Privacy Policy
PRIVACY NOTICE
1. Purpose of this Notice
In the course of operating its businesses Adjure Group processes personal data – including client data – and is accordingly subject to relevant data protection legislation. This Notice describes how we collect and use personal data. Please read the following carefully to understand our practices regarding your personal data and how we process it, and your rights as a data subject in respect of that data.
2. About Adjure Global
Adjure Global (AG) is the trading name of a group of companies operating across several jurisdictions. AG Comprises of the following companies:
Adjure Global Trust Corporation Limited (England and Wales registration 11344601)
AG Services Limited (Guernsey registration 68505)
Adjure Global (Suisse) SA (Switzerland registration C177929)
Adjure Global Charitable Foundation (Guernsey registration 29)
3. Introductory Notes
Guernsey and the UK have implemented primary legislation giving effect to the EU’s General Data Protection Regulation (GDPR) and Guernsey’s Data Protection (Bailiwick of Guernsey) Law, 2017 and the UK’s Data Protection Act 2018 are to all intents and purposes identical. Mauritius’ Data Protection Act 2017 is aligned with GDPR. Switzerland’s Federal Act on Data Protection, 1992 is also being substantially revised to bring it into alignment with GDPR.
Please note, however, that the nature and extent of the rights available to you may vary depending on the identity of the AG entity responsible for processing your personal data and the law to which that entity is subject.
In most cases, it will be clear which entity is responsible for controlling and processing your personal data (for example because your contract is with that entity). Should you have any questions concerning which AG entity has responsibility for the control and processing of your personal data please contact us at dataprotection@adjureglobal.com.
References hereinafter to “we”, “us”, “our” and “ours” should be understood to be a reference to the AG entity responsible for the control and processing of your personal data.
Certain types of Personal Data are defined as special categories and provided with additional protection. This includes racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
4. Data subject types
The manner in which we process your personal data is likely to depend largely upon the nature of our relationship with you, as follows:
4.1 Individuals who are clients or who own or otherwise control clients that are legal persons or legal arrangements
We process the personal data of individuals who are themselves clients and about individuals who own or otherwise control clients that are legal persons (such as corporations) or legal arrangements (such as trusts).
4.1.1 What personal information do we process and how might it be used?
It is our policy to collect only such personal data as is required to enable us to fulfil the responsibilities to which we may be subject pursuant to our contractual obligations to our clients and comply with any applicable laws and regulations governing the conduct of our business. This may mean that the personal data we hold in relation to a data subject may, in some cases, may be limited, while in others may be extensive, including
- full name, principal residential address, telephone number and email address,
- source of wealth and financial / employment / career history,
- nature of data subject’s relationship with the client (where relevant),
- personal bank account details,
- employment status and details of employer (where relevant).
We may, from time to time, use this data to determine whether a data subject might benefit from one or more of the other services that we provide.
4.1.2 What is the source of this personal data?
This data is usually supplied by data subjects themselves but may also be supplied by third parties appropriately authorised to share it with us or obtained from publicly available sources.
4.1.3 How long do we retain this personal data for?
We will retain this personal data for 6 years after the relevant relationship has ceased (or such longer period as might be prescribed in any relevant law or regulation).
4.2 Other individuals whose personal data we obtain in the course of the provision of services to our clients
The services that we provide to our clients sometimes require us to process the personal data of other individuals. For example, where we are appointed as the trustee of a trust, we will need to process personal information concerning the beneficiaries of the trust.
4.2.1 What is the source of this data?
This data may be supplied by our clients or the relevant data subjects themselves (or those they may have authorised to share it with us).
4.2.2 What personal data do we collect and how might it be used?
It is our policy to collect only such personal data as is required to enable us to fulfil the responsibilities to which we may be subject pursuant to our contractual obligations to our clients and comply with any applicable laws and regulations governing the conduct of our business. This may include
- full name, principal residential address, telephone number and email address,
- nature of data subject’s relationship to our client and any correspondent rights and expectations they may have in respect of our client,
- personal circumstances, including financial circumstances.
