Privacy Statement

1What is the purpose of this document?

1.1This privacy notice describes how Collas Crill Group Limited, its affiliated and subsidiary companies and partnerships globally other than Collas Crill Trust Limited and its subsidiaries and Collas Crill Corporate Services Limited (collectively “Collas Crill” or the “Group”) collects and uses personal information about you in accordance with the applicable data protection legislation.

1.2Collas Crill recognises the importance of this data and the risks related to its possession of such data. Collas Crill is committed to protecting the privacy and security of your personal information.

1.3Collas Crill is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. To comply with data protection legislation and best practice we are required to notify you of the information contained in this privacy notice.

1.4This notice sets out your rights under applicable data protection laws as well as our commitment to you regarding how we treat your data. We may update this notice at any time.

1.5It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

2About Collas Crill

2.1Group Information Officer

• Jonathan Keys-Massey
• +44 1481 734276
• Information.Officer@collascrill.com

2.2British Virgin Islands

2.3Cayman

2.4Guernsey

2.5Jersey

2.6London

3Data protection principles

3.1Used lawfully, fairly and in a transparent way.

3.2Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3.3Relevant to the purposes we have told you about and limited only to those purposes.

3.4Accurate and kept up to date.

3.5Kept only as long as necessary for the purposes we have told you about.

3.6Kept securely.

4The kind of information we hold about you

4.1Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

4.2There are "special categories" of more sensitive personal data which require a higher level of protection (as detailed in paragraph 10).

4.3We may collect, store, and use the following categories of personal information about you:

4.3.1Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.

4.3.2Date of birth.

4.3.3Gender.

4.3.4Marital status and dependants.

4.3.5Next of kin and emergency contact information.

4.3.6National Insurance number.

4.3.7Bank account and transactional details, records and tax status information.

4.3.8Information about your legal requirements and sector of interest.

4.3.9Information about your personal and business assets and information relevant to a specific legal issue you seek advice upon.

4.3.10Copies of identification documentation.

4.4We may also collect, store and use the following "special categories" of more sensitive personal information:

4.4.1Information about criminal convictions and offences.

4.4.2Information about your family and personal life relevant to your personal legal advice requirements.

5How is your personal information collected?

5.1We collect personal information about you through your on boarding as a Collas Crill client, and as a result of and through our ongoing work for you. We may sometimes collect additional information from third parties including, credit reference agencies or other background check agencies or databases.

5.2We will collect additional personal information in the course of our work for you.

6How we will use information about you?

6.1We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

6.1.1Where we need to perform the contract we have entered into with you.

6.1.2Where we need to comply with a legal obligation.

6.1.3Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

6.2We may also use your personal information in the following situations, which are likely to be rare:

6.2.1Where we need to protect your interests (or someone else's interests).

6.2.2Where it is needed in the public interest.

7Situations in which we will use your personal information

7.1We need all the categories of information in the list above (see paragraph 4) primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.

7.2Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

7.3The situations in which we will process your personal information are listed in Schedule 1, together with the purpose or purposes for which we are processing or will process your personal information.

8If you fail to provide personal information

9Change of purpose

9.1We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

9.2Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

10How we use sensitive personal information

10.1"Special categories" sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

10.1.1In limited circumstances, with your explicit written consent.

10.1.2Where we need to carry out our legal obligations.

10.2Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about you in the course of legitimate business activities with the appropriate safeguards.

11Do we need your consent?

12Information about criminal convictions

12.1We envisage that we will hold information about criminal convictions.

12.2Where appropriate, we will collect information about criminal convictions as part of the client take-on process or we may be notified of such information directly by you in the course of our relationship.

12.3We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our legal obligations.

12.4Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

12.5We may also process such information about you in the course of legitimate business activities with the appropriate safeguards.

13Automated decision-making

13.1Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

13.1.1Where we have notified you of the decision and given you 21 days to request a reconsideration.

13.1.2Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.

13.1.3In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

13.2If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

13.3You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

13.4We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

14Data sharing

14.1We may have to share your data with third parties, including third-party service providers and other entities in the group.

14.2We require third parties to respect the security of your data and to treat it in accordance with the law.

14.3We may transfer your personal information outside the EU.

14.4If we do, you can expect an equivalent degree of protection in respect of your personal information.

14.5Why might you share my personal information with third parties?

14.5.1Third party service providers who help us work with you and operate our business;

14.5.2Revenue and customs agencies, regulators and other authorities;

14.5.3Financial services compensation schemes;

14.5.4Credit reference agencies;

14.5.5Fraud prevention agencies;

14.5.6Entities working with you or your business’ product or service;

14.5.7Organisations that introduce you to us;

14.5.8Companies that we introduce you to;

14.5.9Market researchers;

14.5.10 Companies you ask us to share your data with; and

14.5.11Credit card companies and direct debit operators.

14.6Which third-party service providers process my personal information?

14.7How secure is my information with third-party service providers and other entities in the Collas Crill group?

14.8When might you share my personal information with other entities in the group?

14.9Transferring information outside the EU

14.9.1British Virgin Islands;

14.9.2Cayman

15Data security

15.1We have put in place measures to protect the security of your information.

15.2Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

15.3We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

15.4We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

16Data retention

16.1We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Retention periods for your personal information are decided by considering the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. This will vary depending upon the relationship we have with you but in general terms for legal advice relationships we will retain your information for 7 years after the end of our relationship unless we are required to keep it longer for legal reasons.

16.2In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

16.3If you have any questions regarding data retention please speak to your Local Information Officer.

17Marketing

17.1We may use your personal information to let you know about those of our products and services we think may be of interest to you. Before doing so we may use your personal information to better understand what services or products you are likely to need or have use for.

17.2If you ask us to stop using your personal information to market to you, we will do so and you can change this choice at any time.

18Cookies

19Rights of access, correction, erasure, and restriction

19.1Your duty to inform us of changes

19.2Your rights in connection with personal information

19.2.1Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

19.2.2Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

19.2.3Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

19.2.4Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

19.2.5Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

19.2.6Request the transfer of your personal information to another party.

19.3If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact your Local Information Officer in writing.

19.4No fee usually required

19.5What we may need from you

20Right to withdraw consent

21Changes to this privacy notice