Privacy Notice

INTRODUCTION

WHO WE ARE

WHAT CATEGORIES OF PERSONAL DATA DO WE COLLECT?

Personal data refers to any information relating to an identified or identifiable individual. It does not include anonymous data. We may collect the following types of personal data:

• Full name (first, maiden, and last)
• Date of birth
• Home address
• Email address / Skype ID
• Telephone / Mobile number
• Nationality
• Passport / ID card / Driver’s licence
• National Insurance Number / Personal Tax Reference
• Tax information (e.g., Tax Identification Number)
• Employment status
• Utility bills or other proof of address
• Bank statements

HOW DO WE COLLECT PERSONAL DATA?

We collect and process personal data received directly from you when:

• You apply for our services
• You enter a contract with us
• You complete a client application form
• You contact us via telephone, email, post, or electronic means

We may also lawfully obtain personal data from third parties such as other service providers, or from public sources, including:

• Registrar of Companies
• Regulatory bodies
• Bankruptcy databases
• Published articles

SOURCES OF INFORMATION

We collect information from:

• Client and customer onboarding forms
• Counterparty questionnaires
• Identification documents (e.g., passports, national ID cards)
• Proof of address (e.g., utility bills)
• Bank statements
• Third-party service providers (e.g., compliance and AML screening platforms)

LAWFUL BASIS FOR PROCESSING PERSONAL DATA

MKUK processes your personal information to fulfil statutory, regulatory, and contractual obligations. We do not collect unnecessary personal data and process your information only as described in this notice. Under GDPR, we rely on the following lawful bases for processing personal data:

• Legal Obligation: To comply with laws and regulations including AML, CTF, tax laws, FATCA, CRS, and obligations from supervisory authorities.
• Contract: To establish, manage, and fulfil our contractual relationship with you.
• Legitimate Interests: Where processing is necessary for our legitimate business interests, provided these are not overridden by your rights and freedoms.

HOW WE USE YOUR PERSONAL DATA

MKUK treats your privacy with the utmost importance and does not sell or share your personal data without your consent, unless required by law.

Your data may be used:

• To meet legal and regulatory obligations
• For business, accounting, and tax purposes
• To fulfil our contractual commitments
• To detect, prevent, and investigate fraud or other illegal activities
• To protect our legal rights and manage regulatory or legal claims
• To perform KYC and AML checks, including automated identity verification

INTERNATIONAL TRANSFERS OF DATA

Personal data may be transferred outside the European Economic Area (EEA) to jurisdictions that may not offer the same level of data protection. In such cases, we ensure:

• Transfers are necessary for our operations
• Your data is protected using appropriate safeguards (e.g., standard contractual clauses approved by the European Commission)

YOUR RIGHTS UNDER GDPR

You have the following rights regarding your personal data:

• Right to access – Request access to your personal data
• Right to rectification – Correct incomplete or inaccurate data
• Right to data portability – Receive your data in a commonly used format and transfer it to another controller
• Right to object – Object to processing based on legitimate or public interest
• Right to restriction – Restrict processing under certain circumstances
• Right to withdraw consent – Withdraw your consent at any time

To exercise your rights, contact us at: compliance@meritkapital.co.uk

We may require verification of your identity to process your request securely.

DATA RETENTION

MKUK retains personal data only as long as necessary. In compliance with legal obligations, we retain your information for a minimum of seven (7) years, after which it is securely destroyed. A strict review and retention policy is in place.

CONSEQUENCES OF NOT PROVIDING YOUR PERSONAL DATA

CHANGES TO THIS PRIVACY NOTICE

We may update this Privacy Notice periodically to reflect changes in our privacy practices or applicable laws. The latest version will always be available on our website: www.mk.com. We encourage you to review it regularly.

LODGING A COMPLAINT

MKUK processes personal data in accordance with this notice and applicable laws. If you are dissatisfied with how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):