Privacy and Cookies

Privacy notice

This Privacy Notice explains how each of Cavendish Trust Company Limited and its subsidiaries (referred to as "CTCL", "we", "us", "our") use and disclose your personal data, and your rights in relation to the personal data we hold.

CTCL is the data controller of your personal data and is subject to the EU General Data Protection Regulation 2016/679 (the "GDPR") and any locally applicable data protection laws, primarily the Data Protection Act 2002 and subsequent legislation in the Isle of Man.

Definitions

Cavendish Trust Company Limited means CTCL and any subsidiary of CTCL.

Personal data means any information that can identify, directly or indirectly, a living individual.

Controller means the natural or legal person which, alone or jointly with others, determines the purposes and means of the processing of personal data. For the purposes of this notice, CTCL is the Data Controller.

Processing means any operation or set of operations which is performed on personal data.

Your rights

Under the GDPR you have the following rights:

• To obtain access to, and copies of, the personal data that we hold about you
• To require that we cease processing your personal data if the processing is causing you damage or distress
• To require us not to send you marketing communications
• To require us to erase your personal data
• To require us to restrict our data processing activities
• To receive from us the personal data we hold about you in a reasonable format, including for the purpose of transmitting it to another data controller (data portability)
• To require us to correct the personal data we hold about you if it is incorrect

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. You can find out more about your rights at www.inforights.im.

How we collect your data

We collect your personal data in a number of ways, including:

• From the information you provide to us when you meet us
• From information about you provided to us by your company or an intermediary
• When you communicate with us in writing, by telephone, via this website, email or other forms of electronic communication
• When you complete (or we complete on your behalf) client on-boarding, application or other forms
• From other companies affiliated to CTCL
• From your agents, advisers, intermediaries, and custodians of your assets
• From publicly available sources or third parties where we need to conduct background checks

The categories of personal data we collect

• Your name and contact information including home or business address, job title, email address and telephone number
• Biographical information confirming your identity including date of birth, tax identification number, passport or national identity card details, country of domicile and nationality
• Information relating to your financial situation such as income, expenditure, assets and liabilities, sources of wealth and bank account details
• An understanding of your goals and objectives in procuring our services
• Information about your employment, education, family or personal circumstances and interests, where relevant
• Information to assess whether you may represent a politically exposed person or money laundering risk

The basis for processing your personal data

We rely on one or more of the following lawful bases:

(i) Performance of a contract with you

We process your personal data to prepare proposals, provide services as set out in our Engagement Letter and Terms of Business, deal with complaints or feedback, and for any other purpose for which you provide us with your personal data. We may share your data with your agents, advisers and intermediaries, third parties engaged to assist in delivering services, our professional advisers, debt collection agencies where necessary, and our data storage providers.

(ii) Legitimate interests

We process your personal data for marketing, staff training and monitoring, administration and management of our business, and seeking advice on our rights and obligations. We may share your data with our advisers or agents and with third parties considering acquiring all or part of our business.

(iii) Legal obligations

We process your personal data to meet compliance and regulatory obligations including anti-money laundering laws, and as required by tax authorities or any competent court or legal authority. We may share data with our advisers and auditors, third parties who assist with background checks, and relevant regulators or law enforcement agencies where required.

Automated decision making

CTCL does not use any automated decision-making, including profiling, in any of its engagements.

Marketing

We will send you marketing about services we provide which may be of interest to you, including alerts, newsletters and invitations to events. We communicate via post, telephone, email or other digital channels. If you have given consent and wish to withdraw it at any time, please contact our Data Protection Officer.

Transfer and processing of your personal data outside the European Union

When we transfer any part of your personal data outside the EEA or adequate jurisdictions we will take reasonable steps to ensure it is treated as securely as within the EEA, including through binding corporate rules, model contracts, or US/EU privacy shield mechanisms.

Retention of your data

Where we have collected your personal data as required by anti-money laundering legislation, we will retain it for between five and seven years after the termination of our relationship, unless required by another law or court proceedings. Otherwise, we will in most cases retain your personal data for a minimum period of five years after the termination of our contractual or other relationship with you.

How we use cookies

This website creates first-party cookies specific to the host site. All first-party cookies created do not store any personal or sensitive information, or anything that makes you personally identifiable to us. They are used for essential functionality such as security when processing form data, and for analytics which helps us use anonymous visitor data to gain a better understanding of how people use this website.

You may accept or decline cookies using the banner that appears when you first visit this website. You can also control cookies through your browser settings. For more information about how to control cookies, please visit www.aboutcookies.org.

Name	Usage	Description
cav_cookie_consent	Consent management	Records whether you have accepted or declined cookies on this website. Expires after 365 days (accept) or 30 days (decline).
__utma	Google Analytics	Used to determine unique visitors.
__utmb	Google Analytics	Establishes and continues a user session. Expires 30 minutes from set or update.
__utmc	Google Analytics	Google Analytics is a free service offered by Google that generates detailed statistics about website visitors.
__utmv	Google Analytics	Custom tracking information.
__utmz	Google Analytics	Tracks referrals from other websites.

Your right to access your information

Please email CTCL's Data Protection Officer at dpo@cavendishtrust.com if you wish to request a Subject Access Request showing all information we hold about you. This information will be provided within one month of your request.

Governing law and jurisdiction

These terms are governed by and construed in accordance with Isle of Man law. By accessing and using this website you agree that disputes arising in connection with this privacy notice shall be subject to the exclusive jurisdiction of the Isle of Man courts.

You have the right to complain to the ICO if you feel that CTCL has not responded to your requests to solve a problem. Contact details are at www.inforights.im.