Privacy Policy

SCOPE:

This policy covers information collected in written and electronic form through direct interview by an employee of the company, or information provided in written or electronic form, including but not limited to, websites and branded social media pages operated by the company. This policy also applies to information collected when individuals visit our websites or social media pages.
This policy does not apply to information collected or provided to third parties or entities that are not connected or affiliated to Firstline.
This policy applies to Firstline Securities Limited, its subsidiaries and associate companies.

POLICY EXECUTION:

1. User Consent to this Privacy Policy

By providing information to us in the form described in section 5.1 above (or any other similar form not mentioned but implied by the terms of this document or your business relationship with Firstline) you are consenting to this Privacy Policy and the collection, use, and disclosure of your personal information by Firstline during its normal business operations and in accordance with the terms and conditions of this Privacy Policy.

2. What Information We Collect

Most of the information we collect is provided directly by you to us when you apply for a service or product that we provide. Firstline also collects financial and other information about you from external sources, including, but not limited to, references that you may have provided to us, transactions that you have made with us or using third party services, credit rating reports, and other financial institutions not directly related to, or affiliated to Firstline.

Firstline will ask you to provide information that enables us to provide a better service or to offer you a product or service that we believe suits your individual investment or financial needs.

2.1. Information About You

Firstline collects information essential to the process of providing you with a service, or to comply with the laws of the Republic of Trinidad and Tobago (or any other jurisdiction in which Firstline operates), or to comply with the regulations of the Trinidad and Tobago Securities Exchange Commission.

This information includes, but is not restricted to:

Information gathered to confirm your identity: this includes your name, address, telephone number, email address, marital status, dependents, date of birth, national insurance number, Board of Inland Revenue (BIR) identification numbers, and your bank account details.
Two forms of identification containing a picture: this might include a copy of your passport, your national identification card, or your Driver’s Permit, or any other form of identification that is deemed acceptable by Firstline.
Information in respect of your annual income, outgoings, assets, liabilities and credit history.
Information in respect of past transactions with Firstline and with third parties, including but not restricted to, payment history, balances, account activity, sources and uses of funds.
Information in respect of the beneficial ownership of assets including part ownership and shared ownership with parties connected or unconnected to you.
Information in respect of your health to assess the need for insurance products like key man insurance.
Information specific to business clients, including, but not restricted to, information in respect of business name, business activities, trading addresses and contact details, account information, email addresses, financial information in respect of the business, names of partners, names of directors and key managers.
Information required to understand your needs.
Information required to determine your eligibility and suitability for Firstline’s products and services.
Information required to process applications for our products and services.
Information required to set up and manage services and products provided to you directly or indirectly by Firstline.
Information required to allow Firstline to provide you with an ongoing and efficient service.
Information required to allow Firstline to assess your appetite for risk.
Information required to allow Firstline to evaluate and improve its existing range of products and services.
Information required to allow accounting, auditing, and other internal functions to function.
Information that Firstline is required to keep so that it meets legal and regulatory requirements.
Information required to allow Firstline to manage and assess the risk it is exposed to.
Information to prevent and detect fraud or criminal activities.
Information required for any purpose that Firstline may specifically disclose to you at the time you provide, or we collect information from you.
Information required to allow Firstline to perform specific services for clients, including but not restricted to, the creation of Information Memorandums and Prospectuses.
Information required to allow Firstline to market investments to potential clients.
Information required to allow Firstline to maintain its corporate image through the publication of marketing and promotional documents that detail milestone events relating to Firstline and its interaction with clients.

2.2 Other information

To improve the products and services we offer to clients we collect information from surveys, information in the public domain, other websites and third parties. Firstline collects this information to assist us with understanding the needs and interests of clients and prospective clients, and to provide additional data to assist with the management of the business risks to which the company may be exposed.

2.3. Storing of Information and Restriction of Access to that Information

Firstline stores your information in written form, electronic databases, its Investment Management System, dedicated databases, and email boxes hosted by the company or its service providers. We keep this information for a period dictated by legal requirements, best practice, and our established policy and procedures in respect of document and information retention.

Access to your information is restricted to authorised persons and third parties. This is described in further detail in section 6.4 of this document.

2.4. How we use your information

2.4.1. Our employees and other Firstline companies

Access to your information is strictly restricted to authorised individuals who have a legitimate business purpose for accessing that information. Any unauthorised access to your information by an employee of Firstline is strictly prohibited by our internal policies and procedures.

All employees of Firstline are required to maintain the confidentiality of client data and information. Failure to do so may lead to disciplinary action being taken against that employee, including, but not restricted to, the dismissal of any employee or employees who breach the confidentiality of client data and information.

