This website is not intended for individuals under the age of 18 years old and we do not knowingly collect data relating to such individuals.
For the purposes of this Policy, the relevant controllers are:
Bequant Prime Limited
House of Francis Room 303, Ile Du Port, Ile Du Port,
For the purposes of this Policy, the relevant processor is:
Bequant Servicing Limited
71-75, Shelton Street, Covent Garden, London, WC2H 9JQ, UK
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.
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:
We do not collect any Sensitive Personal Data about you. Nor do we collect any information about criminal convictions and offences.
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.
We use different methods to collect data from and about you including through:
We may also collect personal information from third parties such as organisations that you have dealings with, regulators, government agencies, credit reporting agencies, publicly available records (including electronic data sources to carry out checks to enable us to comply with applicable law), information or service providers (some of whom may process your personal information on our behalf) and third party platforms that we engage.
We will at all times minimise the collection and use of personal data to what is necessary to administer our business and deliver our services to you. In order to process your requests and transactions we will use the information provided by you. To serve you better, we may combine information you give us through various channels.
We do not seek to collect or otherwise Process your Sensitive Personal Data. We will only process your personal data when the law allows us to. Most commonly, we require your personal data in the following circumstances:
In addition, the processing may be based on your consent where you have expressly given that to us. Although, we do not generally rely on consent as a legal basis for processing your personal data, we will obtain your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Where we rely on legitimate interests as a lawful basis to process your personal data, we will carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests.
We have set out below, in a table format, a description of the ways we plan to use your personal data, type of 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.
|Type of data
|Lawful basis for processing including basis of legitimate interest
To register you as a new customer, administer your account, provide services to you
To process and deliver your order including:
To manage our relationship with you which will include:
To comply with court orders and exercises and/or defend our legal rights
To administer and protect our business, our website and security; to manage access to our IT and communication systems, online platforms, websites and other systems (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data); to prevent and detect security threats, fraud or other criminal or malicious activities
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links (“unsubscribe”) on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, product or service experience or other transactions.
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.
We may share your personal data in the following circumstances:
We require all third parties to respect the security of your personal data and to respect your right to privacy and comply with the data protection principles and this policy. We may also instruct third party service providers to process personal data on our behalf and in accordance with our instructions. We will retain control over and will remain fully responsible for your personal data and will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers;
Otherwise, we will only disclose your personal data when you direct us or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.
Any data sent out of the relevant jurisdiction, shall be sent to a jurisdiction with valid and enforceable data protection laws or regulations.
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.
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 unauthorised 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.
We will only retain your personal information for as long as is necessary for the purpose for which it was collected, including for the purposes of complying with any legal, regulatory, accounting or reporting requirements. In some circumstances you can ask us to delete your data: see your legal rights below for further information.
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.
You have certain rights that you can exercise under certain circumstances in relation to the personal information that we hold. You have the right to:
We hope that Bequant’s data privacy manager can resolve any query or concern you raise about our use of your personal information. If you feel we have not handled your query or concern to your satisfaction you can contact the following authorities:
Bequant Servicing Ltd as a processor: the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues at ico.org.uk/concerns or telephone 0303 123 1113.
You will not, in general, have to pay a fee to exercise any of your individual rights set out in this policy. However, should you wish to exercise any of your individual rights, we may not be able to provide services to you and may charge a fee for access to your personal data if the relevant data protection legislation allows us to do so, in which case we will provide reasons for our decision as required by the law.
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.
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.
If any of the personal data you have provided to us changes, for example if you changed your email address, or if you become aware that we have any inaccurate personal data about you, please let us know by sending an email to [email protected]. We will not be responsible for any losses arising from incomplete, inaccurate, inauthentic or deficient personal data that you have provided to us.
If you have any questions or concerns, please contact our data privacy manager by emailing [email protected].
“Aggregated Data” refers to numerical or non-numerical information that is (1) collected from multiple sources and/or on multiple measures, variables, or individuals and (2) compiled into data summaries or summary reports, typically for the purposes of public reporting or statistical analysis.
“Internal Third Parties” means other companies in the Bequant Group acting as joint controllers or processors and who are based in the Seychelles or in the UK.
“External Third Parties” means:
“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.
“Process” or “Processed” or “Processing” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, or any other information that may be deemed to be sensitive under applicable law.
“Technical Data” includes the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, your ISP and/or mobile carrier, browser plug-in types and versions, operating system and platform, your location; information about your visits, including the full Uniform Resource Locators (URLs) to, through and from which you access our service (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information, methods used to browse away from the page.
This policy was last updated in August 2022. We reserve the right to update and change this policy from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. In case of any such changes, we will post the updated policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on the website.