Terms and Conditions
Zinal Advisors Limited is registered as a private limited company in England and Wales with company number 13910768. Its registered office is at Eighth Floor, 6 New Street Square, New Fetter Lane, London, United Kingdom EC4A 3AQ.
This website and all information contained on this website is provided for information and/or illustrative purposes only and should not be treated as legal, tax, financial or other advice or as the offer of such advice. You should seek professional, independent advice before making any decision in relation to your investments or other financial matters.
Nothing on this website constitutes an offer, invitation, inducement, promotion or endorsement by Zinal Advisors Limited (or by any of its directors, officers, employees, consultants, agents, representatives or affiliates) of any investments, firms or any other matters set out, or referred to, on this website.
This website is not directed at, nor is it intended for distribution to, any person that is located in, a citizen or resident of, or associated with any jurisdiction where such distribution would violate any law or regulation and/or would require any registration, licensing, other consent or no objection or application in such jurisdiction.
Website Privacy Notice
About this notice
This privacy notice explains why and how Zinal processes the personal data of our clients and prospective clients, and visitors to our website hosted at www.zinal.com (referred to in this notice as “you” or “your”).
This privacy notice was updated in June 2023 and supersedes any previous privacy notice or similar terms provided by, or on behalf of, Zinal in connection with the services we provide to you.
How we collect your personal data
We collect your personal data in various ways, principally:
- when you access and navigate around our website;
- when you communicate with us by post, email, telephone or via the website, for example when you contact us to request information about our services;
- when you ask us to provide services to you and provide us with your personal data in application forms for investment advice and arranging services (and in accompanying identification documents);
- from third parties and publicly available sources, for example when we carry out due diligence checks on you before we can accept you as a client;
- from third party introducers or other intermediaries, and from your agents and representatives, where they are interacting with us on your behalf; and
- in other ways as you interact with us during your time as our client, for example when you meet with us or when we exchange formal correspondence and other communications with you.
The categories of personal data we collect
We may collect the following types of personal data about you:
- Contact information, including your name, address, email address and telephone number;
- Identification and due diligence information, including your date of birth, nationality, passport information, proof of address, national insurance number (or other tax identification number) and due diligence information such as the results of anti-money laundering and ‘know your client’ background checks;
- Financial and wealth related information, including bank account details and information relating to your financial situation such as your assets, net worth, income, source of wealth and your investment objectives; and
- Technical information about your use of our website, including information collected through the use of browser ‘cookies’, for example details of your domain name, location and internet protocol (IP) address, operating system, browser version, the date and time of connection, the content viewed during a particular browsing session, and how long you as a website visitor stayed on a particular page.
We may also collect special categories of personal data, including more sensitive personal data, such as data relating to criminal convictions and offences, where relevant for the purposes set out below.
The legal grounds and purposes for processing your personal data
We may process your personal data because it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. In this respect, we may use your personal data:
- to interact with you before you become our client, for example when you express your interest in our services (for example, to send you a proposal or answer enquiries about our services);
- once you have engaged us and become our client, to provide you with the services as set out in our terms of business or any other contractual document between you and us;
- corresponding and interacting with you (or others acting on your behalf) about our services and dealing with any concerns or feedback you may have; and
- maintaining records of your instructions, our advice and the arrangements made on your behalf in relation to investments we have advised on as an appointed representative of Robert Quinn Advisory LLP.
We may also process your personal data for our compliance with our legal obligations. In this respect, we may use your personal data:
- to confirm your identity and carry out due diligence checks, including to confirm your source of wealth for anti-money laundering and 'know your client' purposes;
- to fulfil our tax reporting obligations, principally to HM Revenue and Customs but including under any reporting agreement entered into with a tax authority or revenue service from time to time; and
- to meet our other compliance and regulatory obligations, including in order to comply with any requirement of any applicable statute, regulation or regulatory rule to which we are subject.
We may also process your personal data because it is necessary for our or a third party's legitimate interests. Our "legitimate interests" include our commercial interests in operating our business in a client-focused, efficient and sustainable manner, in accordance with all applicable legal and regulatory requirements. In this respect, we may use your personal data:
- to assess the information that you provide to us through email, telephone or our website, and to find out more about you before contacting you in response, where appropriate;
- to monitor and evaluate the performance and effectiveness of our services and our website;
- outsourcing selected functions to third parties (for example, suppliers of hosted software solutions or cloud storage providers) for the purposes of efficient, fast and secure access to data; and
- for our marketing purposes, including in order to keep you informed (by letter, telephone, and email) of our investment insights, news updates or events which may be of interest to you.
