This policy is aimed at describing the conditions under which CA Indosuez Wealth (Miami) (hereafter known as the "Bank") may collect and process, in the course of its activities, the personal data of any data subject, particularly its clients and users of this Site.
Learn more about important personal data protection concepts: Appendix I
In the course of its activities, the Bank may process, whether automatically or not, personal data of natural persons: existing and potential clients, users of this Site (when they fill out online forms provided to them on this Site) and any other natural person (such as an agent or executive), these people all being individually known below as the "Data Subject".
Personal data regarding Data Subjects which the Bank collects or processes, acting as processing manager, is necessary for it to meet its legal or regulatory obligations, to enable the execution of pre-contractual measures or contracts to which the Data Subject is a party and/or to pursue the Bank's legitimate interests, while respecting the rights of the Data Subject. When such data is collected for other purposes, the Bank must first obtain the consent of the Data Subject.
With regard to Data Subjects who are clients, the Bank uses their personal data to offer them personalised offers and advice, higher-quality service, and everything they need to help make the best decisions.
In the absence of certain information regarding a client that is needed to perform a service, the Bank will not be able to provide him or her the benefit of the service for which that data had been required.
Purposes of personal data processing
The personal data of Data Subjects may be processed, primarily for the purposes mentioned above.
The Data Subject can access detailed information on how his or her personal data is used, both with respect to the purposes of the processing and the legal bases that enable the Bank to process his or her data, and how that data may be transferred to non-member states of the European Union.
Learn more about each process and related data usage (Appendix II)
Storing personal data
This personal data is processed and stored for as long as needed for the intended purpose, and no longer than for a period corresponding to the duration of the contractual or business relationship, plus whatever time is needed for the liquidation and consolidation of rights and for the statutes of limitations and avenues of appeal to lapse.
To meet its legal obligations or respond to requests from regulators and administrative authorities, as well as for the purposes of historical, statistical, or scientific research, the Bank may archive the data under the conditions set out by applicable regulations.
Rights of the Data Subject
The Data Subject, at all times, has the following rights, under the conditions set out by applicable regulations:
The Data Subject may also, at any time and without justification, oppose the use of his or her data for the purposes of commercial prospecting, including profiling1 when it is linked to that purpose, by the Bank or by third parties, or when the processing is legally based on consent, withdraw his or her consent, by writing a letter to CA Indosuez Wealth (Miami), 600 Brickell Avenue, 37th floor, Miami, Florida, 33131, Attn: Chief Compliance Officer Postage fees shall be reimbursed upon request by the Data Subject.
The Data Subject may exercise his or her rights by contacting the Bank’s Chief Compliance Officer, whose contact information appears below in the section entitled "Data Protection Officers".
In support of his or her request, the Data Subject may use the rights exercise form below (Appendix III).
The Data Subject is informed that exercising some of the aforementioned rights may prevent the Bank from providing him or her with certain products or services in some cases.
Data Protection Officer (DPO)
The Bank has designated a Data Protection Officer, whom the Data Subject may contact at the following address: firstname.lastname@example.org; 600 Brickell Avenue, 37th floor, Miami, Florida 33131, Attn: Chief Compliance Officer.
Complaints to Authorities
By contacting the DPO, the Data Subject may access detailed information on his or her rights and how his or her personal data is being used, in particular with respect to the purposes of processing, the legal bases that enable the Bank to process data, its storage periods, its recipients, and, if applicable, its transfer to countries outside the European Union as well as the guarantees implemented.
The transactions and personal data of Data Subjects are covered by professional secrecy, to which the Bank is bound in accordance with its legal and regulatory obligations.
However, in order to meet those obligations, the Bank may be required to disclose information regarding those Data Subjects who are clients to legally authorised judicial or administrative authorities. Thus, for example, some information may be sent to the tax authorities (declaring the opening of accounts, declaring investment income).
Furthermore, each Data Subject who is a client expressly authorises the Bank to share data about him or her and update that data with the following third parties:
Finally, the Data Subject expressly authorises the Bank to send him or her, by e-mail or by such other method agreed by the Data Subject and the Bank, any information about him or her, which may be covered by professional secrecy.
The list of personal data recipients may be sent to the Data Subject upon simple request by him or her to the Bank, at 600 Brickell Avenue, 37th floor, Miami, Florida, 33131, Attn: Chief Compliance Officer.
1"profiling": any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements (art. 4 parag. 4 of Regulation 2016/679 of 27 April 2016).