This Privacy Notice explains how Stonehage Fleming Investment Management (Liechtenstein) AG (“the Company”) collects, uses and discloses your personal data, and your rights in relation to the personal data it holds for the purposes of the provision of its services.
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 and Privacy Regulation that came into force on 1 January 2019 and Regulation (EU) 2016/679, also known as the General Data Protection Regulation. Our Privacy Officer is Mr. Thomas Stejskal. His contact details are: email - firstname.lastname@example.org - tel. +423 399 02 53.
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 - email@example.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 - firstname.lastname@example.org - tel. +44 207 087 0136.
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 had sight of before the date stated below as well as anything to the contrary contained in any agreement with us.
You have the following rights:
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://www.datenschutzstelle.li/
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 Privacy Officer.
We may collect your personal data in a number of ways, for example:
We may collect the following categories of personal data about you:
We may process your personal data because it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
We may also process your personal data because it is necessary for our legitimate interests.
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 may also process your data for our compliance with a legal obligation which we are under.
In sharing your personal data for the reasons set out elsewhere in this Privacy Notice, we may need to transfer it to other Group companies located in Switzerland, Israel, Jersey, Luxembourg, Guernsey, Malta, the Isle of Man, the United Kingdom or Canada, which are countries which provide the same or a similarly adequate level of protection for your personal data as provided within Liechtenstein. We may also share your personal data with Group companies located in the United States of America, South Africa, the British Virgin Islands, Bahamas, Cayman Islands, Monaco and Mauritius, which do not provide the same level of protection to your personal data as provided within Liechtenstein. We will use Standard Contractual Clauses, as a safeguard, when making transfers to these countries or will do so with your explicit consent.
We may also share your personal data with other companies or service providers 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 provided within Liechtenstein. Where we share your personal data with a company or service provider in a non-adequate jurisdiction we will do this using either a contractual data sharing arrangement, another available safeguard or with your explicit consent.
If you wish to receive details regarding all of the companies or service providers which we have engaged to assist in delivering services to you or 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 email@example.com
We retain your personal data for a period of 10 years after the termination of our relationship with you in order to meet our regulatory and legal obligations. However, we may retain your personal data for a longer period where necessary to protect against legal claims, or where we are required by law or regulations to do so.
Version: 9 June 2022