Last Updated: March 2019
For general web-browsing of this website, your personal data is not revealed to us, although certain statistical information is available to us via our internet service provider as well as through the use of special tracking technologies. Such information tells us about the pages you are clicking on or the hardware you are using, but not your name, age, address or anything we can use to identify you personally. Provided you cannot be identified, it will not be personal data.
What are cookies?
Cookies are a feature of web browser software that allows web servers to recognize the computer or device used to access a website. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don't have to keep re-entering them whenever you come back to the site or browse from one page to another.
What are the different types of cookies?
A cookie can be classified by its lifespan and the domain to which it belongs.
By lifespan, a cookie is either a:
- session cookie which is erased when the user closes the browser; or persistent cookie which is saved to the hard drive and remains on the user's computer/device for a pre-defined period of time.
As for the domain to which it belongs, cookies are either:
- first-party cookies which are set by the web server of the visited page and share the same domain (i.e. set by us); or third-party cookies stored by a different domain to the visited page's domain.
Our website gives existing clients the facility to use a cookie for the online account facility. This allows you to choose to save your user ID and password on your computer. When you next access the online facility from the same computer, your user ID and password will automatically appear.
We keep the information held in cookies we have set to a minimum and only we, our associate businesses, their authorised third parties or someone who has access to your personal computer can read it. Many web browsers allow you to control the use of most cookies through their browser settings.
Unless you have adjusted your browser setting so that it rejects cookies, our system will issue cookies when you access or use our website. By accessing or using our website you are agreeing to us using cookies. If you refuse to accept cookies by adjusting your browser setting, some or all areas of our website may not function properly or may not be accessible.
What cookies do we use and why?
We list all the cookies we use on this website in the below. They include cookies set by Nexus Fund Distribution via our web developers (first-party cookies), and those set by others (third-party cookies). We use session and persistent cookies on our website. Cookies are also sometimes classified by reference to their purpose.
We use the following cookies for the following purposes:
- Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that allow us to comply with legal obligations.
- Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it, as well as dates and times they visit, or how long they visit. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, and remember your preferences for example, your choice of language or region. Other cookies may be used when you submit data to us through a form such as those found on contact pages, and may be set to remember your user details for future correspondence.
- Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed, as well as time spent on our website, and the websites visited just before and just after our website. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
We will retain and evaluate information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive. The information also helps us to understand which parts of this website are most popular and generally to assess user behaviour and characteristics to measure interest in and use of the various areas of our website. This then allows us to improve our website and the way we market our business.
This information may also be used to help us to improve, administer and diagnose problems with our server and website. The information also helps us monitor traffic on our website so that we can manage our website's capacity and efficiency.
We may allow others to provide analytics services and serve advertisements on our behalf. In addition to the uses of cookies described above, these entities may use other methods, such as the technologies described below, to collect information about your use of our website and other websites and online services.
Pixels tags. Pixel tags (which are also called clear GIFs, web beacons, or pixels), are small pieces of code that can be embedded on websites and emails. Pixels tags may be used to learn how you interact with our website pages and emails, and this information helps us and our partners provide you with a more tailored experience.
Device Identifiers. A device identifier is a unique label can be used to identify a mobile device. Device identifiers may be used to track, analyse and improve the performance of the website and ads delivered.
What data is collected by cookies and other technologies on our website?
This information may include:
- the IP and logical address of the server you are using (but the last digits are anonymised so we cannot identify you). the top level domain name from which you access the internet (for example .ie, .com, etc) the type of browser you are using, the date and time you access our website the internet address linking to our website.
Third party advertisers: We may work with advertisers, and advertising service providers to serve ads that may be relevant to you based on your inferred interests, location or other information collected about you, which may use a cookie or the technologies described below, placed by us or the third party (although we would not share any other information that identifies you with an advertiser) on our website, or on a third party website or online service. The placing of these technologies on your device may enable you to be identified across multiple websites and online services. We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways.
For these to work the following social media sites including;
Facebook, Twitter and Linked-In, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies Google Analytics Cookies
This website uses , a web analytics service provided by Google, Inc. ("Google"). We use Google Analytics to track your preferences and also to identify popular sections of our website. Use of Google Analytics in this way, enables us to adapt the content of our website more specifically to your needs and thereby improve what we can offer to you.
Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.
