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Privacy Policy
Magna Carbon is responsible for ensuring that it uses your personal data in
compliance with data protection law. The purpose of this notice (the “Privacy Notice”)
is to explain what personal data Magna Carbon collects and how Magna Carbon
uses it. For the purposes of data protection law, Magna Carbon is a data controller
in respect of your personal data. “Personal data” is any data that can be used to
identify you or that Magna Carbon can link to you and which Magna Carbon has in
its possession or control.
In this Privacy Notice when we refer to “Magna Carbon” or “we”/“us”/“our” we mean
Magna Carbon and our Associates. You can find contact details for our Associates,
and the details of the data controllers within Magna Carbon, by contacting us
Personal data that Magna Carbon collects
Magna Carbon will collect and process the following personal data:
Information that you or someone acting on your behalf provides to Magna Carbon
or its Associates. This includes information about you that you give Magna Carbon
by filling in forms, signing up for services on our website or by communicating with
Magna Carbon, whether face-to-face, by phone, e-mail or otherwise. If you are a
client or are connected with one of our client’s matters, this may include personal
data about you or others that is provided to Magna Carbon in connection with the
provision of services to that client.
Information Magna Carbon collects or generates about you. We will also collect
information about you when you use our services or when we otherwise interact or
correspond with you. We use various technologies to collect and store information
when you visit our websites. We may, for example, collect information about the type
of device you use to access the websites, your IP address and your geographic
location, the operating system and version, your browser type, the content you view
and features you access on our websites, the web pages and the search terms you
enter on our websites. For information about how we use Cookies and the choices
you may have, you can request a copy of our Cookies Policy by emailing
data.protection@.rothschildandco.com.
If you are a client, or are connected with one of our client’s matters, this information
may include:
information about you, your transactions, financial information and relationship to
others;
data that Magna Carbon collects about your use of Magna Carbon’s IT systems;
reports and information for tax reporting (e.g. FATCA) or compliance with legal or
regulatory obligations (e.g. insider lists, regulator information requests);
(where required by legal or regulatory obligations or otherwise where we have a
specific legal basis) recordings of telephone calls between you and Magna Carbon.
Information Magna Carbon obtains from other sources. If we collect or receive your
personal data in the context of our provision of services, we might receive
information from third parties such as your employer, other parties relevant to the
services we are providing (e.g. counterparties in transactions) and others such as
regulators and authorities. That information could include your name, contact details,
employment details and other information relevant to the services that we are
providing to our client.
Uses of your personal data
Personal data may be stored and processed by Magna Carbon in the following
ways and for the following purposes:
to provide Magna Carbon’s products and services, including processing
instructions and providing confirmations, advice and statements to our clients;
verify your identity (including for fraud prevention purposes), assess your ability to
meet your financial commitments (if any) and manage Magna Carbon’s relationship
with you and/or the client to whom you are connected;
to contact you in connection with your work with Magna Carbon and the products
and services that Magna Carbon provides to you or a client to whom you are
connected;
to perform the contract with you or a client/supplier to whom you are connected
(including performing Magna Carbon’s obligations and exercising Magna Carbon’s
rights);
to engage in marketing and business development activity and to advise you or a
client to whom you are connected of other products and services similar to those
which you or a client to whom you are connected receive from Magna Carbon
and/or its Associates;
to engage in Community Investment projects where you choose to participate;
to notify you about changes to Magna Carbon’s service;
to carry out financial risk assessments, risk mitigation activities and for risk reporting
and risk management;
to comply with Magna Carbon’s legal and regulatory obligations. This includes
reporting to the relevant authorities, complying with anti-money laundering
obligations and tax reporting obligations;
to use it to prevent and respond to actual and potential fraud or illegal activities; or
to use it to look into any complaints or queries you or a client/supplier to whom you
are connected may have.
Magna Carbon is entitled to use personal data in these ways because:
Consent - we may (but usually do not) need your consent to use your personal data.
You can withdraw your consent by contacting us (see below).
Performance of a contract - we may need to collect and use your personal data to
enter into a contract with you or to perform our obligations under a contract with you
or a client to whom you are connected.
Legitimate interest - we may use your personal data for our legitimate interests,
some examples of which are given above.
Compliance with law or regulation - we may use your personal data as necessary to
comply with applicable law/regulation.
Disclosure of personal data to third parties
Magna Carbon may disclose personal data to its Associates in the circumstances
described below:
to provide the services or perform its obligations in connection with your contract or
the contract of a client/supplier with whom you are connected;
for the management and administration of the Magna Carbon business;
for the management and administration of internal policies and procedures within
Magna Carbon.
