This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal data. Any information collected may be used by any group company or affiliate of CFP Energy Group Ltd.
Updated June 2023
This Privacy Notice for each member of the CFP Energy Group, being CFP Energy Group Ltd. and each of its direct and indirect subsidiary (“Company”, “we”, “us”, “our” refers to each of such companies) sets out the categories of personal data we collect from you, how we collect it, what we use it for and with whom we share it in accordance with the General Data Protection Regulation (EU) 2016/689 (“GDPR”).
By “personal data” we mean any information relating to you such as names of individual contacts at corporates; email addresses of individual contacts at corporates; telephone numbers of individual contacts at corporates, addresses, sources of wealth, country of residence, occupation, passport copies, tax identification numbers, proofs of address etc. and transaction information or online identifiers such as your IP address. Personal data does not include data where you can no longer be identified from it such as anonymised aggregate data.
The Company is a data controller. This means that we are responsible for deciding how we hold and use personal data about you. Our address is 245 Hammersmith Road London W6 8PW. Should you have any questions about this Privacy Notice you can contact us at compliance@cfp.energy.
This Privacy Notice applies to personal data about you that we collect, use and otherwise process in connection with your relationship with us.
We may provide supplemental privacy notices on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. Those supplemental notices should be read together with this Privacy Notice.
What personal data do we collect about you and what do we use it for?
The categories of personal data about you which we may collect, store and use are set out in the table below and, in each case, we have indicated what we use your personal data for and our ‘lawful basis’ for processing it. The law specifies certain ‘lawful bases’ under which we are allowed to use your personal data. Most commonly, we will rely on one or more of the following lawful bases for processing your personal data:
Generally, we do not rely on your consent as a lawful basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us on the details given at the beginning of this notice.
| Categories of personal data collected | What the Company uses this Personal Data for | Lawful Basis |
| Name of individual contact at corporate; email address of individual contact at corporate; telephone number of individual contact at corporate, address, source of wealth, country of residence, occupation, passport copies, tax identification numbers etc. | To facilitate the opening of a client account with the Company, the management and administration of a client account, including sharing such information with any interested party, including but not limited to a introducing broker or a financing bank | Processing is necessary for the performance of a Data Subject’s contract with the Company. |
| To carry out anti-money laundering checks and related actions in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an ongoing basis, in accordance with the Company’s or third party service provider’s applicable anti-money laundering procedures. | To carry out anti-money laundering checks and related actions in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an ongoing basis, in accordance with the Company’s or third party service provider’s applicable anti-money laundering procedures. | Processing is necessary for the purposes of the Company complying with legal obligations to which it is subject. |
| To report tax information to the relevant tax authorities. | To report tax information to the relevant tax authorities. | Processing is necessary for the purposes of the Company complying with legal obligations to which it is subject. |
| To monitor and record calls and electronic communications for (i) processing and verification of instructions; (ii) investigation and fraud prevention purposes; and (iii) crime detection, prevention, investigation and prosecution. | To monitor and record calls and electronic communications for (i) processing and verification of instructions; (ii) investigation and fraud prevention purposes; and (iii) crime detection, prevention, investigation and prosecution. | Processing is necessary for the performance of a Data Subject’s contract with the Company and for the purposes of the Company complying with legal and regulatory obligations to which it is subject. |
| In connection with legal proceedings, such as responding to a subpoena. | In connection with legal proceedings, such as responding to a subpoena | Processing is necessary for the purposes of the Company complying with legal obligations to which it is subject. |
| To provide tailored experiences and advertisements about the Company’s products and services as well as those of its affiliates. | To provide tailored experiences and advertisements about the Company’s products and services as well as those of its affiliates. | Processing is necessary for the purposes of the Company’s legitimate interests in providing tailored advertising and experiences and in promoting its products and services. |
| To update and maintain the Company’s records. | To update and maintain the Company’s records. | Processing is necessary for the performance of a Data Subject’s contract with the Company and for the purposes of the Company complying with a legal obligation to which it is subject and for the purposes of the Company’s legitimate interests in maintaining accurate records. |
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, if we are required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
What if you do not provide the personal data we request?
If you do not provide us with certain personal data when requested, we will not be able to perform all or part of the contract we have entered into with you, or we may be prevented from complying with our legal obligations.
Change of purpose
We will only use your personal data for the purposes for which we collected it (as identified above in the ‘What we use this personal data for’ column), unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose for which you provided it to us. If we need to use your personal data for a purpose that is unrelated to the original purpose for which you provided it to us, we will notify you and we will explain the legal basis which allows us to do so.
How do we collect your personal data?
You may provide personal information to us when communicating or transacting with us in writing, electronically, or by phone. For instance, information may come from requests for forms, literature or prices, and your transactions with us and/or our affiliates. On occasion, such information may come from those providing services to us.
We may also automatically collect certain data when you interact with our website such as technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Our cookie policy is available on request from compliance@cfp.energy.
In addition, we may receive personal data about you from third parties and public sources, such as:
With whom will we share your personal data?
We may share your personal data with third parties where this is required by law, where it is necessary to perform our contract with you, or where we have another legitimate interest in doing so.
We will need to share your personal data with:
Interested third parties, including but not limited to an introducing broker or a financing bank.We may share your personal data with other entities in our group to service your accounts and transactions, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and for hosting of data.
We may share your personal data in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with applicable law or judicial process. We may disclose your personal data if we are required by law to do so or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
How long will we retain your personal data?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.
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 requirements. It is anticipated that all data will generally be stored for at least 6 years.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.
Once we no longer require your personal data for the purposes we collected it for, we will securely destroy your personal data in accordance with applicable laws and regulations.
Accuracy of personal data
It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.
Your rights in relation to your personal data
You have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:
If you want to exercise one of these rights please contact us at compliance@cfp.energy. You also have the right to make a complaint at any time to the Information Commissioner’s Office. We would, however, appreciate the opportunity to deal with your concerns prior to any approach to the supervisory authority so please do contact us in the first instance.
While we strive to protect all information we receive from you, we cannot guarantee the security of any information you transmit to us.
Fees
You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Your right to withdraw your consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact compliance@cfp.energy. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) you originally agreed to unless we now have an alternative legal basis for doing so.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will make an updated copy of such privacy notice available on our website and notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.
Further information
This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal data. If you require any further information, please do not hesitate to contact compliance@cfp.energy.
