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Privacy Policy

EFFECTIVE DATE - 13th June 2021


  • This Privacy Notice describes how we process personal information received during our business. This notice may be amended from time to time and new versions will be published on our website at


  • This Notice is issued by

  • Radstakes is committed to protecting your privacy and personal data. This Privacy Notice describes the personal data that we collect, the purposes for which we use such data, the steps we take to store and protect it and your choices regarding our use of it.


  • Personal data is any information held on a data subject. This includes information such as the subject’s name, address and contact details and may include their IP addresses and on-line identifiers. It may include information on physical, physiological, mental, economic, and social identity factors.

  • A Data Subject is an identifiable living individual to whom personal data relates.

  • Personal data includes information processed or held electronically e.g. on a computer and/or non-electronically e.g. paper records held in a filing system.


  • We collect personal data throughout our relationship with you.

  • We collect the following types of personal data:

  • Basic personal information; including name, e-mail address, contact details;

  • Details of services provided, token or assets received and exchanged

  • The above list is not exhaustive, and Radstakes may also collect and process other data to the extent that this is considered necessary for the provision of our services or our compliance with legislative requirements.


  • Sensitive data is data defined in the Law as such e.g., racial, or ethnic origin, political opinion, religion, trade union membership, health data, genetic or biometric data or criminal records.

  • We will only collect sensitive data for a legitimate reason. Primarily this will be to enable Radstakes to perform and record checks to prevent and detect crime and comply with laws relating to money laundering, fraud, terrorist financing, bribery, corruption, and international sanctions. It may involve investigating and gathering intelligence on suspected financial crime, fraud etc and sharing data with law enforcement and regulatory bodies.


  • We collect and process personal data that you provide to us directly (or indirectly via your advisors) when you initiate contact with us through our website and throughout your relationship with us.

  • We collect and process personal data obtained from third parties such as:

  • Third party partners of Radstakes;

  • Fraud prevention agencies, professional background checking entities, screening tools;

  • Publicly accessible sources such as international sanctions list, electoral registers, company registers, on-line directories, social networks, internet searches etc.

  • Where information on an individual is provided to Radstakes by a third party, we may need to make them aware of how that information was obtained.


  • Cookies are pieces of information that your web browser transfers to your computer’s hard drive for record keeping purposes. They can be used to store information about your preferences on a particular website. Most browsers are initially set to accept cookies, but you can set your browser to refuse them if you want to. 


  • Our use of your personal data will always have a lawful basis. We use and collect personal data on the basis that:

  • It enables us to comply with your intentions/request that we perform a service for you;

  • It is required that we do so to comply with legal or regulatory obligations;

  • It is in our legitimate interests to do so; or

  • You have consented to our use of your personal data.


  • When you or another party provide your details to Radstakes, we may be required to share your data for legal reasons. This may include processing to:

  • Share data with law enforcement, tax authorities and other government and fraud prevention agencies where we have a legal obligation to do so, including reporting suspicious activity and complying with production and other court orders;

  • Delivering mandatory communications to customers or providing updates to terms and conditions of the provision of services;

  • Investigate and resolve complaints;

  • Manage contentious regulatory matters, investigations, and litigation;

  • Perform assessments and analyse customer data for the purposes of managing, improving, and fixing data quality;


  • To manage our risks and determine what services we can offer and the terms of those services;

  • To carry out financial risk assessments and for risk reporting and risk management;

  • To protect our business by preventing financial crime or from being used to facilitate financial crime;

  • To develop, test, monitor and review the performance of services, internal systems and security arrangements offered by Radstakes;

  • To assess the quality of services to clients;

  • To analyse your use of our site and gathering feedback to enable improvement of our site and your experience including development of user experience;

  • To provide you with access to our corporate literature and information about our services;

  • To prevent and detect fraud and abuse


  • To provide services to you, Radstakes may be required to share personal data with third parties.

  • Radstakes may disclose or transfer personal data collected by Radstakes insofar as reasonably necessary for the purposes of providing services or for compliance purposes as well as on the legal basis set out in this Notice.

  • Except as described below, Radstakes will not disclose, transfer, or sell your personal data to any third party without your consent.

