Your Privacy Is Important to Thrust
In the course of serving you as a client or as a portfolio company, Thrust may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.
This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “Thrust” refers to Thrust Capital Ltd. and its affiliates.
The Sources of Information
The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Thrust during the course of your relationship with us. We may also collect information about your transactions and experiences with Thrust relating to the products and services Thrust provides. In addition, depending on the products or services you require, Thrust may obtain additional information about you, such as your credit history, from consumer reporting agencies.
Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g. recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.
The Information We Have about You
If you deal with Thrust as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle, the typical information we collect about you would include:
Your name, address and other contact details;
Your age, occupation and marital status;
Extensive financial information, including source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources;
A head and shoulders photograph from, as applicable, your passport, national identity card or driver’s license, as required by laws and regulations addressing due diligence and related matters; and
A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.
If you are an employee/officer/director/principal, etc. of one of our corporate or institutional clients, the typical information we collect about you personally would include:
Your name and contact details;
Your role/position/title and area of responsibility; and
Certain identifying information (e.g. passport photo, etc.) as required by laws and regulations addressing money laundering and related matters.
Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information 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 information.
Our Use of Your Personal Information
We may use your personal information to:
Administer, operate, facilitate and manage your relationship and/or account with Thrust. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account;
Provide you with information, recommendations, or advice concerning products and services offered by Thrust; and
Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.
If your relationship with Thrust ends, Thrust will continue to treat your personal information, to the extent we retain it, as described in this policy.
Disclosures of Your Personal Information to Third Parties
Thrust does not disclose your personal information to third parties, except as described in this policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with Thrust, including those that provide professional, legal or accounting advice to Thrust. Non-affiliated companies that assist Thrust in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that Thrust dictates.
We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges and clearinghouses.
You should know that Thrust will not sell your personal information.
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You are entitled to access any personal data about you held by Thrust by sending a written request to firstname.lastname@example.org. We will process your request within the time provided by applicable law. You are also entitled to have Thrust modify or delete any information that you believe is incorrect or out of date.