This Privacy Notice explains how Stonehage Fleming US LLC and Peter Rosenberg & Partners LLC (collectively, “the Company”, “we” or “us”) 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 European Union General Data Protection Regulation when providing services to countries in the European Union, and equivalent privacy rules when providing services if you are in Switzerland or Jersey. The Company is also subject to the United Kingdom General Data Protection Regulation when providing services to you in the United Kingdom.
Our Privacy Officer in the United States of America is Mr. Jeff Hollownicsky. His contact details are: email usprivacyofficer@stonehagefleming.com - tel. +1 215 665 7270.
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.
We may amend this Privacy Notice from time to time, to reflect any changes in the way that we process your personal data, and we will notify you of any material changes to this Privacy Notice. By continuing to use our services, you agree that the terms of any amended Privacy Notice will apply to information and personal data previously collected or collected in the future. 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:
If you receive any services from us whilst resident in any country in the European Economic Area or the United Kingdom then you will also be entitled 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.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
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 using any of the following: ‒
By post - 1700 Market Street, Suite 3010, Philadelphia, PA 19103, United States of America
By email - usprivacyofficer@stonehagefleming.com
By telephone - +1 215 665 7270
We may collect your personal data in a number of ways, for example:
We may collect the following categories of personal data about you, which include:
We may process your personal data because it is necessary for the performance of a contract to deliver the services you have directly or indirectly engaged us for or in order to take steps at your request prior to entering into such a contract or to ensure its performance. We may use third parties or service providers to perform any of the actions or activities allowed under this Privacy Notice.
In this respect, we use your personal data for the following:
In this respect, we may share your personal data with the following:
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:
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 for the following:
In this respect, we may share your personal data with the following:
We also may share personal information with third parties upon your request or with your consent, although we may not be able to accommodate all requests.
In sharing your personal data for the reasons set out elsewhere in this Privacy Notice, we may need to transfer it to other companies located in the United States. The European Union and other countries, for example the United Kingdom, do not regard the United States as having laws which provide an adequate level of protection to your personal data. To provide the required protection we make use of data sharing agreements which offer a common level of protection to your data.
While we take steps to help protect the confidentiality and security of personal data that you provide to us, no method of transmission or storage is perfectly secure. We do not guarantee the security of your personal data. We may retain your personal data for as long as necessary for the purposes for which it was collected (which may be for a period of 10 years or longer after the termination of our relationship with you), 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 or permitted by law.
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.
Version: 6 January 2021