At Twelve Squared Capital Ltd. we respect the confidentiality of our clients’ personal information and thus we are committed to ensuring the security of any information Twelve Squared Capital Ltd. is provided with by our prospective and / or existing clients as well as by visitors of our corporate website www.tsqcapital.com, i.e. through this website. This code of confidentiality applies for any further information a new client or respectively an existing client provides Twelve Squared Capital Ltd. within the course of electronic and physical correspondence with Twelve Squared Capital Ltd. All prospective and /or existing private clients of Twelve Squared Capital Ltd. are treated as Data subjects in the sense of the Data Protection regulation 679/2016/EU. With regards to the provisions of the aforementioned regulation, the local management and / or the Universal Beneficial Owner(s) of all prospective and /or existing corporate clients of Twelve Squared Capital Ltd., which are physical persons that represent a legal person, are treated as Data subjects in the sense of the aforementioned regulation.
In order to provide regulated financial services to our clients efficiently and accurately, when each new client applies to register to use our regulated services, we ask of them to submit certain personal information to Twelve Squared Capital Ltd. during the client's assessment and Due Diligence procedure, as well as during the process of the Appropriateness Test and / or Suitability Analysis. For regulatory compliance, this may include client’s full name, date of birth, home and work addresses and telephone numbers, email address, passport number/or ID number, marital status, government issued photo ID with signature, financial information such as estimated annual income, net worth, liquid assets, previous trading experience and risk tolerance. The disclosure of the information as mentioned within this paragraph to Twelve Squared Capital Ltd. is to be submitted willingly by the prospective and / or existing client. Besides the above, we may also gather certain information about the clients' use of our services. This may include information from which they can be identified such as the times they log on (for instance, IP address, type of computer or telecommunication device used for accessing our corporate website, geographical location and internet access service provider of an individual visitor), their volume of use of our corporate website, the types of data, systems and reports they access, duration of sessions and other similar data. This data as described in this paragraph is collected automatically by the IT infrastructure of Twelve Squared Capital Ltd. Twelve Squared Capital Ltd. offers the collection of KYC data from our prospective and / or existing clients via online services by external service partners, which remain legally and economically independent from Twelve Squared Capital Ltd. Please refer to our DPO at firstname.lastname@example.org on further information on the protection of your personal data, which you may submit to us via these services. Furthermore, Twelve Squared Capital Ltd. collects personal information, which is related to an individual visitor of our corporate website by the use of the contact form in the 'contact us' section of our corporate website. At Twelve Squared Capital Ltd., incoming and outgoing telephone calls may be recorded for training and monitoring purposes. Twelve Squared Capital Ltd. fulfills the role of the Data Controller of all data that the company collects from individual visitors of our corporate website as well as from our prospective and / or existing clients in line with the requirements of the Data Protection Regulation 679/2016/EU.
Twelve Squared Capital Ltd. takes responsible to store your information in its protected physical archives and protected electronic databases for reference in order to answer queries or resolve problems, provide improved and new services and to meet any legal data retention requirements and regulatory compliance requirements. This means we may retain your information after you stop using the Site or our services or otherwise interacting with us over the applicable time period of five years, starting by the date your terminate your relations with Twelve Squared Capital Ltd. All electronic information you provide us with is stored on secure and protected servers. The transmission of information via the internet is secured using Secure Socket Layer (SSL) technology with high security 128bit encryption. However, we have put in place various internal security procedures and a Business Continuity Plan (BCP) as set out in this policy. Once we have received your information, we strictly follow these procedures and security features in order to prevent unauthorized access.
You have a choice to supply any or all of the personal information required. However, missing information may result in Twelve Squared Capital Ltd. being unable to open or maintain your account and /or to provide you with our services. If you feel the rights to your personal data had been infringed by Twelve Squared Capital Ltd., please get in touch with our DPO at email@example.com.