In particular Google Analytics tells us your IP address (last 3 digits are masked); the number of pages visited; the time and duration of the visit; your location; the website you came from (if any); the type of hardware you use (i.e. whether you are browsing from a desktop or a mobile device); the software used (type of browser); your general interaction with our website; and your search history (if you decide to use the search bar at the top of our page).
As stated above, cookie-related information is not used to identify you personally, and what is compiled is only aggregate data that tells us, for example, what countries we are most popular in, but not that you live in a particular country or your precise location when you visited our website (this is because we have only half the information- we know the country the person is browsing from, but not the name of person who is browsing). In such an example Google will analyse the number of users for us, but the relevant cookies do not reveal their identities.
For further information about the use of these cookies by Google click here.
Other Google Services
We also make use of other technologies offered by Google, such as advertising services. In doing so, we allow Google to place cookies on our website for this purpose. Google uses a variety of domains to set cookies used in their advertising products and it may not be immediately apparent these domains are associated with Google (e.g. such as “gstatic.com” or “doubleclick.net”). For more information about the types of cookies used by Google click here.
What if you don’t agree to us monitoring your use of our website (even if we don’t collect your personal data)? Enabling these cookies is not strictly necessary for our website to work but it will provide you with a better browsing experience. You can delete or block the cookies we set, but if you do that, some features of this website may not work as intended.
Advertisers and business partners that you access on or through our website may also send you cookies. We do not control any cookies outside of our website. If you have any further questions regarding disabling cookies you should consult with your preferred browser’s provider or manufacturer.
In order to implement your objection it may be necessary to install an opt-out cookie on your browser. This cookie will only indicate that you have opted out. It is important to note, that for technical reasons, the opt-out cookie will only affect the browser from which you actively object from. If you delete the cookies in your browser or use a different end device or browser, you will need to opt out again.
To opt out of being tracked by Google Analytics across all websites, Google have developed the Google Analytics opt-out browser add-on. If you would like to opt out of Google Analytics, you have the option of downloading and installing this browser add-on which can be found under the link: http://tools.google.com/dlpage/gaoptout.
Review of this Policy
We need to gather and check certain information before providing services to you. This includes your identity and, in some cases, the identity of certain associated people. We do not have to provide our services to you until we have carried out these checks although we will use reasonable efforts to carry them out promptly. We may freeze your assets or return them to you until we have checked all the information we need, and we will not accept any legal responsibility for these actions.
Last Updated: March 2019
When using the term “processing”, we mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (so practically anything we do to your personal data is processing!).
Who we are and how to contact us
Nexus Fund Distribution is the data controller of any personal data you provide and responsible for this website. Nexus Fund Distribution, part of the Blacktower Financial Management Group of companies. Blacktower Financial Management is regulated and authorised by the Gibraltar Financial Services Commission under Licence No. FSC 00805B.
Nexus Fund Distribution, Suites 21 & 22 Victoria House, 26 Main Street, Gibraltar, Phone: +350 200 42353 Fax: +350 200 42953
What type of information is collected?
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased as a member of the Nexus Fund Distribution network.
- Profile Data includes your username and password to access our client portal, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services, and navigate through the website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share ‘Aggregated Data’ such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
In most cases, we do not collect any ‘Special Categories’ of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, in limited cases, we may need to collect such categories of data and if so will rely on a lawful basis (such as your explicit consent) to ensure that we can lawfully process that data only as may be required as part of an ongoing business relationship you have with us.
How we collect information from you
We collect information about you when you:
- use our website ‘contact us’ form to enquire about products and services
- register to receive one of our newsletters or attend one of our events
- call our office to enquire about our services
- enter into a formal business relationship with Nexus Fund Distribution.
Other than from information you enter on our website or provide on our documentation, we may also collect your personal data from documents you provide to us. For example, we may also ask you to provide evidence of your identity such as asking for a copy of your passport, driving licence, proof of residence or income. We are required to ask for this information to comply with anti-money laundering (AML) legislation such as the Proceeds of Crime Act 2015, to ensure we safeguard against and report any suspicious activity.
Please note that if you communicate with us electronically, including by e-mail, telephone or fax, this communication may be monitored and/or recorded to protect the interests of our business and our customers. This includes for the purposes of maintaining customer/service quality standards, detection of and/or prevention of crime and to ensure that Nexus Fund Distribution IFAs comply with legal obligations.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services or those of a Nexus Fund Distribution IFA).
