Call Recording & Monitoring Policy

Call Recording Policy

J. Knobel Investor Services Limited

Last updated: June 24, 2025

1. Purpose of the Policy

This policy outlines the procedures and obligations of J. Knobel Investor Services Limited (the "Company") for recording and monitoring telephone conversations and electronic communications in accordance with applicable European and Cyprus legislation, including MiFID II, the Cyprus Investment Services Law, CySEC Circular C194, and the General Data Protection Regulation (GDPR).

2. Scope of Application

This policy applies to:

• All telephone calls and electronic communications between employees of the Company and clients or potential clients
  
• Communications that are intended to result in investment services (e.g., investment advice, reception and transmission of orders)
  
• Communications conducted via:
  • Fixed and mobile telephone lines
    
  • Video conferencing platforms
    
  • Web-based calls (e.g., Zoom, Microsoft Teams, WhatsApp Business — if used for business purposes)

3. Legal Basis for Recording

Call recording is mandated under Article 16(7) of MiFID II and implemented locally via CySEC directives. The recordings are required for:

• Monitoring compliance with applicable regulations
  
• Evidence in case of disputes
  
• Market abuse prevention
  
• Enhancing service quality

Consent is not required under GDPR when processing is based on legal obligation (MiFID II), but transparent disclosure is mandatory.

4. Disclosure and Notification to Clients

Clients and prospects are notified:

• Verbally at the beginning of a call (where feasible)
  
• Through the Company’s Privacy Policy, Website Disclaimer, and Terms & Conditions
  
• In written communications or onboarding documentation

5. Client Rights and Access

In accordance with GDPR, clients may:

• Request access to a copy of a recorded call
  
• Request correction of inaccurate data
  
• Lodge complaints with the Office of the Commissioner for Personal Data Protection (Cyprus)

Access will be granted upon written request, subject to legal and confidentiality constraints.

6. Employee Responsibilities

All staff members must:

• Use only approved and recorded devices/systems when interacting with clients
  
• Notify clients of the recording when required
  
• Avoid using private or unrecorded channels for regulated communications

7. Contact

For questions regarding this policy or to request access to a recorded call, please contact:

📧 dpo@jknobel.com

📞 357 22258790