• Bosomeer does not disclose your personal data, except as described in this Privacy Policy.

Our processing and use of your personal data, for the purposes specified in this Privacy Policy, includes disclosure of your personal data:

• Between us and our associated firms.

• To other persons processing your personal data on our behalf or otherwise providing us or them with professional or other services including our associated firms and vendors which conduct operational, technology and customer service functions in various jurisdictions;

• To persons to whom we assign or novate our rights or obligations;

• To national and international regulatory, enforcement or exchange bodies or courts anywhere in the world as required by applicable law or regulations anywhere in the world or at their request; and

• To any third party to whom you authorise us to disclose your personal data.

These disclosures involve overseas storage and other overseas transfer, processing and use of your personal data, and disclosure to these third parties, including in or to countries or territories where the laws may provide a different level of data protection. Without limiting the foregoing, your data will be disclosed by us to our associated firms and vendors which conduct operational, technology and customer service functions in various jurisdictions where Bosomeer operates. When personal data is transferred to such countries or territories not recognised under applicable law as offering an adequate level of data protection, we have put in place appropriate data transfer mechanisms as required under applicable law, (such as the EU Standard Contractual Clauses), to ensure personal data remains protected. You can obtain a copy of the relevant data transfer mechanism we have put in place to protect personal data by contacting us.

7. How do we protect your personal data we collect about you?

Bosomeer maintains appropriate physical, technical and procedural safeguards designed to protect any information that you provide to us from accidental or unauthorised loss, misuse, damage, modification, access or disclosure.

Bosomeer has established a Security Office, which leads efforts to:

• Safeguard the confidentiality and privacy of information resources;

• Properly classify information resources;

• Meet legal and regulatory obligations concerning the protection of information resources;

• Implement and maintain information security policies and procedures;

• Integrate protection of information resources into the process lifecycles of the business;

• Educate those working for or on behalf of Bosomeer on Information Security policies and responsibilities; and

• Authenticate users and limit access to information resources based on authorization that has been granted.

Third parties who process your personal data on our behalf are required to adhere to appropriate security standards designed to protect such information against unauthorised access, destruction or loss.

8. How do we retain your personal data?

We retain personal data in an identifiable form in accordance with our records retention policy which establishes general standards and procedures regarding the retention, handling and disposition of personal data. Personal data is retained as long as necessary to meet legal, regulatory and business requirements. Retention periods will be extended if we are required to preserve personal data in connection with litigation, investigations and proceedings. Upon request, we and/or our Associated Firms will provide you with more information on the exact retention periods applying to Your Information in each case.

 

9. How do we update this Privacy Policy?

We may change or update portions of this Privacy Policy to reflect changes in our practices and or applicable law and regulation. Please check this Privacy Policy from time to time so you are aware of any changes or updates to the Privacy Policy, which may be indicated by a change in the effective date noted at the beginning of the Privacy Policy. Where required under applicable data protection and privacy laws, we will notify you of any change or update portions of this Privacy Policy by individual message or by disclosing the changes to the data processing on a publicly available medium.

How do we use Cookies and similar Technology?

We, our associated firms and/or other persons acting on our or their behalf use cookies and similar technology to collect, use and share information when you visit our websites or interact with us on-line e.g. via email or other electronic means.

Cookies are small, usually randomly encoded, text files that help your browser navigate through our websites. The cookie file is generated by our website when you access it and is accepted and processed by your computer’s browser software or when you interact with us on-line. The cookie file is stored in your browser’s folder or subfolder.

Cookies and similar technology enable Bosomeer to capture and compile statistical information about how you use our websites and interact with us on-line, including information relating to the frequency of visits, IP addresses, readership data, (such as the average length of visits, which pages are viewed or shared during a visit or other interactions with our content such as time spent viewing videos, PDFs read and links clicked), authentication information, acceptance or rejection of website terms, periods of inactivity, time zones, language preferences and other regional information.

We, our associated firms and/or other persons acting on our or their behalf use this information for the following purposes:

• To assess the effectiveness of advertising and readership content;

• To improve the website content and performance;

• To estimate our audience size and usage pattern;

• To speed up your searches;

• To enable log in and authentication when you log onto our sites;

• To recognize you when you return to our sites;

• To deliver a better and more personalised service by allowing us to customise our site according to your individual interests; and

• To deliver marketing communications that may be of interest to you, including ads or offers tailored to you.

Information held in cookies or similar tracking technology set by Bosomeer are kept to a minimum and can only be read by Bosomeer, our associate firms, their authorized third parties or by someone who has physical access to your personal computer.

How can you manage your Cookie preferences?

Many web browsers allow you to control the use of most cookies through their browser settings. To learn more about cookies, including information on what cookies have been set on your computer and how cookies can be managed and deleted, visit www.allaboutcookies.org.

Our websites use Google Analytics to track your activity.

Most browsers are initially set to accept cookies. However, you have the ability to disable cookies if you wish, generally through changing your internet software browsing settings. It may also be possible to configure your browser settings to enable acceptance of specific cookies or to notify you each time a new cookie is about to be stored on your computer enabling you to decide whether to accept or reject the cookie. To manage your use of cookies there are various resources available to you, for example the “Help” section on your browser may assist you. You can also disable or delete the stored data used by technology similar to cookies, such as Local Shared Objects or Flash cookies, by managing your browser’s “add-on settings” or visiting the website of its manufacturer. As our cookies allow you to access some of our website’s features we recommend that you leave cookies enabled. Otherwise, if cookies are disabled, it may mean that you experience reduced functionality or will be prevented from using the site altogether. Unless you have adjusted your browser setting so that it will reject cookies, our system will issue cookies when you access or use our websites or online services. By accessing or using our websites or online services you consent to Bosomeer using cookies. In the event you refuse to accept cookies by adjusting your browser setting, some or all areas of our websites or online services may not function properly or may not be accessible.

How do we update this Cookie Policy?

We may change or update portions of this Cookie Policy to reflect changes in our practices and or applicable law and regulation. Please check this Cookie Policy from time to time so you are aware of any changes or updates to the Cookie Policy, which may be indicated by a change in the effective date noted at the beginning of this Cookie Policy.

How can you Contact Us?

If you would like to contact us in respect of any element of this Privacy & Cookie Policy, including, without limitation and subject to applicable data protection law, where you wish to exercise any of your data protection rights or where you wish to raise a complaint or grievance please contact contact us at:  [email protected] .

If you make a complaint about a breach of applicable data protection laws by Bosomeer, Bosomeer will respond as soon as possible to let you know who is responsible for managing your complaint. Bosomeer will investigate the complaint and where necessary we will consult with third parties who may be involved in the processing of your personal data. Bosomeer will respond to all complaints within such timeframes required under applicable law. If further investigation is required, it will be carried out and then you will be notified of a proposed remedy. This will be confirmed to you in writing.

If you do not receive a response from us within such timeframes required under applicable law or your complaint is not resolved within that time to your satisfaction, you may apply to the applicable data protection authorities to have your complaint heard and determined.

We will investigate any complaint and will notify you of the making of a decision in relation to your complaint as soon as is practicable after it has been made.