Privacy notice

• 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.

• 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.

• 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.

• 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.

• 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.

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.