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Privacy notice

This Privacy Notice explains how Stonehage Fleming SA (“us”, “we””) and other companies in the Stonehage Fleming Group collect, use and disclose your personal data, and your rights in relation to the personal data being held by us and other Group companies.

We may amend this Privacy Notice from time to time, to reflect any changes in the way that we process your personal data. This Privacy Notice supersedes any previous version of this notice with which you may have been provided or of which you have had sight before the date at the end of the last section of this notice as well as anything to the contrary contained in any agreement with us.

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 direct 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 which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
  • To require us to correct the personal data we hold about you if it is incorrect.

The above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. Also where a Group Company is located outside of the European Economic Union not all of these rights may apply.

If you have any questions about how we or any other Group companies use your personal data, or you wish to exercise any of the rights set out above, please contact our Privacy Officer or, where applicable, the Privacy Officer of any other Group company. Contact details are set out in the last section of this Privacy Notice.

We may use other Group companies to provide services and we may share your personal data for the reasons set out elsewhere in this Privacy Notice. The companies in the Group (“other group companies”) which may be involved with delivering services to you are:

ServiceCompany
Investment management, investment advice, treasury and dealing services
Stonehage Fleming Investment Management Limited (United Kingdom), Stonehage Fleming Dealing and Treasury (Jersey) Services Limited, Stonehage Fleming Investment Management (Suisse) AG,
Stonehage Fleming Investment Management (South Africa) (Pty) Limited,

Stonehage Fleming Investment Management (Liechtenstein) AG

Financial services, including Art Management
Stonehage Fleming Financial Services Limited ( United Kingdom),
Stonehage Fleming (Israel) Financial Services Limited,
Stonehage Fleming Financial Services (Pty) Limited (South Africa), Stonehage Fleming Wealth Planning Limited (United Kingdom)
United States tax, legal advice and related services
Stonehage Fleming US LLC,
Peter Rosenberg and Partners LLC,
Stonehage Fleming Law US
Insurance services
Stonehage Fleming Insurance Services Limited (Jersey)
Administration services
Stonehage Fleming Trust Holdings (Jersey) Limited,
SF Trust Protectors (Switzerland) SARL
Alto Trust Limited
Chasseral (Directors) Limited
Fleming Family & Partners Trustee (Suisse) SA
Heritage Trustees SARL
Primafides (Suisse) SA
Fund Administration, Corporate Trustee services
Stonehage Fleming Corporate Services Limited (Jersey),
Stonehage Fleming Corporate Services Luxembourg S.A. (Luxembourg)
United Kingdom tax and legal advice
Stonehage Fleming Law Limited (United Kingdom)

We may share your data as required with other Group companies located in the European Economic Area as well as Jersey, Canada, United Kingdom or Israel, which are countries which provide the same or a similarly adequate level of protection for your personal data as is provided within Switzerland. We may also share your personal data with Group companies located in the United States of America and South Africa which currently do not have laws which provide the same level of protection to your personal data as are provided within Switzerland. However, these companies are subject to our contractual data sharing arrangements which offer a common level of protection across the Group.

We may also share your personal data with other companies that we have engaged to assist us in providing services to you. These companies may be located in jurisdictions which currently do not have laws which provide the same level of protection to your personal data as are provided within Switzerland, such as the British Virgin Islands. However, these companies are subject to contractual data sharing arrangements which offer a level of protection equivalent to those applicable in Switzerland.

If you wish to receive details regarding the companies within the Group or other service providers which we have engaged to assist in delivering services to entities in respect of which you are connected or have an interest and with whom we have shared your information please contact us at swissprivacyofficer@stonehagefleming.com

We and other Group companies may collect your personal data in a number of ways, for example:

  • From the information you provide to us when you meet with us, from an employee or employees of one of our Stonehage Fleming Group (“Group”) companies or from a family member;
  • When you communicate with us or when we communicate with you by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
  • When you or your agent complete or we complete on your behalf client on-boarding or application or other forms;
  • From other companies in our Group;
  • From intermediaries, your agents, advisers and individuals in the organisation with which you are associated;
  • From the trustee(s) of any trust in respect of which you are a settlor or a beneficiary or with which you are otherwise connected;
  • From your agents and advisers, insurance companies, fund managers, investment managers and custodians of your assets;
  • From publicly available sources or from third parties where we need to conduct background checks about you.

