Privacy Policy

This notice (Privacy Notice) applies to personal information held by Andco as data controllers, as described below. It explains what information we collect about you, how we’ll use that information, who we’ll share it with, the circumstances when we’ll share it and what steps we’ll take to make sure it stays private and secure. It continues to apply even if your agreement with us ends.

This Privacy Notice covers all services you have with us, including the provision of corporate services.

Wherever we’ve said ‘you’ or ‘your’, this means you, any person or agent authorised to act on your behalf whether or not under a power of attorney, and other related people (including authorised signatories, partners, members and trustees).

Wherever we’ve said ‘Company’ or ‘Companies’, this means a company, partnership, foundation or other entity for which Andco provides corporate services where you are a shareholder (directly or indirectly), or trustee, protector, enforcer or beneficiary of a trust which is the beneficial owner or ultimate beneficial owner of the Company.

When we say ‘we’, we mean Andco Trust and Corporate Services Limited which acts as a data controller in respect of your personal data. Unless otherwise stated below, the data controller for the purposes of this notice will be Andco Trust and Corporate Services Limited, a company incorporated in the Isle of Man and having its registered office at First Floor, 18-20 North Quay, Douglas, Isle of Man.

We’ll only collect your information in line with relevant regulations and law. We may collect it from a range of sources and it may relate to any of our services you apply for, currently hold or have held in the past.
Some of it will come directly from you, e.g. when you provide ID to establish a client relationship. We might also get some of it from publicly available sources. The information we collect may include Information that you provide to us, e.g.:

• personal details, e.g. name, previous names, gender, date and place of birth;
• contact details, e.g. address, email address, landline and mobile numbers;
• information concerning your identity e.g. photo ID, passport information, NationalInsurance number, Tax Identification number, National ID card and nationality;
• other information about you that you give us by filling in forms or by communicatingwith us, whether face-to-face, by phone, email, online or otherwise;
• additional information that we receive from external sources that we need forcompliance purposes;
• sales information, e.g. details of the services you receive and your preferences;
• investigations data, e.g. due diligence checks, sanctions and anti-money launderingchecks, external intelligence reports, content and metadata related to relevantexchanges of information between and among individuals, organisations, includingemails, voicemail;
• records of correspondence and other communications between us, including email, andinstant messages;
• information that we need to support our regulatory obligations, e.g. information abouttransaction details, detection of any suspicious and unusual activity and informationabout parties connected to you or these activities;
• information from publicly available sources.

We’ll only use your information where we have a lawful reason for using it. These reasons include where we:

• need to pursue our legitimate interests;
• need to pursue the legitimate best interests of the Company;
• need to process the information to enter into or carry out an agreement we have with you;
• need to process the information to comply with a legal obligation;
• need to establish, exercise or defend our legal rights and obligations.

• deliver our services;
• carry out your instructions;
• manage our relationship with you, including (unless you tell us otherwise) telling youabout products and services we think may be relevant for you;
• investigate and resolve complaints;
• ensure security and business continuity;
• risk management;
• protect our legal rights and comply with our legal obligations;
• correspond with professionals involved in the provision of our services includingaccountants, lawyers, advocates, solicitors, surveyors, valuers, lenders, propertymanagers, insurance brokers and third-party intermediaries;

We may record details of your interactions with us. We may record and keep track of conversations you have with us, including phone calls, face-to-face meetings, letters, emails, instant messages and any other kinds of communication. We may use these recordings to check your instructions to us, assess, analyse and improve our service, train our people, manage risk or to prevent and detect fraud and other crimes. We may also capture additional information about these interactions, e.g. telephone numbers that you call us from and information about the devices or software that you use.

We’ll use your information to meet our compliance obligations, to comply with other laws and regulations, and to share with regulators and other authorities that Andco is subject to. This may include using it to help detect or prevent crime (including terrorism financing, money laundering and other financial crimes). We’ll only do this on the basis that it’s needed to comply with a legal obligation, it’s in our legitimate interests and that of others, or to prevent or detect unlawful acts.

