The Fidelway Group respects the privacy of the people we deal with, and we uphold high standards of privacy practice and security. This policy explains how we handle personal information and how we interact with you online.

Whenever we handle personal information, we take steps to ensure that appropriate standards of privacy practice and security are applied.

The Fidelway Group Privacy Policy sets out why we need to collect personal information, how we collect it, what we do with it, how it is stored and who we might share it with. The Policy also describes how you can access or correct information we hold about you, how you can ask further questions or make a complaint, and information about our websites and online activities.

For most products and services, it is necessary for us to collect 'personal information' such as your name, identity details, photos, contact details and transaction information. We may also need to collect other personal details (such as gender, marital status and financial information) and other information from which you can be identified.

Generally, we do not collect sensitive information about you unless required or permitted by law or where you consent for us to do so. Sensitive information will only be collected if it is relevant to your product or the service or function you are engaging us to provide. If applicable, this will be communicated to you. For example, some forms of biometric data are collected, stored and used to support access and verification procedures as well as fraud prevention. To support the management of COVID-19 related risks and compliance with our local legal obligations, we may collect, store, use or otherwise process some forms of health information.

We will not collect sensitive information about you where this is expressly prohibited by local law.

Sensitive information includes information relating to:

• race
• political or religious beliefs
• sexual orientation and sexual life
• criminal convictions
• membership of professional or trade associations or unions
• biometric and health information.

information about your affiliation with certain organisations, such as professional associations

We collect personal information about you which is reasonably necessary to:

• provide you with quality products, services or transaction opportunities.
• consider applications and approaches you make to us
• conduct marketing and social functions
• maintain your contact details
• fulfil our legal obligations, such as those relating to taxation, anti-money laundering and counter-terrorism financing and comprehensive consumer credit reporting under the National Consumer Credit Protection Act or to prevent fraud or as otherwise authorised by you.

Without such information, we may not be able to process your application or provide you with an appropriate level of service. In such circumstances, we will process your application and provide you with the most appropriate level of service that we can.

We collect personal information about you directly from you — this can be in person, in documents you give us, from telephone calls, emails, competitions you enter, your access to our website or from transactions you make. We take reasonable steps to be transparent about how and why we collect personal data.

We keep personal information in physical and electronic records, at our premises and the premises of our service providers. Where this occurs, we take steps to protect the security and integrity of personal information.

We also keep records of our interactions with you (including by telephone, email and online) and of your transaction history.

We use personal information about you for the purpose for which it was provided to us, including to:

• process applications.
• administer and manage our products and services (including monitoring, auditing, and evaluating those products and services).
• model and test data (in a controlled environment).
• develop scores, risk assessments and related analytical tools.
• communicate with you and deal with or investigate any complaints or enquiries.

We may also:

• anonymise your data for our own purposes including market research and new product development.
• use personal information about you for the prevention and mitigation of fraud and other financial crimes.
• use or permit our affiliates to use your personal information for related purposes to the extent that it is lawful to do so without your express permission. For example, we may from time to time use your personal information to inform you or your employer of investment opportunities or to provide information about products and services which we expect may be of interest to you. However, if you don't want to receive such communications you can tell us by using any of the methods listed below.

We take reasonable steps to ensure that all information we hold is as accurate as possible. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.

We use security procedures and technology to protect the information we hold. Access to and use of personal information within Fidelway Group seeks to prevent misuse or unlawful disclosure of the information — this includes internal policies, auditing, training and monitoring of staff.

If other organisations provide support services, we require them to take appropriate technical and organisational measures to secure the privacy of the information provided to them.

You can contact us to request access to or correction of your personal information. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why (if we can). Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.