We and other group companies may collect the following categories of personal data about you:

All Group companies
  • Your name, date of birth, passport or national identity card details;
  • Country of birth, domicile and citizenship;
  • Contact information such as residential or business address, email address and telephone number;
  • Biometric data such as CCTV images when you visit our offices;
  • Gender, marital status;
  • Information about your employment, education, family, personal circumstances and interests;
  • Information relating to your tax affairs including your tax status and tax identification number;
  • Information, some of which is collected daily, to assess whether you may represent a money laundering, terrorist financing or reputational risk to the Group. This includes whether you are a Politically Exposed Person, are involved in a high risk business, have been arrested, charged or convicted of a crime, are on a sanctions list or expose us to tax, litigation, bribery or corruption risk.
  • Information relating to you and your financial situation such as your industry and marketing segment, the services we offer which may be of interest, your net worth, income, expenditure, assets and liabilities, sources of wealth and your bank account details;
  • Information about your knowledge and experience in the corporate or investment field;
  • Information regarding your goals and objectives in connection with your wealth;
  • With your consent, information concerning your health where relevant to services provided.

Art services

  • Details of your art collection

Insurance services

  • Where you have provided your written consent, information concerning your health where you seek assistance in obtaining life insurance or medical cover;
  • Information relating to risks and exposures which may include details of your assets and liabilities.

United States Companies

We do not knowingly request or collect personal data from any person under 16 years of age without prior verifiable parental consent. If you believe that your child under the age of 16 has provided personal data to us without prior verifiable parental consent, please email usprivacyofficer@stonehagefleming.com so that we can take steps to delete the personal data that she or he has provided as required in accordance with applicable law.

We may process your personal data because it is necessary for the performance of a contract to deliver the services you have engaged us for or in order to take steps at your request prior to entering into a contract.

Our other Group companies may also process your personal data where it is necessary for the performance of a contract to deliver the services we have engaged them for or in order to take steps at your or our request prior to entering into a contract.

We and other group companies use your personal data for the following:We and other group companies may share your personal data with the following:
This and other Group Companies
  • To prepare preliminary information or a proposal for you regarding the services we offer;
  • To provide you with the services as set out in our terms of engagement with you or as otherwise agreed with you from time to time;
  • To deal with any complaints or feedback you may have;
  • To book transport from and to our offices when you are visiting us;
  • For any other purpose for which you provide us with your personal data.
  • Your advisers or agents or employees of firms with which you are associated;
  • Companies, partnerships, other entities or the trustees of trusts, and the directors and/or employees of such companies, partnerships, other entities or trustees of trusts, in respect of which fiduciary and/or administrative services are provided, and in respect of which you are connected or have an interest.
  • Other third parties such as banks, intermediaries, insurance companies, fund managers, investment managers or administrators;
  • Registered agents;
  • Our advisers where it is necessary for us to obtain their advice or assistance;
  • Companies within our Group;
  • Payment processors where we are making payments on your behalf;
  • Transport companies and travel agents;
  • Our data storage providers.

Art services

To arrange for the insurance, acquisition, transportation and exhibition of art.

  • Insurance brokers where we are instructed to arrange insurance;
  • Museums, galleries and auctioneers where you wish art to be exhibited;
  • Storage facilities where you wish art to be stored.

Corporate finance

To provide you with corporate finance and/or direct investment opportunities or as otherwise agreed with you from time to time.

Potential counterparties and their advisers in relation to our corporate finance or direct investment opportunity services.

Stonehage Fleming Law Limited

To provide you with legal services.

  • Third party service providers who we may engage on your behalf, for example, e-disclosure service providers and/or forensic data investigators;
  • Advisers or agents where it is necessary for us to obtain their advice or assistance, for example, foreign legal advisers and/or counsel or other specialists;
  • The Office of the Public Guardian;
  • Relevant tax authorities.

We and our other group companies may also process your personal data because it is necessary for our legitimate interests.

We and other group companies use your personal data for the following:We and other group companies may share your personal data with the following:
  • To run, grow and develop our business;
  • To ensure a safe environment for our employees and visitors, including website visitors;
  • To provide client services;
  • To conduct market research and carry out business development activities;
  • To train our staff or monitor their performance;
  • For the administration and management of our business including carrying out internal group administrative functions and recovering money you owe to us;
  • To seek advice and guidance on our rights and obligations, such as where we require our own legal advice;
  • To make disclosures to external service providers and any regulatory authorities outside of the country where any structure includes an entity incorporated outside Jersey;
  • To mitigate the risks we face.
  • Our advisers, agents, settlors or protectors of trusts where it is necessary for us to obtain their advice or assistance;
  • With third parties and their advisers where those third parties are acquiring, or considering acquiring all or part of our business;
  • Any regulatory authority or service provider;
  • Our advisers where it is necessary for us to obtain their advice or assistance;
  • Our auditors where it is necessary as part of their auditing functions;
  • With third parties who assist us in conducting background checks;
  • With relevant regulators or law enforcement agencies if we are required to do so.

