Unite Ltd has established the following solicitation policy pursuant to the Law on Sales of Financial Products.
1. We will comply with laws, ordinances and rules as well as this solicitation policy to ensure that our practices are appropriate and compliant.
2. We will only introduce products suitably matched to the financial knowledge, transaction experience, asset status and investment purposes of our clients*
3. We will properly and accurately provide information to professional parties with whom we have an existing relationship and a legally binding agreement.
4. We will not make announcements contrary to fact, will not push our opinions on our clients, will not present information that could mislead clients, and will not misrepresent ourselves to our clients.
5. We will not pursue clients at times or in places that inconvenience our clients.
6. We will respond with all sincerity to clients’ inquiries and complaints regarding our solicitation practices and implement necessary actions to enhance our activities.
7. We will strive to improve our knowledge and skills to attract the business of clients in an appropriate and sound manner, and we will set down in-house rules to be strictly followed.
*Clients are either HNW, UHNW, Professional Investors, HNW Corporates, Family Offices and Institutions or their appointed representatives.
At no time does Unite Ltd, sell, solicit or engage with any retail investors or brokers and does not advise clients or handle any funds.
This Policy is provided by Unite Limited (“Unite”), which controls and operates the Unite Websites This Policy details the treatment of your Personal Information by Unite whilst visiting the Unite Website. By accessing the Unite Website, you consent to the processing of your Personal Information as described in this Policy.
This Policy applies to the following company…
REGULATION AND PRIVACY
The protection of your privacy and the confidentiality of your personal information are of paramount concern to Unite. Information is subject to the Data Protection Act 2004 and the Communications (Personal Data and Privacy) Regulations 2006.
Additionally, any processing of personal data within members of Unite is done in accordance with the principles and various Articles established in the EU General Data Protection Regulation 2016 (GDPR) and in compliance with the rules on cross border transfers of personal data covered by the GDPR.
COLLECTION OF INFORMATION
You can visit the Unite Website without providing any personal information about yourself. Unite does not collect information about individual users (“Personal Information”), except where this is specifically stated and provided with the user’s knowledge. The information that Unite collects via the Unite Website consists of voluntarily submitted Personal Information that is required to provide information or goods and services requested through the website. Unite may also collect public and non-public Personal Information about you from any of the following sources: You or your representative on written applications or forms (for example, name, address, identification number, birth date, assets and income); Transactional activity in your account (for example, trading history and balances); Other interactions with Unite (for example, discussions with our staff); Information from other third-party data services (for example, to verify your identity and to better understand your product and service needs); You or your representative regarding your preferences (for example, your choice of electronic communication) or other sources with your consent or with the consent of your representative. Personal Data does not include data where the identity has been removed (anonymous data).
USE OF INFORMATION
The information you provide through the Unite Website may be used: lawfully, fairly and in a transparent way; collected only for specified and legitimate purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes; adequate, relevant and limited to what is necessary in relation to the purposes we have told you about; accurate and kept up to date; not kept in a form which permits your identification for longer than necessary and kept only as long as necessary for the purposes we have told you about; kept secure.
YOUR DUTY TO INFORM UNITE OF CHANGES
It is important that the personal information that Unite holds about you is accurate and current. Please keep us informed if your information changes during your working relationship with Unite.
SHARING OF YOUR INFORMATION
Unite may share Information about you with various entities within Unite, including internal service providers which perform, for example, printing, mailing, and data processing services. For clients in the EEA, Unite ensures that they have adequate and appropriate safeguards in order to protect that Personal Information. Unite may share overall visitor trends and other generic information collected on this website with third-parties but we do not pass on any personal details or personally identifiable information without your specific consent. Except as provided herein, Unite will not share your Personal Information with any unaffiliated third-party without your prior consent. Unite does not sell, trade or rent Personal Information to any unaffiliated third-party without your prior consent. We may share Personal Information with the following entities: Government agencies, other regulatory bodies and law enforcement officials (for example, for reporting suspicious transactions or for tax purposes if relevant, the respective financial services regulator, the Financial Services Compensation Scheme); or Other organizations, with your consent or as directed by your representative, or as permitted or required by law (for example, for fraud prevention). Our service providers are obligated to keep the Personal Information we share with them confidential and use it only to provide services specified by Unite - although it should be noted that, ultimately, Unite does not have control over these service providers.
MARKETING AND OPTING OUT
Unite does not currently engage in direct marketing, however if this policy changes at a future date you will be given the opportunity to withhold or give your permission to receive such materials through an opt out or in message. You can subsequently ask Unite to stop sending you messages at any time by unsubscribing or contacting us at any time.
CHANGE OF PURPOSE
Unite will only use your personal data for the purposes for which we collected and as set out in this Privacy Notice.
We will retain your Personal Information only for as long as it is necessary in connection with the performance of our contractual obligations to you or if it becomes necessary or required to meet legal and regulatory requirements, resolve disputes, prevent fraud and abuse or enforce our terms and conditions. We will keep your Personal Information while your relationship with us is active or until such time as you ask us to stop communications with you, unless we need to keep the information for longer.
