Website Privacy Statement
Zodia Custody respects your privacy and we are committed to keeping your personal data and other data confidential and secure.
Important information and who we are
This Website Privacy Statement tells you the types of information we collect about you when you visit our website (“Website”), use our products and services, interact with us offline, apply for a job position, or which we otherwise obtain directly from you or from another party. It also outlines why and how we use that information and how we may share it.
This Website Privacy Statement is issued on behalf of Zodia Custody Limited and the members of the Zodia Custody Group, including Zodia Custody Limited, Zodia Custody (Ireland) Limited, Zodia Custody (Singapore) PTE. LTD, Zodia Custody (Hong Kong) Limited, and Zodia Custody Australia Pty LTD. (“Zodia Custody Group” “we”, “us”, or “our”).
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every Website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. Personal data commonly include an individual’s name, identification number, phone number, email address and residential address. Personal data also include more sensitive categories including physical, health, genetic, cultural or social information.
In addition to the personal data that we collect from you directly and which we may collect automatically from our Website, we may also receive personal data about you from certain third parties and public sources including:
- other companies in the Zodia Custody Group and other affiliates;
- your employer, our corporate customers or suppliers with which you have a relationship or are an authorised
- representative/user;
- recruitment agencies;
- social media sites (such as LinkedIn); and
- other publicly available databased such as Companies House.
We provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your personal data to form a view on what products, services or other offerings we think you may want or need, or what may be of interest to you. You may receive marketing communication from us if you have requested information from us, have consented to marketing or have purchased goods or services from us and you have not opted out of receiving that marketing or where we are otherwise legally permitted to send you marketing.
The data we collect and the purpose for processing this data vary. We will not take any automated decisions toward you based on your personal data. Please refer to the relevant section below based on your relationship with us.
Purposes for processing personal data
Visitors to Zodia.io
Information you provide directly
We collect personal data that you provide voluntarily through our Website, for example, through completing online forms or subscribing to receive marketing communications from us. The information we collect may include the following:
- Identification data – for example your name or other identifiers such as a username;
- Contact data – for example your email address, phone number or residential address;
- Professional data – for example your professional background, current company, position, or educational details; and
- Other personal data that is voluntarily provided by you.
We do not voluntarily collect sensitive personal data and you will not be required to provide or disclose such information. We may sometimes collect this information if provided by you, voluntarily, for example via an email or through a free-text response.
Information we collect automatically
We also automatically collect certain personal data as you interact with our Website, we will automatically collect certain technical data about your equipment, browsing actions and patterns. This may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
Purpose for which we process your personal data
We collect your personal data to effectively manage our relationship with you. We process your personal data for the following purposes:
- To confirm and authenticate your identity;
- To deliver relevant website content and advertisement to you and measure and understand the effectiveness of the advertising we serve to you;
- To analyse data of website visitors and traffic information;
- To make suggestions and recommendation to you about goods or services that may be of interest to you;
- To handle queries and complaints; and
- For planning, conducting and monitoring Zodia Custody’s business including research and statistical analysis with the aim of improving our Website, products and/or services.
Legal grounds for processing your personal data
The lawful bases we rely on for processing your personal data are:
- Our legitimate interest in operating our business, improving our website, products and services, promoting our brand and staying in touch; and
- Where applicable, your explicit consent.
Recruitment
We collect information from and about candidates for recruitment purposes. This data is primarily collected from the candidate directly and includes:
- Identification data – for example your name or other identifiers such as a username;
- Contact data – for example your email address, phone number or residential address;
- Professional data – for example your professional background, current company, position, educational details and references;
- Financial data – for example, information about your salary, bonus, employee benefits, credit reports, or payslips; and
- Resume or CV.
Additional data will also be collected and processed as a candidate progresses through the recruitment process, including interview notes, assessment results and feedback.
Sensitive personal data may also be collected under our employment law obligations and with the candidate’s explicit consent, for example, we will conduct criminal background checks via a third party service provider prior to offering a job position to any candidate.
Purpose for which we process your personal data
We collect your personal data to effectively manage our relationship with you. We process your personal data for the following purposes:
- To assess your skills and experience against specific recruitment criteria;
- To process and support your application;
- To conduct pre-employment and background checks;
- To communicate with you in respect of the recruitment process; and
- To improve our recruitment process.
Legal grounds for processing your personal data
The lawful bases we rely on for processing your personal data are:
- Your explicit consent;
- Our legitimate interest in identifying and assessing talented candidates, carrying out pre-employment checks and managing our careers website.
