Privacy policy

Introduction

Welcome to Mercurae Limited’s privacy policy.Thank you for using our website, mercurae.com (the Site).Mercurae Limited (Mercurae) respects your privacy and is committed to protecting your personal data. This privacy policy informs you as to how we look after your personal data when you visit our Site (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.By using the Site you accept the practices described in this Privacy Policy.Questions or comments may be addressed to: info@mercurae.com .Our contact details Mercurae Limited, Second Floor, 10 Rathbone Place, London W1T 1HP. Policy last updated: 30 June 2024

GDPR notice

When you are located inside the United Kingdom or the European Economic Area (currently comprised of the European Union countries, Iceland, Liechtenstein, and Norway), the General Data Protection Regulation (GDPR) or the UK GDPR applies. The GDPR and UK GDPR do not apply to any person, including citizens of the EEA nations, who are located outside of these areas. If the GDPR or UK GDPR applies to you, then you have a number of important rights free of charge, which are set out in this policy. Please also use the Glossary at clause 8 to see the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of the Privacy Policy

This privacy policy aims to give you information on how Mercurae collects and processes your personal data through your use of this Site, including any data you may provide through this Site at any time.This Site is not intended for under 18 year olds and we do not knowingly collect data relating to children.It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Mercurae Limited is the controller and responsible for your personal data (collectively referred to as “Mercurae””, “we”, “us” or “our” in this privacy policy).You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:Identity Data, for those who provide their name.Contact Data including your email address.Technical Data includes your internet protocol (IP) address, your login data, 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 this Site.Usage Data includes information about how you use our Site, products and services including page views, routes taken through pages on the site and mouse movement within pages.We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.We do not 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). Nor do we collect any information about criminal convictions and offences.

If you fail to provide relevant personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:apply for our services;subscribe to our service;request marketing to be sent to you;enter a competition, promotion or survey; orgive us feedback or contact us.Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:Technical Data from analytics providers such as Google based outside the EU.

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 we need to perform the contract we are about to enter into or have entered into 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.Please see clause 9 (Glossary) to find out more about the types of lawful basis that we will rely on to process your personal data.Generally, we rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATAWe have set out below a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.  
The type of personal information we collect 
We currently collect and process the following information:Personal identifiers, contacts and characteristics (for example, name, contact details, KYC/AML information, information derived from and as part of your instructions).
How we get the personal information and why we have it
Most of the personal information we process is provided to us directly by you as a client or prospective client.We use the information that you have given us in order to provide a better service to you, and for analytical purposes in connection with the performance of the website. 

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are: (a) Your consent. You are able to remove your consent at any time. You can do this by contacting admin@mercurae.com(b) We have a contractual obligation.(c) We have a legal obligation.(d) We have a vital interest.(e) We need it to perform a public task.(f) We have a legitimate interest.

How we store your personal information

Your information is securely stored within the European Economic Area. We keep personal information for no longer than is necessary or appropriate. We will then securely delete your information 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with Third Parties (see Glossary) for the purposes set out above.We require all Third Parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.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.

7. DATA RETENTION

How long will you retain my personal data?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.In some circumstances you can ask us to delete your data (see below).In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. YOUR GDPR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include:

Request access to your personal data. You have the right to ask us for copies of your personal information. 

Request correction of your personal data. You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Request erasure of your personal data. You have the right to ask us to erase your personal information in certain circumstances.

Object to processing of your personal data. You have the  right to object to the processing of your personal information in certain circumstances.

Request restriction of processing your personal data. You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Request transfer of your personal data. You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

Right to withdraw consent. If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. Please contact us at admin@mercurae.com or Mercurae Limited, Second Floor, 10 Rathbone Place, London W1T 1HP if you wish to make a request.

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 could 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.

9. GLOSSARY

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

Service providers who provide IT and system administration services. Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. HM Revenue & Customs (HMRC), regulators and other authorities who require reporting of processing activities in certain circumstances. How to complain If you have any concerns about our use of your personal information, you can make a complaint to us at admin@mercurae.com. You can also complain to the ICO if you are unhappy with how we have used your data. The ICO’s address:            

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Helpline number: 0303 123 1113ICO website: https://www.ico.org.uk