This statement is designed to help you understand how your personal data is processed by Greystone Trust Company Limited (“Greystone Trust”)and why.
It applies if you enquire regarding our services, are a person who has a connection to a client of Greystone Trust (ultimate beneficial owner, trustee, settlor, beneficiary,company officer etc.) or you are a supplier of services to Greystone Trust or its clients.
Personal data is data which relates to you when you can be identified from that data or from that data when combined with other information which is in the possession of or is likely to come into the possession of Greystone Trust.
Section One – Applicable to Greystone Trust clients
What personal data is processed and how is it used?
In order to become a client of ours, there is certain information and documentation that we are required to collect in order to comply with our contractual, legal and regulatory responsibilities. This includes information about you such as your name, address etc., some understanding of why you want to do business with us, some information about your wealth profile and a copy of your picture identity and address verification documents. We may collect all of this from you or from a third party such as an intermediary if you are going to be a shareholder, an ultimate beneficial owner, a director, or a party connected to a trust. Some of this information might be used to undertake public source searches and searches against paid-for databases in order that we can fully demonstrate compliance with relevant regulatory requirements.
Our contractual, legal and regulatory responsibilities extend to the automatic exchange of information for taxation purposes and for the purposes of inclusion on any central register on which we are obliged to file information. Whilst a lot of the information that we collect, as set out in the paragraph above, is used for these purposes too, we may also need your tax identification number if we will be required to use it for reporting purposes.
We will use your contact information to send you Terms of Business as updated from time to time and to keep in touch with you. As part of assisting you, we may have meetings or calls with you and take notes to assist with the provision of services to you.
Who can see the information?
Our client file may be selected by our auditors, regulatory body or bankers for review as part of any checks that they are required to carry out in relation to our compliance with laws, regulations or conditions of service. We will ensure, however, that these parties only have access to the data that they are obliged to review.
As noted above, we are legally obliged to exchange certain information with the Income Tax Division and the Companies Registry of the Isle of Man. There may also be instances where we are legally obliged to provide information in other countries where legal entities and arrangements related to you are established and we will ensure that we only provide the data which we are obliged to supply.
If as part of our service to you, we need to engage with professional advisors such as lawyers, accountants or tax advisors, some personal data may be shared with them for the purposes of obtaining their services. We may also have to share personal data with any bank, property or investment advisors, or other asset managers with which we are opening an account or contracting for services. We will ensure, however, that we only share the data that is required.
Some personal data, which is generally client due diligence information and documentation, could be made available to registered agents where your company is incorporated in another jurisdiction than the Isle of Man. We will ensure that appropriate safeguards are in place for any such transfer of data and that we only transfer the data required.
Do we use your data for marketing purposes?
We will not use your data or provide it to any third party to market products or services to you.
Your right to object to processing
In addition to the rights set out in Section Three, an important right that you have is the right to object to processing. This right applies where, after careful consideration, we have decided that is in the legitimate interests of Greystone Trust to process data about you. We process data for our legitimate interests when we use your contact details to keep in touch, when we ask for certain information about your wealth profile to assist with our compliance obligations, when we hold your bank account details in case we need to make a payment to you and where we maintain our internal records.
Section Two – applicable to suppliers
What personal data is processed and how is it used
If you are a supplier, we will hold contact information for you as well as relevant correspondence. We might also hold your bank account details if you are an individual supplier of services to Greystone Trust.
Who can see the information?
Your data will only be visible to those Greystone Trust staff who need to have access to it.
Your right to object to processing
In addition to the rights set out in Section Three, we process data for our legitimate interests when we use it to keep in touch with you, to request your services (where applicable) or to reply to a contact made to us.
Section Three – applicable to everyone
Where is the data stored?
All of the data that we process about you is held securely in the Isle of Man office in paper form and/or electronically.
How long is the data kept for?
We will maintain records and data to comply with our statutory, legal and regulatory responsibilities as well as what we deem to be reasonable practice where there is no record keeping period set down in law or other rules. We will destroy personal data in line with these retention periods and our commencement date for any retention period will normally be the end of our relationship with you.
If you have specific queries in relation to retention periods, please contact Mike.riddell@greystone.im.
Your rights
If you wish to see the data processed about you by Greystone Trust, please contact Mike.riddell@greystone.im.
You have additional rights under Isle of Man data protection legislation and regulation such as the right to rectification of incomplete data and the right of erasure of data.
You have the right to receive the personal data you provide to us in a structured, commonly used and machine readable format and have the right to transmit this data to another controller, without hindrance from us.
If you wish to exercise any of these rights, please contact Mike.riddell@greystone.im.
If you wish to make a complaint about how we have processed your data, please contact Mike.riddell@greystone.im. You can also contact the Information Commissioner on 01624 693260 or by emailing ask@inforights.im
Links
This privacy statement does not cover the links within this website linking to other websites. Greystone Trust encourages you to read the privacy statements on the other website you visit.