How we use your personal information
We use personal information about you in connection with the following purposes;
Provision of services and account management
To provide you with the information, products and services that you have requested from us.
- to complete any transaction you are undertaking with us;
- to manage and operate your account with Nexus Fund Distribution, including sending you information relating to your account controlled by Nexus Fund Distribution;
- to meet a legal or regulatory obligation.
- to ensure that content from our site is presented in the most effective manner for you;
- to administer our site and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to notify you about changes to our service;
- as part of our efforts to keep our site safe and secure;
- to provide you with information about other services we offer that are similar to those that you already have or have enquired about;
- to provide you with other marketing material such as our Newsletter.
Where you are an existing client, we will rely on our legitimate interests as the lawful basis for processing your personal information for the purposes of direct marketing. To this end, it may be necessary to process your information so we can directly market in our legitimate interest. In addition, we consider it reasonable for you to expect you may receive marketing material from us in the same methods we normally communicate with you (e.g. via email) and that there is no disproportionate impact to your individual privacy rights in this case.
In this context, “legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us on the above details.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us on the above details.
We do not use automated-decision making methods (including profiling), save that we may risk profile our clients in compliance with applicable anti-money laundering legislation.
How long we keep your information for
Retention periods are determined based on the type of record, the nature of the record and activity and the legal or regulatory requirements that apply to those records. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
However, we may retain your personal data for a longer period of time where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person or where we have a legitimate interest to do so for example, to manage your pension, tax and social security obligations etc.
Your individual rights
You have certain rights under applicable legislation, and in particular under Regulation EU 2016/679 (General Data Protection Regulation or ‘GDPR’). We explain these below. You can find out more about the GDPR and your rights by accessing the European Commission’s website.
Right Information and access
Right to rectification
You have the right to have any inaccurate personal information about you rectified and to have any incomplete personal information about you completed. You may also request that we restrict the processing of that information.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Right to erasure (‘right to be forgotten’)
You have the general right to request the erasure of your personal information in the following circumstances:
- the personal information is no longer necessary for the purpose for which it was collected;
- you withdraw your consent to consent based processing and no other legal justification for processing applies;
- you object to processing for direct marketing purposes;
- we unlawfully processed your personal information; and
- erasure is required to comply with a legal obligation that applies to us.
We will proceed to comply with an erasure request without delay unless continued retention is necessary for:
- Exercising the right of freedom of expression and information;
- Complying with a legal obligation under EU or other applicable law;
- The performance of a task carried out in the public interest;
- Archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, under certain circumstances; and/or
- The establishment, exercise, or defence of legal claims.
Right to restrict processing and right to object to processing
Instead of requesting erasure, you also have the right to right to restrict processing of your personal information where:
- you contest the accuracy of the personal information;
- processing is unlawful, but you do not want us to erase it;
- we no longer need to process your personal information but you need us to retain your information as you need it for the establishment, exercise, or defence of legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
You also have the right to object to processing of your personal information under certain circumstances, such as:
- where the processing is based on your consent and you withdraw that consent;
- where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms; or
- where we are processing your personal data for direct marketing purposes
Exercise of this right may impact the services we can provide and we will explain this to you if you decide to exercise it. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms, and this may allow us to continue to (wholly or partly) process your personal information.
Right to data portability
With respect to automated information which you initially provided consent for us to use, or where the processing is necessary for the performance of a contract to which you are party (or in order to take steps at your request prior to entering into a contract), you have a right to receive the personal information you provided to us in a structured, commonly used and machine-readable format, or ask us to send it to another person.
Right to freedom from automated decision-making
As explained above, we do not use automated decision-making, but where any automated decision-making takes place, you have the right in this case to express your point of view and to contest the decision, as well as request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers.
Right to object to direct marketing (‘opting out’)
You have a choice about whether or not you wish to receive information from us. We will not contact you for marketing purposes unless:
- you have a business relationship with us, and we rely on our legitimate interests as the lawful basis for processing (as described above)
- you have otherwise given your prior consent (such as when you download one of our guides)
You can change your marketing preferences at any time by contacting us on the above details. On each and every marketing communication, we will always provide the option for you to exercise your right to object to the processing of your personal data for marketing purposes (known as ‘opting-out’) by clicking on the ‘unsubscribe’ button on our marketing emails or choosing a similar opt-out option on any forms we use to collect your data. You may also opt-out at any time by contacting us on the below details.