  • The following are potential recipients of data:

  • sub-contractors, agents or service providers to Radstakes

  • courts or tribunals;

  • regulators, registrars or other governmental or supervisory bodies with a legal right to the data or where necessary to fulfil Radstake’s legal and/or regulatory obligations; and

  • law enforcement agencies where disclosure is necessary for Radstakes or its subsidiaries to fulfil their legal and/or regulatory obligations.


  • Where Radstakes employs another company or individual to perform any function on its behalf or to provide services to you, that third party will have access to personal data needed to perform their function, but they may not use it for other purposes.

  • Such functions include, administrative, computer, data processing, screening, and compliance services. Such third parties must process the personal data in accordance with this Privacy Notice and applicable laws.

  • Radstakes will seek to enter into an agreement with each third party setting out the respective obligations of each party, to ensure they process personal data with the same level of security and confidentiality as Radstakes and to be reasonably satisfied that the third party has measures in place to protect data against unauthorised or accidental use, access, disclosure, damage loss or destruction.

  • If authorised by you, Radstakes will disclose data to any third party that you request. Radstakes is not responsible for any such third party’s use of your data, which will be governed by their agreement with you.

  • The personal data that Radstakes holds will be used and stored principally in the United Kingdom. When Radstakes discloses data to third parties to satisfy the purposes outlined above, the third parties are generally located within the European Economic Area (EEA).


  • Radstakes will process and store your personal data for the duration of our services to you in accordance with financial services legislation and the data protection legislation in place from time to time. Radstakes will endeavour to delete any personal data where it is not necessary for it to be held. Radstakes will continue to store your personal data as long as necessary to fulfil legal (e.g., anti-money laundering, proceeds of crime and countering the financing of terrorism legislation), regulatory, contractual or statutory obligations, for the establishment, exercise or defence of legal claims and in general where Radstakes has a legitimate interest for doing so.


  • Radstakes regards the lawful and appropriate treatment of your personal data as fundamental to our successful operation and to maintaining confidence and trust between Radstakes and the community. In fulfilling this objective, Radstakes will:

  • Ensure that your personal data is not used for any purposes that is incompatible with this Privacy Notice.

  • Ensure that any processing of your personal data is fair and transparent and sufficient for the uses set out above:

  • Endeavour to keep your personal data up to date;

  • Retain your personal data no longer than necessary;

  • Ensure that our staff are trained to handle personal data appropriately and securely;

  • Implement appropriate technical and organisational measures to:

  • enable inaccuracies to be corrected and minimise the risk of errors;

  • secure personal data appropriately;

  • protect your personal data against unauthorised or unlawful access or processing and against accidental loss or destruction.


  • You have the following rights:

  • Right of access to your information – you have the right to access the personal data that Radstakes holds about you at any time. Please note that Radstakes is not always required to provide details of or copies of all data held and may charge a fee (where permitted by law) to cover reasonable costs of retrieval.

  • Right to correction of your personal data – you have the right to ask Radstakes to correct any incorrect, inaccurate or out of date information.

  • Deletion of your personal data (Right to be forgotten) – you have the right to ask Radstakes to delete your personal data, to the extent that Radstakes has no legal and/or regulatory obligation to retain such personal information.

  • Right to data portability – you have the right to request a copy of the personal data that Radstakes holds about you.

  • Right to object to direct marketing – you have the right to object at any time to the processing of your personal data for direct marketing purposes by Radstakes.

  • Rights relating to the use of automated decision making and profiling systems based on personal data. Radstakes does not currently make decisions by purely automated means, but should we do so, you have the right to object.


  • you have the right to ask Radstakes to restrict processing of your personal data where:

  • You contest the accuracy of the personal data held by Radstakes;

  • The processing is unlawful, but you objected to the deletion of the personal data and requested that the use be restricted instead;

  • Radstakes no longer needs the personal data for the processing purpose, but you require them for legal reasons;

  • You objected to processing and Radstakes is investigating whether there are legitimate grounds to override your objection.


  • If you do not wish to receive email or other mail from Radstakes or for Radstakes to use personal data that we gather, please contact in the first instance. If you contact us in relation to your rights, we will do our best to accommodate your request or objection. You can help us maintain the accuracy of your information by notifying us of any change at the above address. If you have any questions, concerns or complaints with respect to this Privacy Notice, the way Radstakes is handling your data or have any other queries or concerns, please contact us at the address above.

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