Strategia Wealth and all its affiliates (hereinafter referred to as “we” or “us”) are committed to maintaining the privacy of every current, former and prospective customer. We recognize that you entrust important personal information to us, and we wish to assure you that we take seriously our responsibilities in protecting and safeguarding this information. This Privacy Policy (“Policy”) describes in detail how we deal with the personal data we collect about you and how we process it.

This Policy may be updated at any time. Please ensure that you regularly read the latest version of this page.

Information we collect

We will only collect and use your personal data where we have lawful grounds and legitimate business reasons to do so.

We collect and process your personal data to:

  • ensure our compliance with our regulatory obligations under the applicable anti-money laundering or other applicable laws and regulations;
  • assess an application by you in respect of banking or investment products or services from us; and
  • as is necessary for the performance of our obligations to you under the agreement you enter into with us at the time we on-board you, as may be amended in accordance with its terms.

As a result, the personal data you provide to us at any point, may be shared by us with one or more of the following organizations or persons:

  • banking, regulatory, taxation, governmental or other investigatory authorities, a court or other authority of competent jurisdiction;
  • our affiliates, officers, directors, employees, professional advisers and auditors;
  • any professional adviser and/or professional services business that you have been using to liaise with us;
  • any parties that we work with to provide you with our products or services and to support our business; and
  • any other party with whom you have consented that we may share your personal data with.

Most of your personal data is collected at the time we on-board you as a customer. It may also be collected when there are changes to your personal data and our records need to be updated. We will mostly collect your personal data directly from you. In some cases, as and when required, we may also collect information about you:

  1. As a result of us recording certain telephone calls which our employees may have with you, and storing those recordings, in order to satisfy our legal and regulatory obligations or for the Bank business purposes.
  2. If you register to use the password-protected section of our site, we will ask you to provide us with certain information about yourself. This information may include your name, company name, title, address, country of residence, e-mail address, telephone number, account number, assets, income and financial situation. We use such information about you to verify your identity and eligibility to receive certain products or services, to provide information to you about products and services that we believe may be of interest to you, to record your interest in products and services that we offer, and to respond to your requests for information. We may also use cookies in such section of our Site to collect usage information, and to facilitate your movement within the Site (e.g. remembering passwords during a session).
Security of data transfers

Data that is transported over an open network, such as the Internet or e-mail, may be accessible to anybody. The Company cannot guarantee the confidentiality of any communication or material transmitted via such open networks. When disclosing any personal information via an open network, you should remain mindful of the fact that it is potentially accessible to others, and consequently, can be collected and used by others without your consent. In particular, while individual data packets are often encrypted, the names of the sender and recipient are not. A third party may therefore be able to trace an existing bank account or relationship or one that is subsequently created. Even if both the sender and recipient are located in the same country data may also be transmitted via such networks to other countries regularly and without controls, including to countries that do not afford the same level of data protection as your country of domicile.

For certain services, we use strong encryption to transfer your data. In these cases you will be told separately about the treatment of this data and about the details of encryption.

Your data may be lost during transmission or may be accessed by unauthorized parties. We do not accept any liability for direct or indirect losses as regards the security of your data during its transfer via Internet. Please use other means of communication if you think this is necessary or prudent for security reasons.

Protection, Processing and Use of Personal Data

We use your personal information to enhance the quality of the products or services we wish to provide to our customers or in connection with your investments with or through us and to maintain contact details for those with whom we deal. We restrict access to personal information about you to those employees, agents or other parties who need to know that information to provide products or services to you or in connection with your investments with or through us. 

We maintain physical, electronic and procedural safeguards to guard your personal information, including firewalls, individual passwords and encryption and authentication technology. We do not use for purposes other than as set out above, or disclose to any third party any personal information about our customers or former customers, except with such customer’s consent or as otherwise permitted or required by law. In cases where we believe that additional products and services may be of interest to you, we may share your personal information with affiliates of the Bank to the extent permitted by applicable law. We may also disclose this information to firms that perform services on our behalf to the extent permitted by applicable law. These service providers are required to treat the information confidentially and use it only for the purpose for which it is provided. Certain jurisdictions may have more stringent privacy requirements that will prevent disclosure of your personal information to any other person or entity, including affiliates.

Store of personal data

We will only hold your personal data for as long as is necessary for the purposes for which it was obtained.
However, if we are obliged pursuant to our regulatory or statutory requirements to retain your personal data for a specified period of time, then we will retain your personal data for that minimum specified period.

Your rights

As data subject, you have a number of rights under applicable data protection laws in respect of your personal data, which include but are not limited to the following:

  • Right of access to your personal data;
  • Right to rectify inaccurate personal data;
  • Right to erase your personal data if the continued processing of such data is not justified;
  • Right to restrict the processing of your personal data;
  • Right to object to processing of your personal data (including direct marketing);
  • Right not to be subject to a decision based solely on automated processing of your personal data, including profiling, which produces legal effects concerning you or significantly affects you;
  • Right to lodge a complaint with the Data Commissioner through the Data Protection Office.

If you wish to obtain information about your rights under the new Data Protection legislation, please consult the Data Protection Office website:

Your consent and your right to withdraw your consent

Your consent must be a freely given, specific, informed and unambiguous indication of your wishes to our collection, use or processing of your personal data, either by a statement or a clear affirmative action on your part.

We will process your personal data if you give us your consent in accordance with the law. Our account opening mandate and agreements (including our General Terms and Conditions) contain express provisions regarding your consent, pursuant to which you authorise us to process your personal data.

However, we will not be able to provide you certain products or services as a result of such withdrawal.

Notwithstanding the withdrawal of your consent, we may still continue to collect and process your personal data if we are obliged to do so pursuant to our regulatory or statutory requirements [or if this is necessary pursuant to a contract to which we are a party].