Data Protection

Data Protection Statement


KAZIMIR and other members of our group of companies as well as their affiliates in the financial services business (“we”, “our”, “us” or “KAZIMIR”) are committed to maintaining the privacy and security of any personal data we may collect from time to time about our clients, prospective clients or other third parties or their employees, directors, officers or representatives (any of whom are referred to as “you” in this statement). This statement explains how we use your personal data. If you are a legal entity or partnership, by engaging in the provision of services with us, you confirm to us that you have provided your employees, directors, officers or representatives with the information set out in this statement and that they have consented to us using, in accordance with this statement, any personal data about them that you provide to us in connection of our financial services business. By continuing to engage in the provision of services with us, you authorise us to use and transfer the personal data about your employees, directors, officers or representatives in accordance with this statement as amended from time to time in accordance with the “Notification of changes” section below.


What types of personal data do we collect?


We may control, process and use your “personal data” which may include names, postal addresses, e-mail addresses, telephone numbers or any other personal data that you provide to us. We may also, in appropriate cases and to the extent permitted by law, control, process and use certain “sensitive personal data” (e.g. when undertaking “Know Your Customer” (KYC) or anti-money laundering (AML) checks, we may collect information about any offences that you or your employees, directors, officers or representatives have committed). For the purposes of the relevant jurisdiction in which we receive your personal data we are respectively the data controller or the data user of your personal data.


Who might we provide your personal data to?


In the course of running our financial services business we may provide your personal data to any of thefollowing recipients or categories of recipients:


  • our employees, board members, partners, officers or representatives;
  • our third party service providers, business associates, distributors, advisors or auditors (including their
  • employees, directors, officers, sub-contractors or representatives);
  • domestic and foreign regulators (Regulators), governments, law prevention,
  • detection, investigation or enforcement authorities, tax, social or labour
  • authorities (Authorities) and any other authorities or official bodies and their representatives;
  • domestic and foreign courts, tribunals, arbitrators, ombudsmen, mediators, other dispute resolution
  • bodies (DR Organisations) and their representatives;
  • any party who are directly relating to any one of these recipients; and
  • any person that you request us or permit us to keep informed. If you no longer wish us to share your personal data with such person(s) or wish to change your preferences in this respect, please inform our Investor Relations Team ( in writing.


When we provide your personal data to any of the above recipients, that recipient may process your personal data on our behalf or for its own purposes. If the recipient processes the personal data for its own purposes, it will be responsible for its compliance with any applicable law with regard to your personal data.


How may we use your personal data?


We may process, use or transfer your personal data for the following purposes connected to our financial services business:


  •  administering the provision of services between us including, without limitation, billing, internal
  • reporting and analysis and any other ancillary matters;
  • complying with any present or future law, rule, regulation, guidance, decision or directive (including
  • those concerning anti-terrorism, fraud, AML and anticorruption) and, in appropriate cases, carrying
  • out KYC checks and other procedures that we undertake prior to you becoming a customer of ours;
  • establishing, exercising or defending rights;
  • complying with demands and requests made by, or making voluntary disclosures to Regulators,
  • governments, Authorities or DR Organisations;
  • obtaining advice, receiving services or providing a third party with information about matters that
  • may impact on the KAZIMIR Group;
  • providing you with marketing information relating to our products or services; and
  • any other purposes that are incidental to or directly connected with the foregoing purposes or otherwise in the course of our legitimate financial services business activity.


If you do not wish to provide your personal data for any of the purposes listed immediately above except for the purpose of providing you with marketing information, we will not be able to provide our financial services to you. For the purpose of providing you with marketing information relating to our products or services, you are providing your personal data to us on a voluntary basis.


Transferring your personal data abroad


Your personal data may be transferred to any of the recipients identified in this statement in connection with our financial services business, some of which may be outside the European Economic Area including but not limited to the United States of America, and may be processed by us and any of these recipients in any country worldwide. The countries to which your personal data is transferred may not offer an equivalent level of protection for personal data to the laws of relevant country of the KAZIMIR Group entity you provide your personal data to. In connection with any transfer of personal data to such a country we may, if appropriate, implement measures to ensure an adequate level of protection for your personal data.


Updating and retaining your personal data


It is important for us to maintain accurate records of your personal data. Please inform us of any changes to or errors in your personal data as soon as possible and we will update our records accordingly. We will only retain your personal data for as long as, in our reasonable opinion, is necessary to comply with applicable law or for the purposes for which we process your personal data (as set out in this statement).


Recording of telephone calls


To the extent permitted by and in accordance with applicable law, we may monitor and/or record your telephone calls with us.


Your rights


You have certain rights under data protection laws respectively depending on the country of the KAZIMIR Group entity to which you provide your personal data or we use your personal data, including a right of access to as well as a right to receive a copy of your personal data on payment of a reasonable administrative fee as well as a right to request for correction of your personal data. You also have a right to request for information regarding our policies and practices and the kind of personal data held by us. If you require further information in relation to your rights under data protection law you can visit the website of the relevant data protectionregulator or contact us via the contact details below.


Contacting us


If you have any questions or comments on this statement please contact KAZIMIR Investor Relations team by writing to us at 4th Floor, Sun Court, 66-67 Cornhill, London, England, EC3V 3NB telephoning us on +44 20 7400 6950 or emailing us at


Notification of changes


This statement is dated 23 July 2015. From time to time we may amend this statement without notice and an amended statement will be available at or by contacting Investor Relations team. This maybe for a number of reasons, including changes in law, market practice or our treatment of your personal data.