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Privacy & Legal

In the course of serving you as an individual shareholder, NICO may obtain personal information about you. It is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This Policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy. As used throughout this Policy, the term “NICO” refers to the National Investments Company Limited.

The Sources of Information

The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to NICO.

Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g., recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis but it may be used for compliance or security purposes.

The Information We Have About You

If you deal with NICO in your individual capacity or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you would include:
  • Your name, address and other contact details;
  • Your age, occupation and marital status;
  • Extensive financial information, including source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources ;
  • A head and shoulders photograph from, as applicable, your passport, national identity card or driver's license, as required by laws and regulations addressing due diligence and related matters; and
  • A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.

If you are an employee/officer/director/principal, etc. of one of our corporate or institutional clients, the typical information we collect about you personally would include:

  • Your name and contact details;
  • Your role/position/title and area of responsibility; and
  • Certain identifying information (e.g., passport photo, etc.) as required by laws and regulations addressing money laundering and related matters.

Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

Our Use of Your Personal Information

We may use your personal information to:

Administer, operate, facilitate and manage your relationship and/or account with NICO. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;

Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account;

Provide you with information concerning products and services offered by NICO; and

Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

If your relationship with NICO ends, NICO will continue to treat your personal information, to the extent we retain it, as described in this Policy.

Disclosures of Your Personal Information Within NICO

In order to provide efficient and reliable services, and to improve product and service options available to you, more than one entity within NICO may be given, or given access to, your personal information. When so sharing your personal information we adhere to applicable legal and industry standards regarding the protection of personal information.

Disclosures of Your Personal Information to Third Parties

NICO does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with NICO, including those that provide professional, legal, or accounting advice to NICO. Non-affiliated companies that assist NICO in providing services to you are required to maintain the confidentiality of such information to the extent they receive it, and to use your personal information only in the course of providing such services and only for the purposes that NICO dictates.

We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners, or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations.

NICO will not sell your personal information.

Privacy and The Internet

The following additional information will be of interest to you if you access NICO products or services through NICO's Website:

“Cookies” are small text files consisting of information stored by your Web browser. This information is used for administrative purposes and to improve your experience with our Web sites. For example, this information helps authenticate you (i.e., verify that you are who you say you are), an essential component of site security. Cookies also make it easier for you to navigate a NICO Web site by, among other things, “remembering” your identity so that you do not have to input your password multiple times as you move between pages or services. You can set your Web browser to inform you when cookies are set, or to prevent cookies from being set. However, if you decline to use cookies, you may experience reduced functionality, and declining to use authentication related cookies will prevent you from using the Web site altogether.

Other Privacy Policies or Statements; Changes to Policy

This Policy provides a general statement of the ways in which NICO protects your personal information. You may, however, in connection with specific products or services offered by NICO, be provided with privacy policies or statements that supplement this Policy. This Policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information.

You are entitled to access any personal data about you held by NICO by sending a written request to the applicable individual identified below. You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorized disclosure of your personal information. We will process your request within the time provided by applicable law. You are also entitled to have NICO modify or delete any information that you believe is incorrect or out of date.

NICO may occasionally contact you by post, telephone, electronic mail, facsimile, etc., with information that we believe may be of interest to you. If you do not wish to be contacted in this way, if you wish to exercise your rights of correction and access, or if you require further information regarding our privacy policies and practices please contact us.