Last updated July 2023
This Policy is issued by Mariana UFP (together, “MUFP”, “we”, “us” or “our”), identified as Controller(s) in the Glossary section below and is addressed to individuals outside our organisation with whom we interact, including visitors to our websites (our “Sites”), customers, personnel of corporate customers and vendors, and other recipients of our services, employment candidates, current staff members (together, “you”). Defined terms used in this Policy are explained in the Glossary section below.
This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law or regulation. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.
Any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
Any person whose personal data is being collected, held or processed.
Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;
The natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller
Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the website or a third-party to recognize you and make your next visit easier and the website more useful to you. Cookies can be "persistent" or "session" cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.
When you use and access our website, we may place a number of cookie files in your web browser.
We use cookies for the following purposes:
We use these cookies to remember information that changes the way our website behaves or looks, such as a user's preferred language or the region in which they are located. Disabling these cookies will affect the functionality of the website and may prevent users from fully experiencing our website.
We use these cookies to understand how visitors interact with our website by collecting and reporting information anonymously. This data helps us understand and analyse how well the website performs and where it needs improvement.
These are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
You can prevent the setting of cookies by adjusting the settings on your browser. However, be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will result in disabling all functionalities and features of our site. Therefore, it is recommended that you do not disable cookies.
Collection of Personal Data: We collect, use, store and process Personal Data about you; MUFP ensures that it has a legal basis for processing the Personal Data of Data Subjects.
MUFP collects Personal Data from a variety of sources as follows:
MUFP creates Personal Data about you, such as records of your interactions with us, and details of your accounts, subject to applicable law and regulation.
The categories of Personal Data about you that we may Process, subject to applicable law, are as follows:
given name(s); preferred name(s); nickname(s), gender; date of birth; age; marital status; Social Security or national insurance number; passport number(s); other government issued number(s) (tax identification number(s); driving licence number(s)); nationality; lifestyle and social circumstances; images of passports, driving licences and signatures; authentication data (passwords, mother’s maiden name, challenge/response questions and answers, pins, facial and voice recognition data); photographs; visual images; and personal appearance and behaviour;
names and contact details of family members and dependents;
address; telephone number; email address; and social media profile details;
industry; role; business activities; names of current and former employers; work address; work telephone number; work email address; and work-related social media profile details;
details of your education and qualifications;
billing address; bank account numbers; credit card numbers; cardholder or account holder name and details; instruction records; transaction details; and counterparty details;
IP addresses; cookies, activity logs, online identifiers, unique device identifiers, and geolocation data.
Purposes for which MUFP may Process your Personal Data, subject to applicable law are:
fulfilling our regulatory compliance obligations, including ‘Know Your Client’ checks and confirming and verifying your identity (including by using credit reference agencies), screening against government, supranational bodies (including but not limited to the European Union, the Office of Foreign Assets Control and the United Nations Security Council) and/or law enforcement agency sanctions lists, internal sanctions lists and other legal restrictions;
on-boarding new clients and compliance with our internal compliance requirements, policies and procedures;
conducting credit reference checks and other financial due diligence;
administering relationships and related services; performance of tasks necessary for the provision of the requested services: communicating with you in relation to those services;
communicating with you via any means (including via email, telephone, text message, social media, post or in person) subject to ensuring that such communications are provided to you in compliance with applicable law: and maintaining and updating your contact information where appropriate; Our main channel of communication is through email and we conduct marketing in adherence with the Privacy and Electronic Communications Regulation. This allows for business-to-business marketing on an opt-out basis in so long as a lawful means of processing has been established. Our lawful basis for processing in this instance is Legitimate Interests as well as the client’s Consent. We may also contact you by telephone from time to time to follow up on an interest you have expressed in a course or to verify contact information. If you wish to unsubscribe click on the unsubscribe link available on any email communication that has been sent to you or email, enquiries@marianaufp.com
operation and management of our Sites; providing content to you: and other information to you: and communicating and interacting with you via our Sites;
management of our communications systems, operation of IT security/IT security audits;
health and safety assessments and record keeping: and compliance with related legal obligations;
physical security of our premises (including records of visits to our premises and CCTV recordings); and electronic security (including login records and access details, where you access our electronic systems);
detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law;
compliance with our legal and regulatory obligations under applicable law, including the recording of telephone lines where required;
establishing, exercising and defending legal rights;
compliance, controls and other risk management.
MUFP lawfully processes the Personal Data of Data Subjects for the aforementioned purposes as:
The Processing is necessary for:
Processing your sensitive personal data may be necessary:
Disclosure of Personal Data to Third Parties
We may disclose your Personal Data to other entities within the Mariana Group, for legitimate business purposes (including providing services to you and operating our Sites), in accordance with applicable law.
In addition, we may disclose your Personal Data to:
Because of the international nature of our business, we may need to transfer your Personal Data within MUFP, and more broadly within the Mariana UFP LLP Group, and to third parties, as noted in the section “Disclosure of personal data to Third Parties” above, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements, including data protection laws of a lower standard to those that apply in the country in which you are located.
Where we transfer your Personal Data to other countries, in accordance with our regulatory requirements:
Personal Data of Data Subjects is stored for a period necessary to meet the purpose for which it was collected. In addition, personal data of data subjects will be stored for a period necessary to meet legislative and regulatory requirements including retention time periods. Even when you cease to do business with us, we must retain some of your personal data in case of queries or claims.
MUFP uses a variety of security technologies and procedures to help protect your personal information from unauthorised access, use or disclosure. MUFP also take steps to ensure that only persons with appropriate authorisation can access your personal information.
You are responsible for ensuring that any Personal Data that you send to us is sent securely.
Under the GDPR, you are afforded a number of rights with regards to your personal data. This includes the right to access, rectification, erasure, and restriction. In addition, you have the right to request for a transferable copy of certain data to be transferred to another entity and you may also withdraw your consent with respect to MUFP processing your personal data, however this will not affect the lawfulness of the processing based on your consent prior to the withdrawal.
Please refer to MUFP’s Terms of Business for more information on the process to exercise your data subject rights and information regarding your right to make an internal or external complaint. If you have any concerns as to how your data is processed, please use the contact details provided below.
Incorporated in the United Kingdom
Company Number: OC363748
LEI: 213800YRA1J9QFBMU217
ICO Number: ZA064796
Incorporated in France
Company Number: 84488027800016
LEI: 213800SS8CICRD55O286
Incorporated in the United Kingdom
Company Number: 09234018
LEI: 213800TL8EKGDL1S8C69
Incorporated in Dubai, United Arab Emirates
Company Number: 2672
LEI: 254900LZPKBBPVV00E63
Incorporated in the United Kingdom
Company Number: OC394718
For any questions regarding the Mariana UFP Privacy Policy please contact:
Mark Thomson – Compliance Officer