1. What information are we collecting and how are we collecting it?
Clear Capital Markets Limited (“the Firm”, “we”, “us”, or “our”) is the data controller responsible for yourpersonal data. This Privacy Notice explains how we collect, use, share, and protect your personalinformation.
a. Information You Provide
We collect the personal information you give us directly, for example:
- When you complete account opening forms or provide supporting documents (such as identification or proof of residence).
- When you access and trade on your account via the custodian’s platform.
- When you correspond with us by phone, email, or other communication channels.
This information may include your name, contact details (email, phone, address), financial information (income, wealth), identification numbers (e.g., National Insurance), date of birth, employment and professional details, trading history, and records of products or services you use or are interested in.
b. Information from Other Sources
We may also collect personal data about you from:
- Public sources such as Companies House or the Electoral Register.
- Third parties, including credit reference or fraud prevention agencies, or financial intermediaries acting on your behalf.
c. Monitoring of Communications and Account Activity
Subject to applicable laws, we may monitor and record communications with us, including calls, emails,social media messages, and other interactions. We do this for:
- Regulatory compliance and legal obligations.
- Crime prevention and detection.
- Security of our systems and communications.
- Quality control, staff training, and providing you with records of communications on request.
We may also monitor activity on your account for similar purposes. These activities are justified under our legitimate interests or legal obligations and are conducted in accordance with applicable laws, including FCA rules and UK GDPR.
2. Why we collect your information
The Firm collects your personal information in order to provide you with our products and services, toestablish and manage your account and to comply with the law. By collecting your information, the Firmis able to monitor and improve the services we offer to our existing and potential clients.
3. How we use your information
We process your personal data only when there is a valid legal basis under Data Protection law. This mayinclude:
- Performance of a contract – to deliver the services you have requested and manage your account.
- Legitimate interests – for purposes such as governance, analytics, fraud prevention, marketing, and improving our services.
- Compliance with legal obligations – to meet regulatory, reporting, or other legal requirements.
- Consent – where you have explicitly agreed to specific uses of your personal data.
Your personal information is used in line with these legal bases to provide and manage services, ensure security and compliance, support marketing and research, or carry out activities you have consented to.
These purposes include:
a. Providing and Managing Services
- Delivering the services you request, including processing transactions, customer support, and managing your accounts.
- Verifying your identity when you contact us or access your account.
- Maintaining and updating your personal profile and account information.
- Contacting you regarding your account, services, or products, including tracing your whereabouts or recovering debts.
- Tailoring our services to your needs and interests.
b. Fraud Prevention, Security, and Analytics
- Conducting checks to prevent fraud, money laundering, and other financial crimes.
- Refusing or stopping services if a risk of fraud or financial crime is identified.
- Performing identity verification, anti-fraud, and anti-money laundering checks.
Technical website data processing (behavioural signals, device characteristics, advertising click identifiers) is conducted under our legitimate interests for fraud prevention and service improvement, this data cannot directly identify you and is subject to retention limits.
c. Marketing, Research, and Analysis
- Sending information about our products, services, and relevant opportunities.
- Conducting market research, analytics, and developing anonymized statistical data, which may beshared with other companies but cannot personally identify you.
- Improving and developing new services.
- Requesting feedback on our services.
- You may opt out of marketing communications at any time by contacting our Admin team at: enquiries@clear-cm.co.uk
d. Legal and Regulatory Compliance
- Complying with legal obligations, regulatory requirements, and related disclosures.
- Establishing or defending legal rights.
- Assisting with crime prevention, detection, and investigation.
- Responding to requests under Data Protection law.
e. Consent-Based Uses
- Sharing your personal data with third parties when you request or agree to such disclosures.
- Marketing activities where you have explicitly provided consent.
- You may withdraw consent at any time by notifying us in writing.
4. To whom may we disclose your information
We may share your personal information with the following parties where necessary and legally permitted:
- Regulators and authorities – including the Financial Conduct Authority, other UK and international regulatory or government bodies, and any court or tribunal.
- Financial institutions and corporate partners – including those involved in processingtransactions, providing services, or nominated by you.
- Fraud prevention and law enforcement agencies – where false information is provided or fraud, money laundering, or other financial crime is suspected.
