Privacy Policy

Our Commitment

AUDACIA CAPITAL (IRELAND) PLC (AUDACIA) is committed to the principles of respecting the safety, accuracy, and integrity of all personal data that it holds and only using it for the purposes for which it has lawfully been collected.

AUDACIA is also committed to the principle of transparency – ensuring that to the extent permitted by law all individuals in respect of whom AUDACIA holds personal data are aware of how that data is being used and of their rights in relation to that data.

This Privacy Notice will explain how we collect, hold, use and disclose personal information about you in connection with bond issuance and administration or other company services provided by AUDACIA. From time to time we may need to make changes to this Privacy Notice. This could be because of government regulation or new technologies or other developments in data protection laws.

Data Protection Principles

All processing of personal information is conducted in accordance with the data protection principles set out in the EU's General Data Protection Regulation (GDPR) and/or other relevant data protection legislation depending on your location. Our policies and procedures are designed to ensure compliance with the following principles:

Personal information you provide is processed fairly, lawfully and in a transparent manner; collected for a specific purpose and not processed in a way which is incompatible with that purpose; adequate, relevant and limited to what is necessary; kept accurate and up to date; retained no longer than is necessary; kept secure; and processed in accordance with your rights.

What Personal Data Do We Process?

The types of personal information that we collect will vary depending on a number of factors including the nature of your relationship with us and the services we are requested to perform. This may include: name and contact information (email, postal address and telephone number); KYC information including date of birth, country of residence, nationality, and government identification documents such as passport copies or driver's licences; financial information such as source of funds, source of wealth, and bank account details; public domain information including matters revealed by client screening processes; information about the services we provide to you; CCTV or similar security information should you visit our premises; and information obtained through our use of cookies.

In certain limited circumstances we may request or receive special category data about you, including but not limited to details about your health if the context requires it and with your express consent.

How Do We Collect Your Personal Information?

We mainly collect information from you directly via telephone, electronic communications and to a lesser extent written correspondence. However, this may also be collected indirectly from third parties as a result of the nature of the services we provide. Such information is requested during client introductions and on-boarding including due diligence; client specific activities and transactions; and for legal matters, such as to execute and perform contractual agreements.

Depending on the nature of our relationship with you, we may also collect your personal information from publicly available sources, companies which validate identity for financial crime purposes, third party registers maintained by regulators, and other professional advisors.

How and Why Do We Use Your Personal Information?

This is dependent on our relationship with you and includes: if you are a prospective or existing client, we use your personal information to onboard you as a client and to provide services; to prevent fraud and comply with our regulatory obligations; and if you are viewing our website, we use your personal information contained in cookies.

Marketing: We will never use your information to promote to you the services of other parties unless with your specific written consent.

Legal Basis for Processing Personal Data

We may process your personal information for a number of different purposes. Reasons for collecting personal information include: performance of a contract where processing is necessary for the performance of a contract to which you are party; marketing materials and events to promote the AUDACIA CAPITAL (IRELAND) PLC Group; legitimate business interest to manage, maintain and develop our relationship with clients and day to day operations; and to ensure all legal obligations are met including requests from regulators.

Who Do We Share Your Personal Information With?

We will only disclose your personal information in accordance with applicable laws and regulations. This may include: any person with legal or regulatory power over us that may require disclosure on legal grounds; service providers engaged by us to help us run our business, such as cloud or archive storage providers, software or IT resource providers, and tax advisers; any member of the AUDACIA CAPITAL (IRELAND) PLC Group including affiliates and subsidiaries; and providers of background checks and risk screening services.

How Long Do We Keep Records For?

We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Policy and in order to comply with our legal and regulatory obligations.

International Data Transfer

In the course of providing services to clients we may transfer personal data to third parties located in other countries, including countries outside the European Economic Area (EEA), or countries which do not have data protection legislation deemed equivalent to the GDPR.

We will only transfer your personal information to another country or an international organisation outside the EEA where we have taken the required steps to ensure that your personal information is protected.

Your Rights

Under GDPR and equivalent data protection legislation in other jurisdictions, you have the following rights in relation to our use of your personal information:

Right to access your personal information: You are entitled to a copy of the personal information we hold about you and certain details of how we use it (subject to certain exemptions).

Right to rectification: We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this is the case, please contact us and request an update or amendment.

Right to restriction of processing: In certain circumstances, you are entitled to ask us to stop using your personal information.

Right to data portability: In certain circumstances, you have the right to ask that we transfer any personal information that you have provided to us to another third party of your choice.

Right not to be subject to automated decision making: If decisions are arrived at using automated systems, you have the right to request that this decision is checked by a human.

The right to withdraw consent: For certain limited uses of your personal information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information.

You have a right to complain to the relevant Data Protection Regulator at any time if you object to the way in which we use your personal information. We would be grateful if you would contact the Company Data Protection Officer in the first instance by emailing [email protected]. Any such complaints will be acknowledged within 30 days and will be investigated and responded to without undue delay.