Where personal data is disclosed to its Associates, Magna Carbon will take steps
to ensure that the personal data is accessed only by those persons who need to do
so for the purposes described in this Privacy Notice.
Magna Carbon may also disclose personal data outside of Magna Carbon and its
Associates, as follows:
to third party agents, service providers or contractors, bound by obligations of
confidentiality, who will only use personal data on Magna Carbon’s behalf for the
purposes described in this Privacy Notice;
to third parties relevant to the services outlined in the contract with you or the
contract of a client/supplier with whom you are connected. This may include for
example counterparties to transactions, professional advisers, stock exchanges or
regulators;
to the prospective counterparty, for due diligence purposes, if Magna Carbon and/
or Magna Carbon’s Associates restructure or sell any of its or their business or
assets (for the avoidance of doubt, your personal data would only be transferred in
such circumstances to the extent that such a transfer was required for the purposes
of due diligence and was subject to appropriate security protections e.g.
anonymisation and/or confidentiality restrictions);
to the extent required by law, regulation or court order for example if Magna Carbon
is under a duty to disclose personal data in order to comply with any legal or
regulatory obligation; and in order to establish, exercise or defend Magna Carbon’s legal rights, for example if
Magna Carbon needs to obtain external legal advice or provide personal data in
connection with judicial proceedings.
Transfers of personal data outside the European Economic Area
Personal data may be transferred to, and stored at, a destination outside the UK or
the European Economic Area (“EEA”). It may also be stored and processed by staff
operating outside of the UK or the EEA, who work for Magna Carbon’s Associates
or Magna Carbon’s third party agents, service providers or contractors.
Where Magna Carbon transfers personal data outside the UK or the EEA,
Magna Carbon will ensure that it is protected in a manner that is consistent with
how personal data will be protected by Magna Carbon in the UK and the EEA. This
may be achieved in one of the following ways:
the country that Magna Carbon sends the data to might be approved by the
European Commission or by a relevant data protection authority; or
the recipient might have signed a contract based on “model contractual clauses”
approved by the European Commission or by a relevant data protection authority,
obliging them to protect the personal data that they receive.
In other circumstances the law may permit Magna Carbon to otherwise transfer
personal data outside the UK or the EEA. In all cases, however, Magna Carbon will
ensure that any transfer of personal data is compliant with applicable data protection
law.
You can obtain further details of the protection given to your personal data when it is
transferred outside the UK or the EEA by contacting Magna Carbon in accordance
with the “Contacting Magna Carbon” section below.
Retention of personal data
How long Magna Carbon holds personal data for will vary. The retention period will
be determined by various criteria including:
the purpose for which Magna Carbon is using it - Magna Carbon will need to keep
the data for as long as is necessary for that purpose; and
legal obligations - laws or regulation may set a minimum period for which Magna Carbonhas to retain personal data.
Rights in relation to personal data
You have a number of legal rights in relation to the personal data that Magna Carbonholds about you.
These rights include:
the right to obtain information regarding the processing of your personal data and
access to the personal data which Magna Carbon holds about you;
the right to request that Magna Carbon rectify your personal data if it is inaccurate
or incomplete;
the right to request that Magna Carbon erase your personal data in certain
circumstances. Please note that there may be circumstances where you ask
Magna Carbon to erase your personal data but Magna Carbon is legally entitled to
retain it;
the right to object to, and the right to request that Magna Carbon restrict, its
processing of your personal data in certain circumstances. Again, there may be
circumstances where you object to, or ask Magna Carbon to restrict, its processing
of your personal data but Magna Carbon is legally entitled to continue processing
your personal data and / or to refuse that request;
in some circumstances, the right to receive some personal data in a structured,
commonly used and machine-readable format and/or request that Magna Carbon
transmit such data to a third party where this is technically feasible. Please note that
this right only applies to personal data which you have provided to Magna Carbon;
the right to withdraw your consent, although in certain circumstance it may be lawful
for Magna Carbon to continue processing your data where Magna Carbon has
another legitimate reason (other than consent) for doing so. Magna Carbon is not
relying on your consent in order to process your personal data for the purposes and
in the manner set out in this Privacy Notice; and
the right to lodge a complaint with the relevant data protection authority if you think
that any of your rights have been infringed by Magna Carbon.
You can exercise your rights by contacting Magna Carbon using the details set out
in the "Contacting Magna Carbon" section below.
You can find out more information about your rights by contacting the relevant data
protection authority. We can, on request, tell you which data protection authority is
relevant to the processing of your personal data.
Contacting Us
If you would like further information about Magna Carbon’s processing of your
personal data or the exercise of any of the rights referred to above, please address
questions, comments and requests to
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