- Legal obligations to conduct pre-employment screening, eligibility and criminal record checks
Clients
We collect and process personal data of individuals related to our Clients. These individuals typically include directors, beneficial owners and other authorised positions (e.g., Makers and Authorisers). Personal data is primarily collected from the Client directly and can include:
- Identification data – for example name, date of birth, nationality, official/government identifies such as national identification number and passport numbers and photographs;
- Contact data – for example email address, phone number, residential address and business address;
- Professional data – for example professional background, job position and educational details;
- Financial data – for example, information about source of funds, salary, bonus, credit reports, or payslips;
- Geo-location data – for example, internet protocol (IP) address or cookie identifiers (please see our Cookie Policy for further details); and
- Behavioural data – analytics information on behaviour characteristics relating to produce usage.
We may also collect sensitive personal data where it is necessary and required by law, for example including biometric data, criminal convictions, legal proceedings or allegations data. Where not collected from the Client directly, we may also obtain personal data from other sources as necessary, including:
- Other individuals from the Client;
- Other entities within the Zodia Custody Group;
- Publicly available resources; and
- Website cookies.
Purpose for which we process your personal data
We collect your personal data to effectively manage our relationship with you. We process your personal data for the following purposes:
- To enable us to meet our due diligence obligations;
- To enable the provision of our products and services;
- To manage client relationships and administering accounts;
- For accounting and tax purposes;
- To improve our products and services; and
- To detect, investigate and prevent financial crime.
Legal grounds for processing your personal data
The lawful bases we rely on for processing your personal data are:
- Your explicit consent;
- Performance of a contract;
- Our legitimate interest in providing high-quality services, safeguarding Zodia Custody Group against dealing with the proceeds of criminal activity and continuously improving our offering; and
- Legal obligations including compliance with relevant laws, regulations, government sanctions and regulatory reporting requirements.
Suppliers and vendors
We collect and process personal data of individuals related to our suppliers and vendors. These individuals typically include directors, beneficial owners and other authorised positions who are deemed necessary for us to meet our due diligence obligations. Personal data is primarily collected from the supplier or vendor directly and can include:
- Identification data – for example name, date of birth, nationality, official/government identifies such as national identification number and passport numbers and photographs;
- Contact data – for example email address, phone number, residential address and business address;
- Professional data – for example professional background, job position and educational details;
- Financial data – for example, information about source of funds, salary, bonus, credit reports, or payslips;
- Geo-location data – for example, internet protocol (IP) address or cookie identifiers (Please see our Cookie Policy for further details); and
- Behavioural data – analytics information on behaviour characteristics relating to relationships and contracts.
We may also collect sensitive personal data where it is necessary and required by law, for example including biometric data, criminal convictions, legal proceedings or allegations data. Where not collected from the supplier or vendor directly, we may also obtain personal data from other sources as necessary, including:
- Other individuals from the supplier or vendor;
- Other entities within the Zodia Custody Group;
- Publicly available resources; and
- Website cookies.
Purpose for which we process your personal data
We collect your personal data to effectively manage our relationship with you. We process your personal data for the following purposes:
- To enable us to meet our due diligence obligations;
- To enable the provision of our products and services;
- To managing supplier and vendor relationships;
- To improve our products and services; and
- To detect, investigate and prevent financial crime.
Legal grounds for processing your personal data
The lawful bases we rely on for processing your personal data are:
- Performance of a contract;
- Our legitimate interest in identifying suitable suppliers and vendors, identifying potential conflicts of interest, managing payments and fees, safeguarding Zodia Custody Group against dealing with the proceeds of criminal activity and continuously improving our offering; and
- Legal obligations including compliance with relevant laws, regulations, government sanctions and regulatory reporting requirements.
Change of purpose
We will only use your personal data for the purpose for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosing your personal data
When using your personal data, depending on the type of personal data and the purposes of processing, we may disclose it to:
- other companies within Zodia Custody anywhere in the world (including affiliates) in order to provide services to you, for business management or administration or to fulfil our legal or regulatory obligations;
- third party service providers, subcontractors, agents and other organisations who provide services to us in connection with the operation of our business or to you on our behalf such as IT and cloud hosting providers, HR and administrative services, financial and accounting, recruitment agencies, onboarding/KYC /ID verification/Travel Rule providers;
- professional advisers including lawyers, bankers, auditors, accountants and insurers;
in relation to job applicants, educational institutions, previous employers, credit reference agencies and recruiters; - anyone authorised by you, as specified by you or in any contract with you;
- third parties where we choose to sell, transfer or merge parts of our business or our assets;
- our customers in connection with the products and services we provide to them;
- regulators who regulate how we operate, including the Financial Conduct Authority and the Information Commissioner’s Office; and
- any person or organisation to whom disclosure is required or permitted under applicable laws and regulations.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Where third party service providers act as processors on our behalf, we do not allow them to use your personal data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions.
