Blackcircle privacy & data

TBCWM International Limited is the data controller responsible for Personal Data collected directly through this Website

name and contact information; identification and verification information; date of birth and nationality

This may involve taking a photo or video of you and comparing it with your identity document. This involves biometric data.

financial, investment and transactional information; source of wealth and source of funds information

IP address; browser type and version; device and operating system information

Website usage and interaction data; and cookie and similar technology information.

responding to enquiries and communicating with you

conducting identity verification, KYC, AML, sanctions screening, source-of-funds and source-of-wealth checks and other due diligence

sending marketing and other communications where permitted by applicable law

complying with legal, regulatory, compliance, governance and record-keeping requirements

We keep KYC and transaction records for at least five years after our relationship ends, or longer where the law requires.

We keep enquiry records for up to two years if no relationship begins.

This may include reliance on adequacy decisions, approved contractual safeguards or other lawful transfer mechanisms.

Where Personal Data is no longer required, it will be deleted, anonymised or otherwise handled in accordance with applicable law and our retention procedures.

request access to Personal Data we hold about you

request correction of inaccurate or incomplete Personal Data

request deletion of Personal Data in certain circumstances

request restriction of processing

object to certain processing

request portability of Personal Data where applicable

We do not sell Personal Data.