Privacy Policy
Welcome to our Privacy Policy page. When you use our web services, you trust us with your information. This Privacy Policy is meant to help you understand what data we collect, why we collect it, and what we do with it. This is important; we hope you will take time to read it carefully. Remember, you can find controls to manage your information and protect your privacy and security. We’ve tried to keep it as simple as possible.
Privacy Policy
This notice (privacy notice) applies to personal information we collect from you when you use this site. If you are a Sargam Token customer, or otherwise have a relationship with us, we may also have provided you with a separate privacy notice setting out how we use your personal information, which will also apply.
Sargam Token and its subsidiaries (collectively referred to as “Sargam Token”, “we”, “us”) take data protections and privacy responsibilities seriously. This privacy notice explains how we collect, use and share personal information in the course of our business activities, including:
- What personal information we collect and when and why we use it;
- Legal rights available to help manage your privacy; and
- How you can contact us.
Carrying out direct marketing;
Transferring personal information globally;
How we protect and store personal information;
How we share personal information within Sargam Token, with third parties and regulators;
Using cookies and other technologies;
We may amend this notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this notice. If we make significant changes to this privacy notice, we will seek to inform you by notice on our website or email (“Notice of Change”).
What Personal Information We Collect And When And Why We Use It
Sargam Token collects information about you if you:
- Register with or use our Website or online services;
- Represent one of our institutional clients;
- Work with us as a service provider; or
- Visit a Sargam Token office or register to attend a Sargam Token event.
- Are a private client;
PERSONAL INFORMATION WE COLLECT WILL FALL WITHIN ONE OF THE BELOW:
- Identification data including unique descriptors– Government issued identifiers, other unique identifiers such as date of birth, and personal descriptors that might identify you.
- Your name and how to contact you– basic information about you, including your signature;
- Contractual details – information collected as part of the products and services we provide you.
- Financial and transactional – financial information about you, transactional information and credit information, account authentication details.
- Socio-demographic– includes details about your work or profession, nationality, education.
- Behavioural – information about how you use our products and services.
- Technical information– details about your devices and technology that you use to access our services, including IP address.
- Location – data we receive about where you are.
- Publicly available information – details that are in public records and information about you that is openly available on the internet.
- Sensitive categories of data – the law and other regulations treat some types of personal information, including personal information relating to health and criminal convictions and offenses as special and affords them additional protections. We will only collect and use these types of data if the law allows us to do so.
- Communications – information we capture through your communications with us, e.g. telephone conversations, emails and instant messaging.
Personal information we collect will be used for one or more of the following services:
1. To manage your relationship with Sargam Token
- To manage our relationship with you or your business, for example how to best contact you
- To develop new ways to meet our clients’ needs and to grow our business, for example by seeking client feedback or sharing market research
- To develop and carry out marketing activities in order to keep our clients informed about our products and services
- To develop and manage our brand
2. To administer the products and services we deliver
- To make and manage client payments
- To manage fees, charges and interest due on client accounts
- To exercise our rights set out in agreements or contracts
- To collect and recover money that is owed to us
3. To protect our brand, our business and our clients’ interests
- To manage risk for us and our clients
- To protect our IT systems, network and infrastructure
- To run our business in an efficient manner, for example managing our financial position, planning, corporate governance or audit
- To comply with all applicable laws, law enforcement and regulatory requirements
- To respond to complaints and seek to resolve them
4. Crime prevention and detection
- To comply with other laws and regulations that apply to us
- To detect, investigate, report, and seek to prevent fraud, financial crime and anti-money laundering, for example through know-your-customer checks, AML screening and other identity checks
The lawful basis on which we will collect and use this data will include:
- Consent (where required by law) – you have provided your consent to us using the personal information, for example if you have agreed to receive marketing
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Legitimate interests – our use of your personal information is in our legitimate interest as a commercial organisation to provide services to our clients, provided our use is proportionate and respects your privacy rights, where we rely on our legitimate interest, we will tell you what that interest is. Our legitimate interests include:
- Seeking your consent when we need to contact you
- Keeping our records up to date and honouring your communication preferences
- Ensuring we are able to effectively and efficiently meet our contractual obligations
- Working out which of our products or services might interest you and telling you about them
- Complying with regulatory requirements
- Public interest – our use of your personal information is required for regulatory reasons that are in the public interest, for example to prevent and detect financial crime.
- Contractual obligation – our use of personal information is necessary to fulfil a contract we have with you or to take steps to enter into a contract with you, for example
- Legal obligation – our use of your personal information is necessary to comply with a legal obligation that we have, for example where we are required to report to tax authorities.
Children’s Privacy
We do not accept users under the age of 21 and no part of our website is structured to attract anyone under 21. In the event that we learn we have inadvertently collected personal information from an individual under the age of 21, we will take reasonable steps to delete that information. If you believe that we might have any information from an individual under 21, please contact us at info@sargamtoken.com
How You Can Contact Us
The primary point of contact for all issues arising from this privacy notice, including exercising your rights described above is our Data Protection Officer. The Data Protection Officer can be contacted in the following ways:
By Email
info@sargamtoken.com