This Privacy Notice explains how SF Trust (Liechtenstein) AG (“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:
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:
Service | Company |
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 |
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 in the United States of America |
Insurance services | Stonehage Fleming Insurance Services Limited (Jersey) |
Administration services | Stonehage Fleming Trust Holdings (Jersey) Limited; Stonehage Fleming (Switzerland) SA Stonehage Fleming 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 need to transfer it to other Group companies located in the European Economic Area as well as Jersey, Switzerland or Israel, which are countries which provide the same or a similarly adequate level of protection for your personal data as is provided within Liechtenstein. We may also share your personal data with Group companies located in the United States of America, South Africa and the British Virgin Islands which do not have laws which provide the same level of protection to your personal data as are provided within Liechtenstein. However, these companies are subject to our Group‐wide data sharing arrangements which offer a common level of protection across the Group.
If you wish to receive details regarding the companies within the Group 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 liechtensteinprivacyofficer@stonehagefleming.com
We and other Group companies may collect your personal data in a number of ways, for example:
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We and other group companies may collect the following categories of personal data about you:
All Group companies |
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Art services |
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Insurance services |
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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 |
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Art services | To arrange for the insurance, acquisition, transportation and exhibition of art. |
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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. |
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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: |
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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: |
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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 Kingdom | For 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:
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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. |
Liechtenstein
Privacy Officer: Scott Murphy
By post – Bahnhofstrasse 15, Schaan, FL 9494, Liechtenstein
By email - liechtensteinprivacyofficer@stonehagefleming.com
By telephone - +41 32 723 7013
Switzerland
Data 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
EU Representative: Stonehage Fleming Services Limited
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
EU Representative: Stonehage Fleming Services Limited
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 –One Liberty Place, 1650 Market Place, 26th Floor, Philadelphia PA19103
By email - usprivacyofficer@stonehagefleming.com
By telephone - +1 215 665 7270
EU Representative: Stonehage Fleming Services Limited
Luxembourg
Privacy Officer: Peter Egan
By post ‐ 3A, Val Ste Croix, L-1371 Luxembourg
By email ‐ luxprivacyofficer@stonehagefleming.com
By telephone ‐ +352 2744 7303
Version 4: 22 January 2020