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Privacy Statements Collas Crill Corporate Services Limited

1What is the purpose of this document?

1.1This privacy notice describes how Collas Crill Corporate Services Limited (“CCCS”) collects and uses personal information about you in accordance with the applicable data protection legislation.

1.2CCCS recognises the importance of this data and the risks related to its possession of such data. CCCS is committed to protecting the privacy and security of your personal information.

1.3CCCS is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. To comply with data protection legislation and best practice we are required to notify you of the information contained in this privacy notice.

1.4This notice sets out your rights under applicable data protection laws as well as our commitment to you regarding how we treat your data. We may update this notice at any time.

1.5It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

2About CCCS

CCCS is licenced to provide company management services in the Cayman Islands by the Cayman Islands Monetary Authority. CCCS is part of the Collas Crill Group, a major offshore legal and fiduciary services provider made up of a number of different entities. More detail of CCCS and our group is available at www.collascrill.com.

We have appointed an Information Officer to oversee compliance with this privacy notice for CCCS.

If you have any questions about this privacy notice or how we handle your personal information, please contact your CCCS Information Officer, contact details of whom are set out below. You have the right to make a complaint at any time to your local regulator for data protection and privacy issues. Details of the local regulators are also set out below:

2.1Information Officer:     

Regulator: Information Commissioner

3Data protection principles

We will comply with applicable data protection laws. Whilst these obligations differ due to the many jurisdictions CCCS' clients operate in, CCCS has committed to applying the highest standards. This means that the personal information we hold about you must be:

3.1Used lawfully, fairly and in a transparent manner.

3.2Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3.3Relevant to the purposes we have explained to you and limited only to those purposes.

3.4Accurate and kept up to date.

3.5Kept only for so long as is necessary for the purposes explained to you.

3.6Kept securely.

4The kind of information we hold about you

4.1Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

4.2There are "special categories" of more sensitive personal data which require a higher level of protection (as detailed in paragraph 10).

4.3We may collect, store, and use the following categories of personal information about you:

4.3.1Personal contact details such as name (including previous names and known aliases)title, addresses, telephone numbers, and personal email addresses.

4.3.2Date of birth.

4.3.3Gender.

4.3.4Marital status and dependants.

4.3.5Bank account and transactional details, records and tax ID or status information.

4.3.6Information about your employer and employment status.

4.3.7Information about your academic history and professional qualifications.

4.3.8Information about your service requirements and sector of interest.

4.3.9Information about your personal and business assets and information relevant to specific structures, transactions or issues you seek assistance with.

4.3.10Information relating to your place of residence, domicile and nationality.

4.3.11Information related to identification, such as passport/ID card numbers and dates of issue/expiry, proof of residential address copies of identification documentation.

4.4We may also collect, store and use the following "special categories" of more sensitive personal information:

4.4.1Information about criminal convictions, offences, adverse media or sanctions.

4.4.2Information about your direct involvement with politics or affiliation with politically exposed persons (PEPs).

4.4.3Information about your family and personal life relevant to your personal service requirements.

5How is your personal information collected?

5.1We collect personal information about you through your on boarding as a CCCS client, and as a result of and through our ongoing work for you.  We may sometimes collect additional information from third parties including, credit reference agencies or other background check agencies or databases.

5.2We will collect additional personal information in the course of our work for you.

6How we will use information about you

6.1We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

6.1.1Where we need to perform the contract we have entered into with you.

6.1.2Where we need to comply with a legal obligation or regulatory requirement.

6.1.3Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

6.2We may also use your personal information in the following situations, which are likely to be rare:

6.2.1Where we need to protect your interests (or someone else's interests).

6.2.2Where it is needed in the public interest.

7Situations in which we will use your personal information

7.1We need all the categories of information in the list above (see paragraph 4) primarily to allow us to perform our contract with you and to enable us to comply with legal or regulatory obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.

7.2Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

7.3The situations in which we will process your personal information are listed in Schedule 1, together with the purpose or purposes for which we are processing or will process your personal information.

8If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as processing a transaction on your behalf), or we may be prevented from complying with our legal obligations (such as to ensure you are property identified for compliance with anti-money laundering legislation).

9Change of purpose

9.1We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

9.2Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

10How we use sensitive personal information

10.1"Special categories" sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

10.1.1In limited circumstances, with your explicit written consent.

10.1.2Where we need to carry out our legal or regulatory obligations.

10.2Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about you in the course of legitimate business activities with the appropriate safeguards.

11Do we need your consent?