Unite recognizes the importance of confidentiality and uses secure servers and various other technological means to ensure the security of your Personal Information and of your online session, and to protect Unites system from unauthorized access. Please note however that no data transmission over the internet can be guaranteed to be totally secure and we cannot guarantee or warrant the security of any information which you send to us. Unite restricts access to Personal Information to those who require it to develop, support, offer and deliver products and services to you. Unite has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Details of your visits to our website and information are collected through cookies and other tracking technologies, including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access. The Unite Website may use "cookies." A cookie is a small file of letters and numbers that we store on your browser. Cookies contain information that is transferred to your computer's hard drive. This helps us track basic visitor information in order that we can better tailor the site to our visitors' needs. Most web browsers automatically accept cookies but you can disable this function by changing your browser settings if you so wish. Certain necessary cookies (such as those required for the sole purpose of carrying out the transmission of a communication) do not require your consent. Other cookies, that are helpful or convenient for your navigation of our website, may require your consent. In such cases you consent will be requested. Our cookies do not identify you by name as an individual or by account number. Please note, however, that if you reject cookies, your access to certain information may be restricted or you may have to re-enter information.
All users enjoy certain rights relating to their Personal Information that Unite commits to upholding. The below list contains the principal rights generic across all jurisdictions but you may be entitled to other rights in your specific location. The right to be informed: We need to be clear with you about what data is being collected, how it’s being used, how long it will be kept and whether it will be shared with any third parties. This information must be communicated concisely and in plain language. The right to access: You may submit subject access requests
(https://www.itgovernance.eu/blog/en/the-gdpr-how-to-respond-to-subject-access-requests/), which oblige us to provide a copy of any personal data concerning you. We have one month to produce this information, although there are exceptions for requests that are manifestly unfounded, repetitive or excessive. The right to rectification: If you discover that the information we hold on you is inaccurate or incomplete, you may request that it be updated. As with the right to access, we have one month to do this, and the same exceptions apply. The right to erasure: (also known as ‘the right to be forgotten’) You may request that we erase your data in certain circumstances, such as when the data is no longer necessary, the data was unlawfully processed or it no longer meets the lawful ground for which it was collected. This includes instances where you withdraw consent. This is not an absolute right, we may be justified in keeping certain personal data in order to perform a contract with you, comply with legal obligations or in relation to the exercise or defence of legal claims. The right to restrict processing: You may request that we limit the way we use your personal data. It’s an alternative to requesting the erasure of data, and might be used when you contest the accuracy of the personal data or when you no longer need the information but we require it to establish, exercise or defend a legal claim. The right to data portability: You are permitted to obtain and reuse your personal data for your purposes across different services. This right only applies to personal data that you have provided to us by way of a contract or consent. The right to object: You may object to the processing of personal data that is collected on the grounds of legitimate interests or the performance of a task in the interest/exercise of official authority. We must stop processing information unless we can demonstrate compelling legitimate grounds for the processing that overrides your interests, rights and freedoms or if the processing is for the establishment or exercise of defence of legal claims. Rights related to automated decision-making including profiling: The GDPR includes provisions for decisions made with no human involvement, such as profiling, which uses personal data to make calculated assumptions about you. There are strict rules about this kind of processing, and you are permitted to challenge and request a review of the processing if you believe the rules aren’t being followed. The right to stop direct communication messages: You may disable direct communication messages by requesting to unsubscribe by return. Please note that it may take a few days for your preferences to be updated in our system, so you may receive messages from us while we process your request. The right to complain to your data protection regulator: you are able to submit a complaint to the regulator for data protection of each the respective companies about any matter concerning your personal information, using the details below. However, we take our obligations seriously, so if you have any questions or concerns, we would encourage you to raise them with us first, so that we can try to resolve them.
You will not have to pay a fee to access the Personal Information held by Unite. However, we may refuse to comply with your request in circumstances where your request is clearly unfounded, repetitive or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests as soon as reasonably practicable and, in any event, within 30 days of receipt of the request. Where we cannot comply within 30 days we will inform you immediately.
If you have any questions concerning this Policy, wish to review your Personal Information that Unite may have stored or exercise any of your rights listed above, please contact us at
Tel: (+44) (0) 203 137 4400
Keeping your information accurate and up to date is very important to Unite. In some jurisdictions, you may have the right to write to us in order to request that you have reasonable access to your non-public Personal Information. If you believe the information that Unite may have collected about you is inaccurate, you may request that we amend, correct or delete it. Unite will notify you of our decision, give you our reasons and the opportunity to file a concise statement of dispute with us if you do not agree. Your statement will be made a part of our file and sent to persons or organizations that received your information in the past and in the future as may be required by applicable law.
Please note that this Policy may be reviewed, and may change, from time to time. The revised Policy will be posted to this page so that you are aware of the information we collect, how it is used and under what circumstances we disclose it.
© Unite 2011