Privacy Policy
You will hopefully be very familiar with the General Data Protection Regulation or GDPR as it is more commonly referred to. Nevertheless, we would strongly encourage you to read this privacy and cookie policy (“this Policy”) and to be familiar with its contents. It explains how Wilson Excel Consulting Limited collects, uses and shares the information you provide to us and the information we collect about you in the course of operating our business (we refer to this as “Personal Data”). It also sets out how we use cookies on our website and in our communications with you.
In this Policy, references to Wilson Excel or “we”, “us”, or “our” are references to Wilson Excel Consulting Limited. Our registered office is at 27 Old Gloucester Street, London, WC1N 3AX.
The types of personal data we process
Expanding on what we have said above, Personal Data is any information that can be used to identify you or that can be linked to you and which we have in our possession or control. Due to the nature of the services we provide, the types of personal data we process can be exceptionally varied. It may include:
The information you provide to us
- Personal details (e.g. your name, date of birth, gender and employment details)
- Contact details (e.g. your address, email, landline number and mobile number)
- Information about your identity (e.g. your nationality, passport information, driver’s licence and National Insurance number)
- Your bank details (e.g. your account name, number and sort code)
- Details of other trades you may have with other foreign exchange providers and which you provide us with or input into our system for comparison purposes
Information we collect about you
- Communication records (e.g. emails)
- Publicly available information (e.g. information made available on websites such as LinkedIn)
- Information from investigatory agencies (e.g. anti-money laundering reports, credit reports, external intelligence reports and other due diligence reports)
- Information gathered when you visit our websites (for more information on this, please see our Cookie Policy)
How we collect personal data
At various different stages in our interaction with you or in relation to our dealings with you, we may collect Personal Data. These can include:
- When you register with us online, subscribe to our services, fill in forms (whether physically or on our website), by corresponding with us (by telephone or email), or in any documents you provide us with
- From cookies on our website (please see our Cookie Policy)
- From feedback provided by you in relation to our services and/or website
- From various third parties including:
- Our partners (e.g. individuals or companies who introduce you to us)
- Our clients (e.g. if you are a third party payee and we are making a payment to you)
- Identity verification agencies (e.g. GBGroup)
- Government and law enforcement agencies (e.g. Companies House, HMRC and NCA)
How we use personal data
We use it to:
- Provide introductory services to regulated entities to assist you with your requirements
- Engage in marketing and business development activity in relation to our services
- Discharge our legal and regulatory obligations
- Establish, exercise or defend our legal rights or for the purpose of legal proceedings
- Record and monitor your use of our websites or our other online services for business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports
- Share with our professional advisors
- Share with a prospective buyer or seller in the event that we buy or sell any business or assets, or substantially all of our assets are acquired by a third party
- Undertake legitimate business interests, such as business research and analysis, managing the operation of our websites and our business
- Look into any complaints or queries you may have
- Prevent and respond to actual or potential fraud or illegal activities
We may also collate, process and share statistics based on an aggregation of information held by us provided that no individual is identified and that such collation is permitted by law.
The basis for processing personal data
We will only process your Personal Data where we have a lawful basis for doing so. Our lawful basis will be one or more of the following:
- Consent – if we have obtained your consent. You can withdraw consent at any time by contacting us.
- Performance of a contract – to perform a contract to which you are a party or to take steps at your request prior to entering into a contract.
- Legitimate interest – necessary for pursuing our legitimate interests (providing foreign exchange services and general business operations).
- Compliance with law or regulation – necessary to comply with applicable legal or regulatory obligations.
Sharing information with third parties
In providing services and complying with our obligations, we may share your Personal Data (to the extent permitted by law) with:
- Third party agents, suppliers or contractors bound by confidentiality (e.g. IT service providers).
- Third parties relevant to services we provide (e.g. counterparties, professional advisers, regulators, authorities).
- A designated third party when required by law, regulation or court order.
Third parties we use
Google Analytics
Google Analytics is a web analytics service provided by Google, Inc (“Google”). Google uses cookies to help us analyze how users use our website. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. Google will truncate/anonymize the last octet of the IP address for EU Member States and parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. On behalf of our website, Google will use this information for the purpose of evaluating our website usage and compiling reports. Google will not associate your IP address with any other data held by Google. You may refuse these cookies by adjusting your browser settings (see our Cookie Policy), or by installing Google’s opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=en-GB. Further terms: Analytics Terms and Google Privacy Policy.
Google reCAPTCHA
We use “Google reCAPTCHA” to check whether form submissions are made by humans. It analyses visitor behaviour (e.g. IP address, mouse movements) in the background and forwards data to Google. Processing is based on Art. 6 (1)(f) GDPR—our legitimate interest in preventing fraud. More: Google Privacy and reCAPTCHA Info. For cookies used, see our Cookie Policy.
Transfers to EEA
We may transfer Personal Data outside the European Economic Area (e.g. when reporting to foreign authorities). In such cases we comply with GDPR security standards and ensure data is stored securely. By submitting your Personal Data you agree to these transfers.
Transmission and keeping your information safe
Internet transmission is not completely secure. Although we use strict procedures and security features in line with GDPR to protect your data, we cannot guarantee absolute security. Transmission is at your own risk.
How long we keep your information
We retain Personal Data only as long as necessary for the purpose collected, subject to:
- The purposes for which we are using it (e.g. while providing services);
- Legal obligations (e.g. Money Laundering Regulations 2017 and Companies Act 2006 require up to 6 years retention).
At the end of retention, data is deleted or anonymised.
What are your rights?
You have rights under GDPR, and we will respect requests to exercise them:
- Access – Request a Subject Access Request; we’ll respond free of charge within 30 days (unless request is unfounded).
- Correction – Ask us to correct inaccurate, out-of-date or incomplete data.
- Erasure – Request deletion when data is no longer necessary (subject to legal retention rights).
- Restriction – Ask us to stop processing your data when you contest its accuracy or lawfulness.
- Withdrawing consent – You may withdraw any consent given at any time.
- Legitimate interests – Ask us to stop if you object to processing based on our legitimate interests.
- Marketing – Opt-out of direct marketing at any time.
Submitting a request
You can exercise any of these rights by contacting us at cs@wilsonexcel.com. To protect confidentiality, we will ask you to verify your identity before proceeding. If you’ve authorised a third party to act on your behalf, they must provide proof of your permission. If we cannot comply, we will explain our reasons.