We will not use this personal data for marketing purposes.
4.2.3 How long do we retain this data for?
We will retain this personal data for 6 years after the relevant relationship has ceased (or such longer period as might be prescribed in any relevant law or regulation).
4.3 Business partners / potential business partners
We process the personal data of business partners or potential business partners.
4.3.1 What is the source of this data?
This information is provided by the data subjects themselves, usually at conferences, networking events and similar fora.
4.3.2 What personal data do we collect and how might it be used?
In the case of such data subjects, we collect such data as might facilitate subsequent and/or ongoing contact with them, which may include
- contact details,
- employer details.
We may use this data to communicate with such data subjects about possible opportunities for collaboration, our range of professional services, in order to share insights or to invite them to events.
4.3.3 How long do we retain this data for?
In such cases, we will retain this personal data for as long as is necessary is considered necessary to fulfil the purposes for which it is collected.
4.4 Our employees
The processing of the personal data of our employees is undertaken pursuant to the terms of that employment and is not described in this notice.
4.5 Recruitment applicants
We process the persona data of those who apply for a job with an AG group entity.
4.5.1 What is the source of this data?
The principal source of this data are the applicants themselves, however we may also collect information from third parties (for example, from referees or recruitment agencies) or use publicly available information.
4.5.2 What personal data do we process and how might it be used?
We process such data as is necessary to evaluate an applicant’s suitability for employment with AG. This may include
- employment history,
- education,
- references, and
- personal contact details.
4.5.3 How long do we retain this data for?
We will retain personal data for as long as is necessary to fulfil the purposes for which it is collected. If an applicant becomes an employee of AG, their personal data will be retained in accordance provisions in the relevant employment contract.
If an applicant does not become an employee of AG, their personal data will no longer be kept, unless the data subject consents for us to do so in order that they might be kept informed of future opportunities for employment with AG.
4.6 Suppliers
We process the personal data of individual who are suppliers of ours or of those who may be individuals with a relevant connection to our suppliers (for example, a relationship manager at a supplier).
4.6.1 What is the source of this data?
This data is sourced from those individuals themselves.
4.6.2 What personal data do we process and how might it be used?
We process the data we need to manage our relationship with those individuals. This may include:
- contact details,
- business activities,
- personal bank account details
4.6.3 How long do we retain this data for?
We will retain that personal data for as long as is necessary to fulfil the purposes for which it is collected. For suppliers, such data will be held for at least as long as we have a business relationship with them.
4.7 Visitors to our website
We collect personal data about those who visit our website.
4.7.1 What is the source of this data?
This data is sourced from those visitors themselves, primarily through written submission from those visitors, although we additionally source rudimentary data via the use of cookies on our website. Further guidance on cookies and their use may be found on this website.
4.7.2 What personal data do we process and how might it be used?
For the most part, such data is limited to the personal contact details of the individual concerned, although, depending on the basis of any written submission by that individual further data may be provided and processed. Unless contact is expressly solicited, this data will not be used for anything other than market research and insight.
4.7.3 How long do we retain this data for?
We will retain that personal data for only so long as is necessary to fulfil the purposes for which it is collected.
5. Data sharing
5.1 Why might we share your personal data with third parties?
We will share your personal data with third parties where we are required by law or regulation, where it is necessary in the provision of services to our clients, for administration purposes or where we have another legitimate reason in doing so.
5.2 Third party service providers
As a matter of contract, we require any third party service providers - including bankers, investment managers, IT providers, professional and advisors - with whom we are obliged to share your personal data process it strictly for purposes to
- take commercially reasonable and appropriate security measures to protect it, and
- process it only for the purposes of the mandate we give them.
5.3 Others
We may also need to share your personal data with a regulator, professional body or an external quality control reviewer, or to otherwise comply with the law.