We may use your information to provide you with details about Andco’s services and other relevant information via our newsletter. You can change your mind on how you receive these communications or choose to stop receiving them at any time. To make that change, please contact us by e-mailing the Data Protection Officer at eric@andco.im

If you ask us not to send you newsletters, it may take us a short period of time to update our systems and records to reflect your request, during which time you may continue to receive these messages. Even if you tell us not to send you our newsletter, we’ll continue to use your contact details to provide you with important information, such as changes to your terms and conditions or if we need to tell you something to comply with our regulatory obligations.

We may share your information with others where lawful to do so, including where we or they:

• need to in order to provide you with the services you’ve requested;
• have a public or legal duty to do so, e.g. to assist with detecting and preventing fraud,tax evasion and financial crime;
• need to in connection with regulatory reporting, litigation or asserting or defendinglegal rights and interests;
• have a legitimate business reason for doing so;
• have asked you for your permission to share it, and you’ve agreed.

We may share your information for these purposes with others, including:

• any joint shareholders of a Company, trustees, trust companies, beneficiaries,administrators or executors;
• any accountants, lawyers, solicitors, advocates or barristers acting or proposing to actfor a Company;
• intermediaries, banks, stockbrokers, surveyors, valuers, property managers, insurancebrokers;
• financial institutions, bankers, lenders and holders of security over any property ownedby a Company, tax authorities, trade associations, payment service providers and debtrecovery agents;
• any fund managers who provide asset management services to you or your Companyand any brokers who introduce you to us or deal with us for you;
• any people or companies where required in connection with potential or actualcorporate restructuring, merger, acquisition or takeover, including any transfer orpotential transfer of any of our rights or duties under our agreement with you;
• law enforcement, government, courts, dispute resolution bodies, our regulators,auditors and any party appointed or requested by our regulators to carry outinvestigations or audits of our activities;
• other parties involved in any disputes, including disputed transactions;
• anyone who provides instructions or operates any of your Company, products orservices on your behalf, e.g. Power of Attorney, solicitors, intermediaries, etc;
• anybody else that we’ve been instructed to share your information with by either you,a joint shareholder or anybody else who provides instructions or operates any of yourCompanies on your behalf;

We keep your information in line with legal and regulatory requirements and where we need it for our legitimate purposes.

If we don’t need to retain information, we may destroy, or delete it.

Your information may be transferred to and stored in locations outside of the Isle of Man and the European Economic Area (EEA), including countries that may not have the same level of protection for personal information as the Isle of Man and the EEA do. When we do this, we’ll ensure it has an appropriate level of protection and that the transfer is lawful. We may need to transfer your information in this way to carry out our contract with you, to fulfil a legal obligation, to protect the public interest and / or for our legitimate interests. In some countries the law might compel us to share certain information, e.g. with tax authorities. Even in these cases, we’ll only share your information with people who have the right to see it.

You have a number of rights in relation to the information that we hold about you. These rights include:

• the right to access information we hold about you and to obtain information about howwe process it;
• in some circumstances, the right to withdraw your consent to our processing of yourinformation, which you can do at any time. We may continue to process yourinformation if we have another legitimate reason for doing so;
• in some circumstances, the right to receive certain information you have provided to usin an electronic format and / or request that we transmit it to a third party;
• the right to request that we rectify your information if it’s inaccurate or incomplete;
• in some circumstances, the right to request that we erase your information. We maycontinue to retain your information if we’re entitled or required to retain it;
• the right to object to, and to request that we restrict, our processing of your informationin some circumstances. Again, there may be situations where you object to, or ask usto restrict, our processing of your information, but we’re entitled to continue processingyour information and/or to refuse that request.

You can exercise your rights by contacting us. You also have a right to complain to the data protection regulator in the country where you live or work. For the Isle of Man, this is:

• the Information Commissioner in the Isle of Man www.inforights.im

You’re responsible for making sure the information you give us is accurate and up to date, and you must tell us if anything changes as soon as possible. If you provide information for another person (for example, another Company shareholder, a protector or enforcer or trustee of a trust or a beneficiary under a trust), you’ll need to direct them to this notice and we will assume that you have obtained their consent.

We use a range of measures to keep your information safe and secure, which may include encryption and other forms of security. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards, including obligations to protect any information and applying appropriate measures for the use and transfer of information.

If you’d like further information on anything we’ve said in this Privacy Notice, please contact Eric Jones, Andco’s Data Protection Officer.

This Privacy Notice may be updated from time to time.