Privacy Policy

This page (together with the terms of use and any other documents referred to in it) sets out the basis on which any personal data Dexion Capital (Guernsey) Limited (“Dexion Capital”) (trading as Dextra) collects from you, or that you provide to Dexion Capital, will be processed by Dexion Capital in connection with the website www.dextra.gg (the “Site”). Please read the following carefully to understand what the position is under Guernsey law relating to collection and use of such personal data and Dexion Capital’s views and practices regarding your personal data and how Dexion Capital treats it.

Data Protection

Guernsey has data protection legislation which affects the collection and use of personal data (“Client Information”) which could apply in relation to certain types of information transferred on the Site.

The law on data protection in Guernsey is the Data Protection (Bailiwick of Guernsey) Law, 2001 (the “Data Protection Law”) and the subordinate legislation thereunder. The Data Protection Law applies to “data controllers” (i.e. a person who (either alone or jointly or in common with other persons) determines the purposes for which, and the manner in which, any “personal data” is, or is to be, processed) which are established in Guernsey or who use equipment in Guernsey for the processing of data (other than for the purposes of transit through Guernsey).

The Data Protection Law defines “personal data” as data which relates to a living individual who can be identified by the data or from the data and other information which is in the possession of, or is likely to come into the possession of, the “data controller”.

If applicable, the Data Protection Law requires the “data controller” (subject to certain exceptions) to:

1. notify the Guernsey Data Protection Commission (the “GDP Commission”) of the details of their processing (i.e. obtaining, recording or holding data or the carrying out of any operation in relation thereto (such as disclosure of information)) and details are published by the GDP Commission in the Register of Data Controllers (which can be accessed on the Data Protection Commissioner’s website). Processing of personal data without an entry on the register is an offence; and
2. comply with the eight data protection principles, which together form a framework for the proper handling of “personal data”. One of the effects of those principles is to limit the ability of a “data controller” to disclose “personal data” to (i) third parties, or (ii) countries or territories outside Guernsey unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data (the eighth principle).

Dexion Capital is listed on the Data Protection Register (www.dpr.gov.gg) as a Data Controller under Registration Number 011232.

Information Dexion Capital May Collect From You

Dexion Capital may collect personal data about you, directly (where you are asked to provide the data), indirectly or implicitly when you communicate with Dexion Capital in person, in writing, by e-mail, by SMS, by fax, when you use the Site or by telephone. Dexion Capital will, however, only use such personal data in accordance with the purposes set forth in this privacy policy and is committed to protecting and respecting your privacy.

Dexion Capital may collect and process the following data about you:

• Information that you provide by filling in forms. This includes information provided via this website, e-mail, SMS, telephone or otherwise.
• If you communicate with Dexion Capital, it may keep a record of that correspondence.

Sensitive Data

Dexion Capital does not seek to collect sensitive personal data (described in the Data Protection Law as data revealing racial or ethnic origin, political opinions, religious beliefs, affiliation with labour organisations or trade unions, or data concerning any offences committed, health or sex life). If Dexion Capital does seek to collect, use or transfer such data, your prior consent will be sought.

Where Dexion Capital stores your personal data

The data that Dexion Capital collects from you may be transferred to, and stored at, a destination inside or outside the European Economic Area (“EEA”). We may in certain circumstances transfer your Client Information to other countries on the basis that anyone to whom we pass it provides an adequate level of protection. However, such other countries may not provide the same level or type of statutory (other legal) protection as your country. It may also be processed by staff operating inside or outside the EEA who work for Dexion Capital, one of its associates or for one of its or its associates’ agents. Such staff may be engaged in, among other things, the provision of support services By submitting your personal data, you agree to this transfer, storing or processing of Client Information. In some circumstances, your Client Information may be accessed by law enforcement agencies and other authorities to prevent and detect crime and comply with legal obligations.

Dexion Capital will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Unfortunately, the transmission of Client Information via the internet is not completely secure. Although Dexion Capital will do its best to protect your personal data, Dexion Capital cannot guarantee the security of your data transmitted to its website; any transmission is at your own risk.

Purposes Of Processing

Dexion Capital uses Client Information held about you in the following ways:

• To provide you with information including newsletters about products or services that you request from Dexion Capital or products or services offered by Dexion Capital and/or its associates which Dexion Capital feels may interest you, where you have consented to be contacted for such purposes.
• To notify you about changes to Dexion Capital’s products or services.

If you are an existing client, Dexion Capital will only contact you by electronic means (e-mail or SMS) with information about products and services offered by Dexion Capital and/or its associates similar to those which were the subject of a previous sale to you.

If you are a new client, and where Dexion Capital permits any of its associates to use your data, Dexion Capital (or they) will contact you by electronic means only if you have consented to this.

By providing your residential address, e-mail address, fax number or telephone number to Dexion Capital you consent to receiving such communications by such medium.

If there is any change to your personal data which you have submitted to Dexion Capital, please contact Dexion Capital at the address listed on the “Contact Us” section of the Site so that it may ensure its records of your personal data are accurate and, where necessary, kept up to date. Personal data shall not be retained on record for longer than is necessary for the purpose it is held.

Disclosure of your information

Dexion Capital may disclose your personal information to third parties if (i) substantially all of Dexion Capital’s assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or (ii) Dexion Capital is under a duty to disclose or share your personal data in order to comply with any legal obligation (whether in your jurisdiction or elsewhere) or in order to enforce or apply the terms of use and other agreements.

Your rights

You have the right to ask Dexion Capital not to process your personal data for the purposes listed in the Purposes Of Processing section above. You can exercise your right to prevent such processing (i) by contacting Dexion Capital at the address listed on the “Contact Us” section of the Site; or (ii) for the purpose of providing newsletters(s) to you either by contacting Dexion Capital at the address listed on the “Contact Us” section of the Site or by clicking on the “unsubscribe” option found at the bottom of electronic communications relating to newsletters (e-mail or SMS) sent to you by Dexion Capital.

Cookies

Dexion Capital does not place and does not permit any third parties to place cookies which store any personal information on its website’s users equipment.

Passwords

Where Dexion Capital has given you a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. Dexion Capital asks you not to share a password with anyone.

Access to information

Under section 7(1) of the Data Protection Law (and/or other relevant legislation), you have the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Law (and/or other relevant legislation). Any access request may be subject to a fee of up to £10 to meet Dexion Capital’s costs in providing you with details of the information it holds about you.

Amendments

Dexion Capital reserves the right to modify sections of this privacy policy at any time provided always that it continues to comply with the Data Protection Law. Any changes Dexion Capital may make to its privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

How To Contact Dexion Capital

If you have any questions about this privacy policy, Dexion Capital’s data processing activities, or you wish to access or update the information held about you, you may contact Dexion Capital by visiting our registered offices or telephoning us with the information listed on the Contact Us section of the Site.