We do not need your consent if we use your personal information in accordance to carry out our legal and regulatory obligations or exercise specific rights under the law. .  In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

12Information about criminal convictions, offences, adverse media or sanctions

12.1We envisage that we will hold information about criminal convictions, offences, adverse media or sanctions where such information is available in the public domain.

12.2Where appropriate, we will collect information about criminal convictions, offences, adverse media or sanctions as part of the client take-on process or we may be notified of such information directly by you in the course of our relationship.

12.3We may only use information relating to criminal convictions, offences, adverse media or sanctions where the law allows us to do so. This will usually be where such processing is necessary to carry out our legal or regulatory obligations.

12.4Less commonly, we may use information relating to criminal convictions, offences, adverse media or sanctions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

12.5We may also process such information about you in the course of legitimate business activities with the appropriate safeguards.

13Automated decision-making

13.1Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

13.1.1Where we have notified you of the decision and given you 21 days to request a reconsideration.

13.1.2Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.

13.1.3In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

13.2If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

13.3You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

13.4We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

14Data sharing

14.1We may have to share your data with third parties, including third-party service providers or other entities in the Collas Crill group which provide support services to CCCS.

14.2We require third parties to respect the security of your data and to treat it in accordance with the law.

14.3We may transfer your personal information outside of the Cayman Islands.

14.4If we do, you can expect an equivalent degree of protection in respect of your personal information.

14.5Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. This may involve us sharing your information with:

14.5.1Third party service providers who help us work with you and operate our business; (if any);

14.5.2Revenue and customs agencies, regulators and other authorities;

14.5.3Financial services compensation schemes;

14.5.4Fraud prevention agencies;

14.5.5Entities working with you or your business’ product or service;

14.5.6Organisations that introduce you to us;

14.5.7Companies that we introduce you to; and

14.5.8Companies you ask us to share your data with.

If the make-up of CCCS changes or such changes are proposed we may share your data with third parties to allow us to sell, merge or transfer aspects of our business or acquire or merge into other businesses. We will only do this if they agree to keep your data to the same standards we have set for holding your data. Following such a change other parties may use your data in line with these standards.

14.6Which third-party service providers process my personal information?

"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. Information technology, finance and compliance related services are provided to CCCS by other entities in the Collas Crill group.

14.7How secure is my information with third-party service providers and other entities in the Collas Crill group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

14.8When might you share my personal information with other entities in the group?

We will share your personal information with other entities in our group, to the extent required in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data, or where we have outsourced certain administrative or management oversight functions of CCCS to another Group entity.

14.9Transferring information outside the EU

By providing your personal information to CCCS you understand it will generally be processed within the Cayman Islands, and that we may from time to time as part of our normal business processes, transfer the personal information about you to the following countries which are outside of the EU.

14.9.1British Virgin Islands;

14.9.2Guernsey;

14.9.3Hong Kong;

14.9.4Jersey;

14.9.5Singapore;

in order to perform our contract with you. There is not an adequacy decision by the European Commission in respect of all of those countries. This means that some countries to which we transfer your data are not deemed to provide an adequate level of protection for your personal information.

However, to ensure that your personal information does receive an adequate level of protection we have put in place binding contract clauses in line with international standards to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the applicable laws on data protection. If you require further information about these protective measures, you can request it from your Local Information Officer.

15Data security

15.1We have put in place measures to protect the security of your information.

15.2Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

15.3We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

15.4We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

16Data retention

16.1We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, regulatory or reporting requirements. Retention periods for your personal information are decided by considering 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. This will vary depending upon the relationship we have with you but in general terms for legal advice relationships we will retain your information for 7 years after the end of our relationship unless we are required to keep it longer for legal reasons.

16.2In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

16.3If you have any questions regarding data retention please speak to your Local Information Officer.

17Marketing

17.1We may use your personal information to let you know about those of our products and services we think may be of interest to you. Before doing so we may use your personal information to better understand what services or products you are likely to need or have use for.

17.2If you ask us to stop using your personal information to market to you, we will do so and you can change this choice at any time.

18Cookies

We use "cookies" on our website, these are small pieces of data that allow us to track which computers visit our website and how. To find out how, please review our cookie policy.

19Rights of access, correction, erasure, and restriction

19.1Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

19.2Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

19.2.1Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

19.2.2Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

19.2.3Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

19.2.4Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.

19.2.5Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

19.2.6Request the transfer of your personal information to another party.

19.3If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact your Local Information Officer in writing.

19.4No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

19.5What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

20Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact your Local Information Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

21Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Schedule

How Collas Crill uses your data

June 2018