If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your personal interests or fundamental rights and freedoms which require protection.

We and our other group companies may also process your data for our compliance with a legal obligation which we and they are under.

We and other group companies use your personal data for the following:We and other group companies may share your personal data with the following:
  • To meet our compliance and regulatory obligations, such as compliance with anti‐ money laundering and countering terrorist financing regulations, tax reporting and beneficial ownership reporting requirements.
  • Our advisers where it is necessary for us to obtain their advice or assistance;
  • Our auditors where it is necessary as part of their auditing functions;
  • With third parties who assist us in conducting background checks about you, such as whether you are on sanctions lists;
  • With relevant regulators, tax authorities and law enforcement agencies where we are required to do so.

We may retain your personal data for as long as necessary for the purposes for which it was collected, in order to provide you with services, to carry out our legitimate business interests, to meet our regulatory and legal obligations, and where otherwise required by law. We and other Group companies retain your personal data as follows:

United KingdomFor a period of seven years after the termination of our relationship with you in case any claims arise out of the provision of our services to you. However:
  1. Where we have collected personal data as required by anti-money laundering legislation, we may retain your personal data for five years after the termination of our relationship, unless we are required to retain this information by another law or for the purposes of court proceedings.
  2. Where we have provided advice relating to a pension transfer, pension conversion, pension opt-out or free- standing additional voluntary contribution, we will keep your personal data relevant to this indefinitely as we are required to do so by the Financial Conduct Authority.

Other jurisdictions

The company retains your personal data for a maximum period of 10 years after the termination of our relationship with you in order to meet our regulatory and legal obligations. Where we act as trustees or directors we retain indefinitely certain records that demonstrate how effectively the entities have been managed.

Switzerland

Privacy Officer: Scott Murphy
By post: Rue Du Puits-Godet 12, POBox 763, 2002 Neuchatel, Switzerland
By email: swissprivacyofficer@stonehagefleming.com
By telephone: +41 32 723 7013

Jersey

Privacy Officer: Paul Le Bihan
By post: No 2 The Forum Grenville Street, St Helier Jersey, JE1 4HH Channel Islands
By email: jerseyprivacyofficer@stonehagefleming.com
By telephone: +44 1534 823 109

United Kingdom

Data Protection Officer: Cesare Milani
By post: 15 Suffolk Street, London SW1Y 4HG
By email: ukdataprotectionofficer@stonehagefleming.com
By telephone: +44 (0) 207 087 0136

United States

Privacy Officer: Jeff Hollownicsky
By post: 1700 Market Street, Suite 3010, Philadelphia PA19103
By email: usprivacyofficer@stonehagefleming.com
By telephone: +1 215 665 7270

Luxembourg

Data Privacy Officer: Peter Egan
By post: 3A, Val Ste Croix, L-1371 Luxembourg
By email: luxprivacyofficer@stonehagefleming.com
By telephone: +352 2744 7303

Liechtenstein

Privacy Officer: Thomas Stejskal
By post: Landstrasse 123, 9495 Triesen, Liechtenstein
By email: liechtensteinprivacyofficer@stonehagefleming.com
By telephone: +423 399 02 53

South Africa

Information Officer: Johann Louw
By post: 54 Glenhove Road, Melrose, Johannesburg, 2196, South Africa, or, First Floor, North Block, Waterway House, 3 Dock Road, V&A Waterfront, Cape Town, 8001, South Africa
By email: sainformationofficer@stonehagefleming.com
By telephone: +27 21 446 2132

APPOINTED REPRESENTATIVES

Our appointed representative in the European Union is Sturdon Holdings Luxembourg SARL. Our Data Privacy Officer in Luxembourg is Mr Peter Egan. His contact details are: email - luxprivacyofficer@stonehagefleming.com tel. +352 2744 7303.

Our appointed representative in the United Kingdom is Stonehage Fleming Services Limited. Our Data Protection Officer in the United Kingdom is Mr Cesare Milani. His contact details are: email - ukdataprotectionofficer@stonehagefleming.com tel. +44 207 087 0136.

Version: 26 April 2021