Right to request access
You also have a right to access information we hold about you. You can exercise this right at any time by contacting us on the above details.
We are happy to provide you with details of your personal information that we hold or process. To protect our customers' personal information, we follow strict storage and disclosure procedures, which mean that we will require proof of identity from you prior to disclosing such information. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated
Right to withdraw consent
Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time by contacting us on the above details. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent
Raising a complaint about how we have handled your personal data
If you wish to raise a complaint on how we have handled your personal data, you can contact us as set out above and we will then investigate the matter.
Right to lodge a complaint with a relevant supervisory authority
If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved to your satisfaction, you are entitled to make a complaint to the Data Protection Commissioner under the Data Protection Act, which is presently the Gibraltar Regulatory Authority (GRA). You may contact the GRA on the below details:
You also have the right to lodge a complaint with the supervisory authority in the country of your habitual residence, place of work, or the place where you allege an infringement of one or more of our rights has taken place, if that is based in the EEA.
Sharing your personal information
We may pass your information to our Nexus Fund Distribution network, business partners, administration centres, third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf, or to enable us to obtain a quote for you or provide you with other related services.
These third parties may include:
- Fund managers, insurers, insurance brokers, or credit brokers.
When we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
We may transfer your personal information to a third party as part of a sale of some, or all, of our business and assets or as part of any business restructuring or reorganisation, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.
Transferring your information outside of the European Economic Area
There may be instances where as part of the services offered to you by Nexus Fund Distribution, the information which you provide to us may be transferred to countries outside the European Economic Area (“EEA”). The EEA includes the European Union countries as well as Iceland, Liechtenstein and Norway. Transfers outside of the EEA are sometimes referred to as ‘third country transfers’.
This may happen if any of our Platform providers are located in a ‘third country’ outside of the EEA. If we transfer your information outside of the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Policy. This may require us to take certain additional steps to ensure that appropriate safeguards are in place if that third country is not deemed by the European Commission to offer an adequate level of protection for your privacy rights, which may include use of contractual safeguards to allow you to be able to enforce your rights and ensure these are preserved. In certain circumstances, we may need to ask you for your explicit consent to such third country transfers, and will always do so in writing and giving you full information about why we need your consent and your right to withdraw that consent at any time (together with the consequences of withdrawal).
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see further information on the European Commission’s website: European Commission: EU-US Privacy Shield.
If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.
Keeping your information safe
At Nexus Fund Distribution, we take our responsibility to look after your personal information and privacy seriously. In today’s world, we have all seen a growing trend in cybercrime and security breaches. We have a number of security measures in place to help prevent fraud and cybercrime.
If we become aware that a personal data breach has occurred and is likely to result in a high risk to the rights and freedoms of our clients, business partners or employees, we will inform them without undue delay.
We educate and train our employees on our information security, fraud prevention and privacy obligations annually. Information Security awareness also forms part of our new employee induction program.
We also educate our employees in identifying potential financial crime and internal fraud; any suspicious activity is reported to the Gibraltar Financial Intelligence Unit.
We will always interact with you in a safe, secure and consistent manner
When interacting with you, we will:
- Post information electronically to your email
- Verify who you are when speaking to you on the phone, by asking you security questions.
We will not:
- Ask you for any password over the phone.
- Send you an unsolicited email with a link to our login page asking you to enter your email details
- Ask you for payment or credit card details by email or telephone.
As well as protecting your digital information, Nexus Fund Distribution also protects its offices where personal data may be used and stored. This includes secure disposal of confidential waste and hardware, personal card access and locks on doors and file storage cabinets, with a ‘clear desk’ policy to ensure all information is locked away and protected.
Nexus Fund Distribution uses technical security measures to make sure our systems where we store and use personal information are protected from unauthorised access. Tools such as authentication controls, antivirus, firewalls, malware detection and back-up procedures are used across the business. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We have a business continuity plan.
The key drivers in developing the business continuity plans are;
- To mitigate the risks that could lead to the significant disruption of our services to our clients.
- To provide a recovery plan that supports a timely and full restoration of our services for our clients
Whilst we take appropriate technical and organisational measures to safeguard your personal information, please note that we cannot guarantee the security of any data that you transfer over the internet to us.
- Protecting children's privacy is important to us. For that reason, we do not collect or maintain information on our website from those we actually know are under the age of 16, nor is any part of our website targeted to attract anyone under 16. We request that all visitors to our website who are under 16 not disclose or provide any personal data and discontinue use of our website.