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. In such circumstances, any onward processing of that data will be strictly monitored and controlled.
6. Transferring personal data outside of the European Economic Area (EEA)
We will not transfer your personal data to a country outside the EEA (the EU plus Norway, Liechtenstein and Iceland) unless
- the country in question has been deemed by the European Commission to provide an adequate level of protection for personal data, or
- appropriate safeguards have been put in place or a specific exception applies.
Guernsey and Switzerland have both for many years continued to be assessed by the European Commission as providing an adequate level of protection. The UK was until recently a member of the EU/EEA and has subsequently been assessed by the EU as providing an adequate level of protection for GDPR transfer purposes. Mauritius is positively seeking adequacy status but currently any transfers of personal data to AG Mauritius require appropriate safeguards or exemptions.
6.1 Appropriate safeguards
AG, as an exporter of personal data in such circumstances, will require the data importer to enter into specified contractual terms requiring inter alia the personal data in question to be processed only for the purposes for which it is shared and controls to be applied such as to guarantee its security.
6.2 Specific exceptions
AG might transfer your personal data to a country outside the EEA.
- on your express consent or direction,
- should it be necessary for the performance of our contract with you or otherwise done in your interests, or
- where it is necessary for the establishment, exercise or defence of legal claims.
7. Data security
We apply commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We 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.
8. Rights to access, correction, erasure and restriction
8.1 Your duty to inform us of changes
It is important that the personal data we hold is accurate and current. Should the personal data that you have supplied to us change, please notify us of any changes of which we need to be made aware by informing your usual AG contact.
8.2 Your rights in connection with personal data
Under certain circumstances, you have the legal right to
- request access to the personal data we hold about you,
- request correction of the personal data that we hold about you,
- request the deletion of your personal data, where there is no good reason for our continuing to process it,
- object to our processing your personal information for direct marketing and certain other purposes,
- request that the processing of your personal data be in some way restricted, or
- request that your personal data be transferred to you or another data controller.
If you want to exercise any of the above rights, please email us at dataprotection@adjureglobal.com.
You will not have to pay a fee to access your personal data (or to exercise any of these other rights) unless your request for access is unfounded or otherwise excessive. Please also be aware that your request may be refused if we believe it to have no legal basis.
9. Right to withdraw consent
Should you have given your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw that consent at any time.
To do so please contact us at dataprotection@adjureglobal.com.
Upon notification of your withdrawal of such consent, we will desist from the processing of your personal data, no unless we have another legitimate basis for doing so in law.
10. Changes to this notice
We will keep this Privacy Notice under regular review. It was last updated in September 2021.
11. Contact us
If you have any questions regarding this notice or if you would like to speak to us about the manner, in which we process your personal data, please email dataprotection@adjureglobal.com or write to us at an appropriate office, the addresses of which are displayed on this website.
12. Complaints
If you feel your data protection rights (or someone else’s) are not being respected by AG, in the first instance please contact AG in writing or email dataprotection@adjureglobal.com, and explain to us which of your rights you want to exercise, where appropriate. Make sure you keep a copy of your letter or email.
If you do not receive a timely response or you are not satisfied with the response from AG you can chose to raise your concerns about the manner in which AG has controlled and/or processed your personal data by contacting the relevant supervisory authority, as follows:
Guernsey
Website – Make a Complaint · ODPA
Office of the Data Protection Authority
St Martin’s House
Le Bordage
St. Peter Port
Guernsey
GY1 1BR
Telephone – +44(0)1481 742074
Email – enquiries@odpa.gg
Switzerland
Office of the Federal Data Protection and Information Commissioner
Feldeggweg 1
CH – 3003 Berne
Switzerland
Telephone - +41(0)58 4624395
Email – info@edoeb.admin.ch
United Kingdom
Website – Your personal information concerns | ICO
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone – +44(0)303 123 1113
Livechat – Live chat - individuals | ICO