- External service providers – who assist the Firm in delivering services or managing accounts.
- Your representatives – such as financial advisers, brokers, solicitors, or accountants.
- Other account holders or connected parties – for example, individuals named on your application.
- Authorities or parties required by law – including disclosures necessary under legal or regulatory obligations.
- International transfers – any sharing outside the UK or EEA is protected by adequacy decisions, Standard Contractual Clauses (SCCs), or other approved safeguards.
We do not sell your personal information to third parties for marketing purposes. Any external organisation handling your data is required to respect confidentiality, comply with relevant Data Protection laws, and uphold your privacy rights.
5. What rights do you have?
Your rights are as follows in respect of the personal information we hold about you:
- The right to be informed about processing of your personal data.
- The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed.
-The right to object to processing of your personal data.
- The right to restrict processing of your personal data.
- The right to have your personal data erased.
- The right to request access to a copy of your personal data and information about how we process it. Please make all requests for access in writing (see how to contact us for details) and provide us with evidence of your identity.
- The right to move, copy or transfer your personal data.
- You have rights in relation to automated decision-making, including the right to request human intervention and to contest decisions.
- You have the right to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk) if you believe your data has been handled unlawfully.
Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request.
You can contact us by sending an email to enquiries@clear-cm.co.uk. If you prefer to contact us via phone or by post, please refer to the below section "How to contact us".
We will stop processing your personal data unless the processing is for the establishment, exercise or defence of legal claims or we have a legitimate business purpose or legal grounds for the processing.
6. How we protect your information
The Firm is committed to protecting the privacy of all personal information that we obtain from you.
We continue to adopt industry and information security best practices to protect your personal information and ensure that unauthorised persons cannot access it. Measures include encryption of data during transmission, strong authentication mechanisms, cybersecurity processes and secure access to machines and data.
We train our employees who handle personal information to respect the confidentiality of customer data and the privacy of individuals.
7. How we protect your information in data transfers
We may transfer personal information to other countries outside of the UK and European Economic Area. In such circumstances, we will ensure that any international transfers of personal data are lawful and subject to appropriate safeguards, including adequacy decisions, Standard Contractual Clauses (SCCs), or other approved mechanisms
8. How you can protect your information
Just as at the Firm, you should care about the security of your personal data. Do not give your security details to log in to your account, such as passwords or passcodes, to anyone else. If you feel someone may have gained knowledge of your login details, please contact the Firm so we can support you and protect you and your information.
Additionally, we recommend securing your devices with a password or passcode
9. How long we hold your information
We keep your personal information only as long as necessary to provide our services, meet legal or regulatory requirements, and maintain proper business records. In general, this means your data is securely deleted or anonymized at least five years after the end of our relationship with you.
In some cases, we may retain information for longer where required by law, regulation, or contractual obligations. All deletion or anonymization is carried out in line with the Firm’s internal Record Keeping Policy.
10. What to do if you have a complaint
If you have any questions or complaints about the way the Firm handles your information, please contact us.
You also have the right to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk) if you believe your data has been handled unlawfully.
11. Changes to our Privacy Policy
The Firm may change this Privacy Notice from time to time. When such a change is made, we will post are vised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this Privacy Notice periodically, so you are aware of any changes. By using our services, you agree to this Privacy Notice.
12. How to contact us
If you have any questions about this Privacy Notice or wish to exercise your data protection rights, you can contact us by:
- Phone: +44 (0) 203 869 6080
- Email: enquiries@clear-cm.co.uk (please include “Data Protection Query” in the subject line)
- Post: Data Protection Officer, Clear Capital Markets Limited, 6th Floor, Wilson's Corner, 23–25 Wilson Street, London, EC2M 2DD
We aim to respond to all requests promptly within one month.
We will reach out for a quick introductory fact find to see how we can best serve your specific needs and arrange a convenient time for a consultation with a member of the appropriate specialist team.
An Advisory Broker will contact you for a deeper fact find and share information on how we can best enhance your portfolio.
We will conduct a full RCP in accordance with FCA regulations to ensure that your appropriate risk profile is set. You will then have access to an extensive suite of investments, supported by your dedicated Advisory Broker.
