Sharing your confidential information
This notice sets out the basis on which information that an MUFG Affiliate collects, or has previously collected, will be utilised and processed.
Each MUFG Affiliate will treat all information it holds as confidential, unless disclosure is in accordance with this notice or is otherwise permitted.
Basis of using and processing information
Information held by an MUFG Affiliate may be, to the extent permitted by applicable law:
(i) processed, utilised and/or disclosed for any of the following purposes:
(a) purposes related to any transfers of information authorised by the applicable law of your jurisdiction;
(b) activities of the control, audit, finance, legal, compliance and support units of MUFG Affiliates, including risk management, know-your-client (“KYC"), anti-money laundering, sanctions compliance and operations;
(c) compliance with, or directly or indirectly facilitating compliance with, legal and regulatory requirements in any jurisdiction, to the extent permitted by applicable law (see also “Regulatory Requirements" below);
(d) compliance with, or directly or indirectly facilitating compliance with, the requirements in any jurisdiction of any exchange, trading facility, trading system, organised market, clearing house, settlement system, exchange or other service provider to facilitate clearing and settlement (a “Market");
(e) client account relationship management and execution of your client business;
(f) direct marketing of products or services of other MUFG Affiliates, which are solely intended for commercial use by our clients; and
(g) any other purposes we have previously communicated to you in connection with the terms of business or any other agreements;
(ii) shared with or transferred to any MUFG Affiliate and its officers, employees, agents, and professional advisors and entrusted third party services providers, in any jurisdiction, for any of the purposes described at (a) - (g) above; and
(iii) made available, to the extent permitted by applicable law, to Markets, regulatory authorities, regulatory organisations, and governmental or quasi-governmental organisations and judicial authorities in any jurisdiction, when required or requested.
Personal information and data protection
Details on how we process personal information are set out in the privacy notice (“the Privacy Notice") published and updated periodically on the MUFG EMEA website at: www.mufgemea.com/governance/privacy-notice.
When sharing personal information with us, you commit to ensuring individuals who are the data subjects are made aware of the scope of processing described in the Privacy Notice and you have procured any consent of those individuals as may be required under applicable laws.
Notwithstanding anything to the contrary in this notice or in any non-disclosure, confidentiality or other agreement between us, we may disclose information, to the extent permitted by applicable law:
(a) to the extent required or permitted under, or made in accordance with or to facilitate compliance with:
(i) the provisions of applicable laws, rules or regulations which mandate reporting, retention and/or delivery of information (including but not limited to pursuant to anti-money laundering, sanctions screening, market abuse, portfolio reconciliation, dispute resolution, portfolio compression, mandatory trade execution and mandatory clearing requirements);
(ii) any order, rule or directive which mandates reporting, disclosure, retention and/or delivery of transaction and similar information issued by an authority, body or agency in accordance with which we are required or accustomed to act,
(together, the Regulatory Requirements) and
(b) to and between MUFG Affiliates or any persons or entities who provide services to MUFG Affiliates in connection with the Regulatory Requirements.
Disclosures made to comply with Regulatory Requirements could result in anonymous transaction and pricing data becoming available to the public.
In undertaking business with the MUFG Group you consent to the collection, use and disclosure of confidential information held about you by an MUFG Affiliate on the terms and for the purposes set out in this notice.
Except as expressly stated, the contents of this notice will not amend the terms of business or any other agreements which we have with you. For the avoidance of doubt, in addition, nothing in this notice limits the scope of any consent you have separately provided.