Note: If you do not wish to receive such marketing information, please let us know now or at any time in the future, and your details will be removed from our mailing list(s).
We may also process your personal data where:
- it is necessary for reasons of substantial public interest (for example, where the due diligence checks we carry out involve our processing data relating to criminal convictions and offences and we do not ask your consent because to do so might lead to a 'tipping off' offence under anti-money laundering legislation);
- it is necessary for the establishment, exercise or defence of legal claims (for example, to protect and defend our rights or property, and/or the rights or property of our clients, or of third parties); and
- we have your specific or, where necessary, explicit consent to do so.
When your personal data may be shared with others
In order to provide our services to you, we may disclose your personal data:
- to Robert Quinn Advisory LLP as our principal firm (and to other organisations in the Robert Quinn group of companies);
- to other organisations including those in the Zinal group of companies, such as Zinal GP Ltd and Zinal Growth Partners Limited (all entities established in Jersey);
- to other third 'data processors' we may engage to perform, or assist in the performance of, our services or to advise us, for example agencies we engage to perform anti-money laundering checks on our clients and prospective clients, where relevant;
- to your agents and representatives, where they are interacting with us on your behalf (for example, brokers and custodians of your assets); and
- in circumstances where we are required or authorised by law (including applicable data protection laws), court order, regulatory or governmental authorities to disclose your personal data.
Transferring your personal data overseas
Where relevant for your services, your personal data may be transferred to and processed outside of the UK and/or the European Economic Area ("EEA") in countries or territories that do not provide the same level of protection for personal data as the UK and the EEA does. Where this happens, we will put in place appropriate measures to ensure the adequate protection of your personal data when it is transferred outside of the UK and/or the EEA, as required by the GDPR.
In these circumstances, your personal data will only be transferred on one of the following grounds:
- the country or territory to which the transfer is made ensures an adequate level of protection for personal data (please note that Jersey, where Zinal’s group companies are based, has such an ‘adequacy decision’ from the European Commission which has also been adopted by the UK Secretary of State);
- Zinal and the recipient of the personal data outside the UK / the EEA have signed a form of model data protection clauses (standard contractual clauses) approved by the European Commission or the model international data transfer agreement approved by the UK Information Commissioner’s Office; or
- there exists another situation where the transfer is permitted under applicable law (for example, where we have your explicit consent to make the transfer).
You can obtain more details of the protection given to your personal data when it is transferred outside the UK and/or the EEA by contacting us using the details set out below.
How long your personal data is kept
We will retain your personal data for as long as we are providing you with the services referred to in any relevant terms of business or any other contractual document, and for as long as permitted or required for legal and regulatory purposes after the relationship between you and us has ended, or if your application for a particular service or services is declined or abandoned.
Subject to any other notices that we may provide to you, we will typically retain your personal data for a period of seven years following the date of our last interaction with you (for the purposes described above). However, some information may be retained for longer than this, for example where we need to retain it for the purposes of legal claims or for compliance with particular directions, instructions or rules made by a competent regulatory authority.
Your rights in relation to your personal data
Under the GDPR, you have the following rights in relation to our processing of your personal data. Please note that these rights are not absolute, and we may be entitled (or required) to refuse requests where exceptions apply.
- to obtain access to, and copies of, the personal data that we hold about you;
- to require us to correct the personal data we hold about you if it is incorrect;
- to require us to erase your personal data in certain circumstances;
- to require us to restrict our data processing activities in certain circumstances;
- to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on you;
- to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller (including another investment services firm); and
- where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal.
Note: If you have given your consent and you wish to withdraw it, please contact us using the contact details as set out below. Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services.
If you are not satisfied with how we are processing your personal data, you can raise a concern with the Information Commissioner. You can also find out more about your rights under data protection legislation from the Information Commissioner's Office website available at: www.ico.org.uk.
If you have any comments or questions about how we process your personal data, you can contact us by writing to our registered office: Zinal Advisors Ltd, Eighth Floor 6 New Street Square, New Fetter Lane, London, EC4A 3AQ, United Kingdom. Alternatively, you can contact us by email: firstname.lastname@example.org