Privacy Policy

WHAT IS PERSONAL DATA?

Personal data is defined as any information which identifies an individual or from which an individual is identifiable.

What is a data subject, a data processor and a data controller?

· A data subject means an identified or identifiable individual.

· A data controller determines the purposes and means of the processing of personal data. The data controller has decision making power in respect of the processing.

· A data processor processes personal data on behalf of a data controller.

· In certain circumstances, we are the data controller of personal data while on other occasions we act as data processor.

What personal data do we collect, have or compile about you?

Personal data that is typically collected and used by us includes but is not limited to the following:

· Contact details: such as your name, your address(es), your telephone number(s) and email address(es);

· Due diligence and regulatory details: such as your identity and/or passport documentation, proof of address documentation, source of wealth information, bank account, financial and tax information, transactional information on your accounts/dealings, your marital status, your gender, date and place of birth, your employment history, your dependant, your signature, photographs or other visual images of you, telephone conversations with our staff.

· Please note that the personal data set out above is an indicative list only and is not exhaustive.

How do we collect your personal data? We collect personal data that you voluntarily give to us (most of the time, this will be at the time we on-board you as a client) and from information we learn about you during our relationship. We may also

obtain data about you from third parties such as your legal advisors, your accountants and from the public domain such as the internet.

It is important that the personal data we hold about you is accurate and up-to-date. You are kindly requested to inform us of any change in your personal data as relevant.

Purpose of collecting and processing your personal data

We only collect and use your personal data where we have lawful grounds and legitimate business interests and reasons to do so.

We collect and process your personal data:

· To carry out due diligence checks and to perform risk assessments in accordance with the legal obligations to which we are subject;

· To ensure compliance with our legal and regulatory obligations under the applicable anti-money laundering and other applicable laws and regulations;

· As is necessary for the performance of our obligations to you under the agreement to which you are a party;

· To send you legal updates, marketing materials on our products and events and any information which may be of interest to you; and

· For our business purposes, including improving the provision of our services; statistics and analysis and internal management and administrative purposes.

How may we share your data?

We may share your data only when necessary for our legitimate professional and business needs and/or as is required or permitted by law or professional standards. We may share your data with one or more of the following organisations or persons:

· Our affiliates, employees, directors and officers for them to perform their assigned duties;

· Third parties service providers with whom we work to provide you with our products or services and to support our business. Examples include IT service providers, professional advisers, auditors and banks;

· Third parties whenever required or permitted by law, including but not limited to banking, regulatory, taxation, governmental or other investigatory authorities; law enforcement authorities; government authorities and courts, tribunals or other authorities of competent jurisdiction

· Any other party with whom you have consented that we may share your personal data.

For how long do we store your personal data?

We will only hold your personal data for as long as is reasonably necessary for the purposes for which it was obtained.

However, if we are obliged to retain your personal data for a specified period of time pursuant to our regulatory or legal requirements, we shall then retain your personal data for that minimum specified period