We use your information internally for the following reasons:

To assess your risk appetite
To provide you with financial products and services that match your risk appetite.
To assess your financial position and determine your suitability for our products and services.
To manage risk within the scope of our Enterprise-Wide Risk Assessment.
To meet legal and regulatory requirements including, where applicable, those of a foreign country.
To prevent or detect fraud or to suppress financial abuse.

2.4.2. Third parties and outside service companies

Firstline may share information with third parties under the following circumstances:

To provide you with the financial products and services requested.
To comply with regulations issued by the Trinidad and Tobago Securities and Exchange Commission or to comply with other legal and regulatory obligations.
To comply with the directives of a court order.
To enforce our terms and conditions, our rights under legal agreements or relevant law, or to comply with our internal policies and procedures.
To address issues of fraud and to suppress financial abuse.
To respond to an emergency.
To protect the property and rights of Firstline or our stakeholders.
To protect the personal safety of employees, clients, customers or third parties on Firstline property.
With your consent.

Firstline may share anonymous information with third parties to help design and deliver new products and services to our clients, or to assist Firstline to respond to market needs.

Firstline does not disclose private health information to third parties.

2.5. Foreign Account Tax Compliance Act

The Foreign Account Tax Compliance Act of 2010 (FATCA) seeks to obtain information on accounts and investments held by US taxpayers in other countries. Firstline is required to:

Report annually to the Board of Inland Revenue, information on clients who are US persons, or foreign entities with substantial US ownership.

Report accounts and investments of clients who fail to provide sufficient information to determine whether they are US persons.

2.6. Providing information access

If you wish to review the information we keep in respect of you, please send a written request to the dedicated officer identified in section 7.1 of this document.

In rare circumstances, there may be instances where access to your information may be restricted in accordance with the laws of the Republic of Trinidad and Tobago (or any other jurisdiction in which we operate). If applicable, we will advise you of the reasons for restricting access subject to any legal or regulatory constraints imposed upon us.

2.7. Keeping your information accurate

Firstline is committed to ensuring that the information it maintains in respect of you is accurate and complete. As the company bases the provision of its products and services on the information it holds, we encourage you to help us keep the information that we hold current. Any changes, or additional information, should be sent to the dedicated officer identified in section 7.1 of this document, or to your normal account representative, or Firstline contact.

2.8. Security of your information

Firstline maintains physical, electronic, and procedural safeguards to protect the confidentiality of the information you provide to us.

Information you send to us electronically may not be secure when it is transmitted to us.

We recommend that you do not use unsecured methods of transmission such as public Wi-Fi connections that do not use authentication or other verified internet connections to communicate sensitive financial and personal information to us.

2.9 Linking to Third Party Websites and Referrals to Third Party Websites

Firstline may provide clients with links to websites, or refer clients to websites that are owned and operated by third parties which are not connected to Firstline. Should you choose to use a link to a third-party website, you will be subject to the owners of that website’s privacy and security policies. Third parties may operate privacy and security policies that are different to those operated by Firstline. In using third-party websites, you should ensure that you are familiar with the terms and conditions of their privacy and security policies before you provide any information to the third-party.

Firstline does not guarantee, and is in no way responsible, for the privacy and security of third-party sites, and is not responsible for the completeness, accuracy, reliability, or appropriateness of any information such third party sites contain, or may be provided to the user in electronic or written form.

2.10. Collecting Information on our Website and the Use of Cookies

When you visit our website, the information that we collect about you depends on how you use our website and may involve the use of cookies.

A cookie is a small text file that is placed on your computer’s hard drive by our website server and which we can later access. Cookies are frequently used on websites, and you can choose if and how your computer accepts them by configuring your preferences and options in the internet browser you use to access the internet.

We use cookies so that we can improve our website and tailor its content to provide a better service to visitors. Our use of cookies has two purposes.

First, we allocate a cookie to your internet browser if you visit our website. This cookie allows us to:

Determine if you have visited our website before.

Identify the pages that you have accessed.

Second, we may use cookies to maintain online security and to provide protection for users who have login privileges on our website.

2.11 Respecting and Responding to Your Concerns in Respect of Privacy

You have the right to refuse or withdraw consent to the collection, use and disclosure of your information, and we will, subject to constraints imposed by law or regulators, respect your decision. If you wish to refuse or withdraw consent, please send your request in writing to the dedicated officer noted in Section 7.1 of this document.

2.12. Your consent and choices

By providing us with information, you acknowledge that you have read and understood the terms of this Privacy Policy, and agree to all the terms and conditions contained herein.

CORPORATE RESPONSIBILITY

3.1. Accountability

At Firstline, we are committed to ensuring that the personal, business, and financial information you provide, and entrust to us, is protected. Our commitment to protect your information is fundamental to our business creed and the way we do business in Trinidad and Tobago.

If you have any questions or concerns in respect of privacy, you may contact us at info@firstlinesecurities.com.

Effective date: June, 2025