Privacy Notice for Esme Commercial Finance Brokers

Uses of your personal information

Your personal information may be stored and processed in the following ways and for the following purposes:

  • to check your identity and process and manage your appointment as a commercial finance broker including assessing your suitability;
  • to carry out adverse media checks, screening against external databases and sanctions lists and establishing connections to politically exposed persons. This may include information relating to criminal offences obtained from pre-registration screening;
  • for the day-to-day management of your role as a broker (such as processing your registration, interactions with our regulators; statutory and regulatory filings within all jurisdictions where we operate; providing you with advice and support; for inclusion on internal and external websites; and communicating with you);
  • to monitor and record communications and telephone conversations between us and you. We will only undertake monitoring for preventing and detecting possible criminal activity; to ensure compliance with the bank’s internal policies; to comply with local laws and regulations and to check for viruses or other threats to our IT systems. We will comply with all local laws, regulations and internal policies when doing so. Those recordings may be used by us in evidence in the event of a dispute with you or our customer with whom you are associated; and
  • to provide you with the fees to which you are entitled.

We are entitled to use your personal information in these ways because:

  • it is necessary for the performance of our contract with you (for example for the provision of your services and for remuneration);
  • we have legal and regulatory obligations to prevent and detect crime, money laundering, fraud, terrorist financing, bribery and corruption, and to comply with international sanctions;
  • the use of your personal information is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates), in the course of running our business, or to establish, exercise and defend our legal rights; or
  • in relation to processing information relating to criminal convictions or offences, to comply with relevant laws and regulations, to prevent or detect unlawful acts, to exercise or defend our legal rights or in connection with legal proceedings, or where we have obtained your explicit consent.