International transfers
We may transfer your personal data outside of the UK / EEA / Singapore / Hong Kong / Australia where we have affiliates or service providers based in countries elsewhere in the world.
Where we transfer your personal data outside of the UK / EEA / Singapore / Hong Kong / Australia, we ensure a similar if not the same degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
We transfer your personal data to countries that have been deemed to provide an adequate level of protection by the UK Secretary of State or the European Commission.
We implement certain standard contractual clauses with the recipients of your personal data to safeguard transfers to countries outside of the UK / EEA / Singapore / Hong Kong / Australia.
Please contact us if you would like further information about the specific mechanism used by use when transferring your personal data out of the UK / EEA / Singapore / Hong Kong / Australia.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have 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.
In order to maintain the security of our systems, protect our staff, record transactions, and, in certain circumstances, to prevent and detect crime or unauthorised activities, we reserve the right to monitor all Internet communications including web and email traffic into and out of our domains.
Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory and tax, accounting or other requirements.
Generally, we will only retain personal data related to a particular client contract for 7 years following the termination or expiry of that relationship. Personal data relating to unsuccessful job applicants is usually retained for 6 months.
In some circumstances you can ask us to delete your personal data (see your rights below).
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your rights
You have other rights regarding the processing of your personal data. Under certain circumstances, you have the right: to make a request to access, correct, erase or restrict the use of, or to object to the way in which we process, the personal data we hold about you, or to make a request to withdraw any consent previously given. If you would like to exercise any of these rights, you can contact our Data Protection Officer (details below).
Contact us
If you have questions, concerns or complaints about our Website Privacy Statement or our processing of your personal data more generally, please contact our Data Protection Officer at:
The Data Protection Officer, Zodia Custody Limited, 5th Floor, Holland House, 1-4 Bury Street, London, EC3A 5AW.
Email: [email protected]
You also have the right to complain to the applicable data protection authority.
The data protection authority in the UK is the Information Commissioner’s Office.
In Ireland it is the Data Protection Commission.
In Singapore it is the Personal Data Protection Commission.
In Hong Kong it is the Office of the Privacy Commissioner for Personal Data, Hong Kong.
In Australia it is the Office of the Australian Information Commissioner.
Changes to our Website Privacy Statement and your duty to inform us of changes
We update our Website Privacy Statement from time to time and you are advised to check this Website regularly to make sure you are familiar with the most recent version.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This Website Privacy Statement was last updated in June 2024.
Cookies
Effective date: 21/06/2024
What are cookies?
This Cookie Policy explains what cookies are and how we use them, the types of cookies we use i.e, the information we collect using cookies and how that information is used, and how to manage the cookie settings.
Cookies are small text files that are used to store small pieces of information. They are stored on your device when the Website is loaded on your browser. These cookies help us make the Website function properly, make it more secure, provide better user experience, and understand how the Website performs and to analyse what works and where it needs improvement.
How do we use cookies?
As most of the online services, our Website uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the Website to function the right way, and they do not collect any of your personally identifiable data.
The third-party cookies used on our Website are mainly for understanding how the Website performs, how you interact with our Website, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with our Website.
Types of cookies we use
Necessary
Necessary cookies are required to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any personally identifiable data.
Cookie: elementor
Duration: never
Description: The website’s WordPress theme uses this cookie. It allows the website owner to implement or change the website’s content in real-time.
Manage cookie preferences
Cookie settings
You can change your cookie preferences any time. This will let you revisit the cookie consent banner and change your preferences or withdraw your consent right away.
In addition to this, different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. Listed below are the links to the support documents on how to manage and delete cookies from the major web browsers.
Chrome: https://support.google.com/accounts/answer/32050
Safari: https://support.apple.com/en-in/guide/safari/sfri11471/mac
Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox?redirectslug=delete-cookies-remove-info-websites-stored&redirectlocale=en-US
Internet Explorer: https://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc
If you are using any other web browser, please visit your browser’s official support documents.