Website Privacy Notice
Last updated: May 2018
At ICBC Standard Bank plc your right to privacy and security is very important to us. This Privacy Notice applies to personal information that we collect through our website at https://www.icbcstandardbank.com/CorporateSite (“Website”). We treat personal information obtained through the use of the Website as private and confidential and are committed to keeping your personal information and other data confidential and secure and providing you with secure access to our online services.
All references to "ICBC Standard Bank" or "we", "us" and "our" are references to ICBC Standard Bank Plc, and/or any entity controlled, directly or indirectly, by it (each an "ICBC Standard Bank Group" member).
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.
What does ICBC Standard Bank do?
ICBC Standard Bank is a financial markets and commodities bank that specialises in global commodities, fixed income, currencies and equities. We are headquartered in London, with operations in New York, Singapore, Tokyo, Shanghai, Hong Kong and Dubai.
For more information about us, please see the “About Us” section of our Website.
When does this Website Privacy Notice apply?
This Website Privacy Notice (“Privacy Notice”) explains the approach taken by us toward the personal information that we collect about you when you visit this Website, electronically respond to our online advertisements or when you send us communications via any computer, mobile or other similar electronic devices. It does not apply to information we collect in other ways.
This Privacy Notice is limited to information and data collected on this Website, our online advertisements and electronic communications.
Whenever we commission other organisations to provide support services to us, we will bind them to our privacy policies as far as they may be required to have access to our customers' personal information to perform such services.
Our Privacy Notice does not apply when you leave our Website, including third-party websites where our online advertisements are displayed or links to third-party websites which we do not operate or control.
Our Website may contain links to or from other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the security or privacy practices employed by other sites. We recommend that you always read the privacy and security statements and terms and conditions of these third-party websites and decide whether they satisfactorily protect your rights.
What information do we collect from you?
The personal information that we may collect about you broadly falls into the following categories:
Information that you provide voluntarily
Certain parts of our Website may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details in order to register an account with us, and/or submit enquiries to us. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
Information that we collect automatically
When you visit our Website, we may collect certain information automatically from your device. In some countries, including in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the page accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.
- Information that you provide voluntarily
Cookies and similar tracking technology
To whom may we disclose your personal information?
We may disclose personal information to the following categories of recipients:
- to our group companies, third party service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or to help enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect Your Information;
- to any competent law enforcement body, regulatory or government agency, court or other third party where we believe disclosure is necessary: a) as a matter of applicable law or regulation; b) to exercise, establish or defend our legal rights; or c) to protect your vital interests or those of any other person;
- to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer that it must only use Your Information for the purposes disclosed in this Privacy Notice; or
- to any other person with your consent to the disclosure.
Legal basis for processing personal information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only a) where we need the personal information to perform a contract with you; b) where the processing is in our legitimate interests and not overridden by your rights; or c) where we have your consent to do so.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Website, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect your personal information, please our Data Protection Officer at: email@example.com.
We will retain your personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or toc comply with applicable legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Our security practices
We are committed to providing secure online services and use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. As such, all interactions with our transactional sites are protected through encryption that complies with international standards. Encryption is used to protect the transmission of your personal information when completing online application forms. Our Internet servers are protected by firewalls and intrusion detection systems. Access to information on these servers is restricted to authorized personnel only. We have also employed the services of independent security experts to test and advise us on the security of our systems.
Your Information that we collect via the Website is stored in a secure environment.
International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are a resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, our group companies and third party service providers and partners operate around the world, including in the United States, China, Hong Kong, Japan, Singapore and the United Arab Emirates. This means that when we collect your personal information, we may process it in any of these countries.
However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the European Economic Area in accordance with European Union data protection law.
Your data protection rights
You have the data protection rights detailed below.
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting our Data Protection Officer at firstname.lastname@example.org.
- In addition, you can object to our processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting our Data Protection Officer at email@example.com.
- Similarly, if we have collect and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact our Data Protection Officer at firstname.lastname@example.org.
We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Right to amend this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business requirements. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
All amendments will be posted on the Website. Unless otherwise stated, the current versions shall supersede and replace all previous versions of the Privacy Notice.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.
If you have questions about our use of your personal information, please contact our data protection officer at email@example.com.
The data controller of your personal information is ICBC Standard Bank plc.