Conflicts of Interest
Nexus Fund Distribution is committed to high standards of integrity in all that we do and promotes a strong culture of compliance.
Nexus Fund Distribution members should avoid any conflict of interest arising, or where conflicts arise, should ensure fair treatment to all its clients by disclosure, internal rules of confidentiality, declining to act, or otherwise.
Nexus Fund Distribution members should take reasonable steps to give clients, in a comprehensible and timely way, any information needed to enable clients to make a balanced and informed decision.
Nexus Fund Distribution members must not claim independence or impartiality if this is not the case. Any limitations to these claims must also be disclosed. Nexus Fund Distribution members must disclose any material interests they have in any investment transaction or any conflicts of interest which arise or alternatively take reasonable steps to ensure that the interests of the client are not adversely affected.
We are committed to high ethical standards and expect the same of all our employees and anyone who joins the Nexus Fund Distribution Network.
We do not allow the following.
- (a) Offering, promising, giving or authorising others to give anything of value, either directly or indirectly, to anyone so that they: improperly arrange or keep business; influence the actions of a foreign official; otherwise gain any improper business advantage.
- (b) receiving or agreeing to receive anything of value that results, or may result, in the improper performance of any activity connected with a business.
- (c) facilitation of payments on our behalf
Gifts and entertainment provided by or to us or our members must be for genuine business purposes only, be reasonable in scale and frequency, and proportionate to the nature of the relationship.
Gifts and entertainment must be declared. If you break this policy, we may dismiss you or end our relationship with. If we make any changes to this policy, we will post them on this page by publishing a new version of this policy.
MAIN CONTACT FOR COMPLAINTS: Compliance Team
We take care to maintain high standards of service. When we become aware of a client concern or unease, we will resolve the matter as quickly as possible and will handle the client’s concern fairly and within a reasonable timescale.
The Compliance Team will coordinate the investigation of the complaint.
Upon receipt of a complaint, we will do all we can to resolve a concern within three business days. If we cannot do this, we will write to the client within five business days to acknowledge the complaint and let them know when we expect to be able to issue a full response.
When acknowledging a complaint, we will address all of the issues raised in the complaint and may request further clarification where necessary from the client.
A full investigation will be carried out using our files, together with any relevant reports from other parties involved. We may write to the client if further information is required. We will keep the client informed of the progress of the complaint investigation by writing to them again after four weeks if the complaint is not resolved by sending a final response letter.
After eight weeks, if a final response letter has not already been sent, we will issue:
- A final response letter detailing the conclusion of our investigation and resolution of the complaint. The final response letter will also confirm that if a client remains dissatisfied with our final response, they may refer their complaint to the Gibraltar Financial Services Commission. (delete or replace with ‘you may want to seek independent legal advice’
- A letter explaining the reasons why we are still not in a position to make a final response and indicating when we expect to be able to provide a final response letter.
In the event that we receive a complaint that is not about us, or our services, and assuming that we can identify the firm to whom the complaint should be addressed, we will take the following action:
- We will forward the complaint to the firm involved and ask them to contact the client directly with their response
- We will enclose a copy of the client’s original complaint letter to that firm
- We will write to the client to explain the above points and will include the contact details of the relevant firm.
A complaint is considered closed when a final response letter is issued.
This website is for Regulated & Professional users only; it is not for general consumption.
Nexus Fund Distribution operates as a Distributor of products and any material contained in this website has been prepared for informational purposes only, and is not a solicitation to take any action based upon it. This website does not contain financial advice and is not a representation that any product described on this website is suitable or appropriate.
Nexus Fund Distribution is an Appointed Representative (or Distributor) of Blacktower Financial Management (International) Limited. Blacktower Financial Management is regulated and authorised by the Gibraltar Financial Services Commission under Licence No. FSC 00805B.
Information contained in this website may be subject to change and we cannot guarantee the validity of any statement or figure after the date of its publication.
Any reference to any product or service which has been or may be provided by Nexus Fund Distribution or any other company does not amount to a promise that such product or service will be available at any time. Changes to or improvements in such products or services may be made at any time without notice.
Nexus Fund Distribution owns the copyright in the content published on this Website except where otherwise indicated by a third party's proprietary notice. Images, trade marks and brands are also protected by other intellectual property laws and may not be reproduced or appropriated in any manner without written permission of their respective owners.