Privacy notice

This Privacy Notice explains how Stonehage Fleming Services (IOM) Limited (“the Company”) collects, uses and discloses your personal data, and your rights in relation to the personal data it holds. This privacy notice concerns our processing of personal data which relates to suppliers of services and goods to us and associated Stonehage Fleming Group Companies.

In this Privacy Notice, “us”, “we” and “our” refers to the Company.

The Company is the data controller of your personal data and is subject to the Data Protection Act 2018 and related instruments. Our Data Protection Officer may be contacted at the following email address: groupdataprotectionofficer@stonehagefleming.com

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 it.

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 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.

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 under data protection legislation at https://inforights.im

If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact our Data Protection Officer using the following:

By post - Stonehage Fleming Services (IOM) Limited, Falcon Cliff, Palace Road, Douglas, Isle of Man, IM2 4LB

By email - groupdataprotectionofficer@stonehagefleming.com

If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner https://inforights.im

We may collect your personal data in a number of ways, for example:

  • From the information you provide to us;
  • When you communicate with us by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
  • From other companies in our Group;
  • From publicly available sources or from third parties to whom you also provide services (for example, where those third parties pass on your details when they recommend you to us).

We may collect the following categories of personal data about you:

  • Your name and your employer or employee names and contact information such as address, email address and telephone number;
  • Details regarding and relating to the services you supply.

We may process personal data because it is necessary for the performance of a contract to which you are a party or to enter into a contract with you. In this respect, we may use your personal data for the following:

  • To provide you with information about us (as relevant for your supply of services to us);
  • To carry out diligence and reference checks on you or your employees, where relevant, before you begin to supply services to us;
  • To perform the contract between us.

In this respect, we may share your personal data with the following:

  • Other suppliers with which we may need to interact;
  • Other companies or entities within our Group;
  • Our data storage providers.

We may also process your personal data because it is necessary for our legitimate interests. In this respect, we may use your personal data for the following:

  • For the administration and management of our business;
  • Seeking advice on our rights and obligations, such as where we require our own legal advice.

In this respect we may share your personal data with the following:

  • Our advisers 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.

We may also process your data for our compliance with a legal obligation which we are under. In this respect, we may use your personal data to meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws. In this respect, we may share your personal data with the following:

  • 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 relevant government agencies where we are required to do so.

We may process your data, provided that you have given your explicit consent at the time you provide your data to us, where you supply your services at our premises and we need to make reasonable adjustments to our working environment to cater for your medical conditions. We may obtain or record your consent in writing. Please note that where you volunteer more sensitive or special category personal data to us for a particular purpose, your provision of that data may itself indicate your consent for us to process it for that purpose.

Please note that if you do not agree to this or you withdraw your consent then we may not be able to make special arrangements to accommodate your condition(s).

We may need to transfer your personal data for the reasons set out elsewhere in this Privacy Notice, to other Group companies located in Switzerland, Israel, Jersey, Liechtenstein, Luxembourg, Guernsey, Malta, the United Kingdom or Canada which are countries which provide the same or a similarly adequate level of protection for your personal data as is provided within the Isle of Man. We may also share your personal data with Group companies located in the United States of America, South Africa, the British Virgin Islands, Monaco, the Cayman Islands and Mauritius which do not have laws which provide the same level of protection to your personal data as provided within the Isle of Man. We will use Standard Contractual Clauses, as a safeguard, when making transfers to these countries or will do so with your explicit consent.

We will retain your personal information for as long as necessary and permitted for legal, regulatory, and legitimate business purposes. After this period, your personal data will be deleted or destroyed

Stonehage Fleming Advisory (IOM) Limited

Stonehage Fleming Pension Services Limited

Stonehage Fleming Trustees Limited

Stonehage Fleming Trustees (IOM No2) Limited

Theseus Trustees (IOM) Limited

Version dated: 22 February 2022