GBM Securities Ltd - Privacy & Cookies Policy

1. Who We Are

GBM Securities Limited (“GBM”, “we”, “our”, or “us”) is authorised and regulated by the Financial Conduct Authority (“FCA”) under Firm Reference Number 5586463.

We are incorporated in England and Wales under company number 08040031 with our registered office at 99 Bishopsgate, London, United Kingdom, EC2M 3XD.

This Privacy & Cookies Policy explains how we collect, use, store, and protect personal data in connection with our business activities, including prime brokerage, execution, and custody services.

For any questions relating to data privacy, please contact us at: compliance@gbmsecurities.com

2. Legal Basis for Processing

Under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, GBM processes personal data only when we have a lawful basis to do so, including:

• Performance of a contract – to provide prime brokerage and related services.
• Compliance with legal obligations – including FCA, HMRC, and AML requirements.
• Legitimate interests – to manage our business operations and improve client service.
• Consent – where required (e.g., marketing communications).

We do not sell personal data to third parties.

3. Information We Collect

We may collect personal data directly or indirectly through the following sources:

• Information you provide when opening an account or engaging with us;
• Intermediaries, brokers, or professional advisers acting on your behalf;
• Other GBM Group companies and appointed representatives;
• Publicly available sources and regulatory databases;
• Credit reference and fraud prevention agencies;
• Trade counterparties and settlement institutions.

Examples of data we collect include:

• Personal identifiers (e.g. name, date of birth, passport/ID details);
• Contact information (e.g. business address, phone number, email);
• Financial and transactional data (e.g. bank details, payment records, trade activity);
• Employment and professional background;
• Regulatory and compliance information (e.g. AML/KYC data, PEP status, sanctions checks);
• Communications records (e.g. emails, call recordings, Bloomberg/Teams chats);
• Information about products and services you use with GBM.

4. How We Use Your Information

We process personal data only where we have a lawful basis to do so under the UK GDPR and the Data Protection Act 2018.

GBM uses your information for the following purposes:

Providing, managing and administering services - To deliver, maintain and operate our prime brokerage, execution, and custody services and to fulfil our contractual obligations to you. Legal basis: Performance of a contract / Legal obligation.

Carrying out anti-money-laundering, due-diligence and sanctions checks - To verify identity, assess suitability and meet our statutory obligations under AML and financial-crime regulations. Legal basis: Legal obligation / Substantial public interest.

Meeting regulatory and legal reporting requirements - To comply with obligations imposed by the FCA, HMRC and other competent authorities. Legal basis: Legal obligation.

Managing client relationships and support - To respond to queries, handle complaints and maintain accurate records of interactions. Legal basis: Legitimate interest (to ensure effective client service).

Monitoring and recording communications - To record calls, emails and messages for regulatory, quality-assurance and training purposes. Legal basis: Legal obligation / Legitimate interest.

Providing information about products and services - To send updates, research or marketing communications that may be relevant to you, in line with your communication preferences. Legal basis: Legitimate interest / Consent (where required).

Preventing and detecting financial crime - To safeguard our systems and clients from fraud, market abuse or unauthorised access. Legal basis: Legal obligation / Legitimate interest.

5. Who We Share Your Information With

We may share your data with:

• Other GBM Group entities involved in providing services;
• Regulators and supervisory authorities (e.g. FCA, HMRC, NCA, ICO);
• Banks, custodians, brokers, and clearing or settlement agents;
• Auditors, legal advisers, and consultants;
• Technology and data service providers (e.g. trade/order management systems, CRM platforms, secure hosting);
• Fraud prevention and credit reference agencies.

All third-party service providers are contractually required to protect your information in accordance with data protection laws.

6. International Data Transfers

Your personal data may be transferred outside the United Kingdom and European Economic Area (EEA), including to jurisdictions such as Japan, the Middle East, or the United States, where some GBM Group operations or partners are located.

When transferring data internationally, GBM ensures appropriate safeguards, including UK Addendum to the EU Standard Contractual Clauses (SCCs) or adequacy decisions recognised by the UK Government.

7. Data Retention

We retain personal data for as long as necessary to:

• Maintain our client relationship;
• Meet FCA recordkeeping obligations for no longer than seven years after the relationship ends;
• Respond to complaints, investigations, or legal requirements.

After this period, data will be securely deleted or anonymised.

8. Your Rights

Under UK data protection law, you have the right to:

• Access your personal data;
• Request rectification or erasure;
• Restrict or object to processing;
• Request data portability;
• Withdraw consent (where processing is based on consent);
• Lodge a complaint with the Information Commissioner’s Office (ICO) at https://ico.org.uk.

Requests should be directed to compliance@gbmsecurities.com

9. Cookies and Website Tracking

We use cookies and similar technologies on this website to:

• enable core site functionality,
• analyse web traffic and usage patterns, and
• enhance your browsing experience.

Cookies are small text files placed on your device that help the website operate efficiently and remember your preferences. You can manage or delete cookies through your browser settings at any time. Some features of our site may not function properly without certain cookies.

When you first visit our site, you will be presented with a banner allowing you to accept or reject non-essential cookies. For full details, please refer to this section, which forms part of GBM’s combined Privacy & Cookies Policy.

10. Updates to This Notice

We may update this Privacy & Cookies Policy periodically. The most recent version will always be available on our website.

If changes materially affect how we process personal data, we will notify you where appropriate.

11. Contact Information

GBM Securities Limited
99 Bishopsgate, London, United Kingdom, EC2M 3XD
Authorised and regulated by the Financial Conduct Authority (FRN 586463)
compliance@gbmsecurities.com