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GDPR – Privacy Notice/Statement
Who we areThe Law Trust Limited, 2nd Floor, Quay House, South Quay, Douglas, Isle of Man, IM1 5AR.
Telephone No: +44(0)1624 640900
Information held about youThe types (categories) of information we will hold about you include:
- information establishing your identity (for example, name, residential and work addresses, phone number, email address, date of birth, copies of identification documents) and publicly available information (and may include information relating to your family and associates); and
- where you are a corporate client or other legal entity, details about persons with an interest in you, including shareholders, partners, trustees, settlors, protectors, enforcers, beneficiaries, staff and corporate contacts.
This information is required to be provided under our contractual terms and also to fulfil our statutory and regulatory obligations.
The collection of sensitive (also referenced as “Special Category”) information extends to information about your religion, racial or ethnic origin, political opinions, criminal record, and sexual orientation. It also includes health, genetic and biometric information. Generally, we only collect this type of information if it is necessary to provide you with a specific product or service or where you have consented to that collection. For example, where we have been appointed as a Trustee or where we are in possession of a Power of Attorney.
Where you determine not to provide the data or request us to cease processing your data we may need to cease provision of our services to you.
How we will use information about you
1. to provide the service for which you have contracted with us, which includes:
a. communicating with you about (including changes to) the services you have requested;
b. setting up and administering foundations, partnerships, trusts and companies;
c. providing 3rd parties with your information where we identify a need to contract with the 3rd party in order to deliver the services requested. (e.g. banks, external legal counsel); and
d. our own business purposes (e.g., issuing invoices, recovering a debt, client management, archives, assessing and managing our operations and risks, and bringing or defending any dispute or litigation concerning the services provided to you; and
e. to fulfil legal and/or regulatory and/or financial and/or other reporting obligations, including in relation to Anti Money Laundering and Countering the Financing of Terrorism;
2. to verify your identity and for the purposes of complying with legal and regulatory obligations (e.g. Anti Money Laundering and the Countering the Financing of Terrorism);
We may confirm some of the information that you provide to us with external sources e.g. Regulatory Data Corp (“RDC”) or similar products, open source information (via the internet), public registers or a client that is a company and to which you are connected.
We may also acquire information about you from other organisations to ensure the information is accurate, up to date and to prevent or detect crime. This may include a client to which you are connected e.g. as a director, beneficial owner or officer.
People who email us
Any email sent to us, including any attachments, is checked and monitored for reasons of security and for monitoring compliance with our policy. Email monitoring or blocking software is also used.
People who make a complaint to us
If you make a complaint to us, your contact details, the nature of your complaint and sufficient information to enable us to confirm your identity will be retained on our systems in line with our data retention schedule.
Sharing your information
The information we collect about you will not be transferred to or stored outside the European Economic Area or a jurisdiction with an adequacy decision unless it is to support provision of the service you have requested e.g. suppliers; legal firms; banks etc.
We may only disclose or transfer your information for the purposes set out in this privacy statement to:
- all companies owned or controlled by or under common control with The Law Trust Limited
- our employees, agents and service providers, who are required to maintain the confidentiality of this information;
- companies and organisations that assist us to provide the services for which you have contracted under our Terms of Business;
- your professional advisers (e.g. accountants and lawyers)
- regulatory, police authorities or law enforcement and fraud prevention agencies, where we are compelled or permitted or required to do so by order of a court or governmental or administrative tribunal or by law, regulation or any other legal requirement; or
- any other person where disclosure is made at your request or with your consent (including your advisors or agents).
Protecting and storing your information
The information we collect about you is stored under our control and with our selected archive and data backup service providers.
We have put in place appropriate security procedures plus technical and organisational measures to safeguard your personal information and which guard against unauthorised or unlawful access to, alteration, disclosure or destruction of personal data and against accidental loss or destruction of or damage to personal data. Access to internal data servers is limited to the specialist personnel and is controlled using defined policies.
We will only retain the information gathered for as long as is necessary, having regard to relevant laws and regulations and our data retention policies. Such information may be retained after a matter has been closed, and for client identification purposes in accordance with our data retention policy.
Access to your information and correction
If you would like access some or all of the information we hold about you, please e-mail or write directly to:
The Data Protection Officer, The Law Trust Limited, 2nd Floor, Quay House, South Quay, Douglas, Isle of Man, IM1 5AR
You may ask us to correct, remove or cease processing information if you think it is inaccurate or where you wish us to cease provision of services.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
We may ask for certain personal information when you contact us in order to confirm your identity.
Should a situation arise where you feel the need to complain about how we process and/or retain your data we request that you contact our Data Protection Officer directly so that we may address your concerns.
You also have the right to lodge your complaint with the Isle of Man’s Information Commissioner, whose contact information can be found at: www.inforights.im.