This Privacy Notice sets out how Pavilion Fiduciary deals with your personal information which we collect in the course of you and people and entities connected with you interacting with Pavilion Fiduciary or using our website. We take privacy and security of your personal information seriously and will only use such personal information as set out in this Privacy Notice and in ways which are reasonably ancillary to what is set out below.
References to “Pavilion Fiduciary”, "We", "us" are to Pavilion Fiduciary Limited.
References to "you" include all individuals whose personal information we collect, hold and process in the course of operating our businesses and our website.
2. CONACT DETAILS
You can contact the Pavilion Fiduciary Data Protection Officer in relation to data protection and your rights by email email@example.com or in writing to:
The Data Protection Officer
Pavilion Fiduciary Limited
3. EU REPRESENTATIVE
The Pavilion Fiduciary entity processor and controller, which is situated outside of the European Economic Area (EEA), has nominated a Luxembourg entity as its EU representative. Full details are available on request.
4. THE PERSONAL INFORMATION PROCESS
4.1 We may collect various types of personal information about you, including:
4.1.1 Your identification information (which may include your name, ID card and passport numbers, nationality, place and date of birth, gender, photograph and/or IP address and personal information relating to claims, court cases and convictions, politically exposed person (PEP) status, personal information available in the public domain and such other information as may be necessary for Pavilion Fiduciary to provide its services and to complete its client due diligence process and discharge its AML/CFT obligations);
4.1.2 Your tax statusinformation (which may include your tax residency, tax ID and tax status);
4.1.3 Your contact information (which may include postal residential and business addresses, personal and business e-mail address and your home, business and mobile telephone numbers);
4.1.4 Your family relationships (which may include your marital status, the identity of your spouse and the number of children that you have);
4.1.5 Your professional and employment information (which may include your level of education and professional qualifications, your employment, employer’s name and details of directorships and other offices which you may hold); and
4.1.6 Financial information, sources of wealth and your assets (which may include details of your assets, sources of wealth, shareholdings and your beneficial interest in assets, your bank details and your credit history);
4.2 We may also collect and process personal information regarding people connected to you, either by way of professional (or other) association or by way of family relationship
5. WHERE WE OBTAIN YOUR PERSONAL INFORMATION:
5.1 We collect your personal information from the following sources:
5.1.1 personal information which you give to us, including but not limited to:
(a) such other forms and documents as we may request that are completed in relation to the administration/management of any of our services;
(b) information gathered through client due diligence carried out as part of our compliance with regulatory requirements; or
(c) any personal information provided by way of correspondence with us by phone, e-mail or otherwise;
5.1.2 personal information we receive from third party sources, such as:
(a) entities in which you or someone connected to you has an interest;
(b) your legal and/or financial advisors;
(c) other financial institutions who hold and process your personal information; and
(d) credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements; and
5.1.3 personal information received in the course of dealing with advisors, regulators, official authorities and service providers by whom you are employed or engaged or for whom you act.
6. WHY WE COLLECT YOUR PERSONAL INFORMATION:
Lawful grounds for processing:
6.1 We may hold and process your personal information on the following lawful grounds:
6.1.1. the processing is necessary for our legitimate interests, provided your interests and fundamental rights do not override those interests;
6.1.2 the processing is necessary to comply with our contractual duties;
6.1.3 the processing is necessary to comply with our legal and regulatory obligations;
6.1.4 (on exceptional occasions) where we have obtained your consent to processing your personal information for a specific purpose; and
6.1.5 on rare occasions, where it is needed in the public interest.
Purposes of processing
6.2 Pursuant to paragraph 6.1 above, your personal information may be processed for the purposes set out below ("Purposes"). The Purposes based on our legitimate interests are set out in paragraphs 6.2.1 to 6.2.4 inclusive):
6.2.1 facilitating the administration of our business and/or our service providers;
6.2.2 communicating with you as necessary in connection with our services;
6.2.3 monitoring and recording telephone and electronic communications and transactions:
(a) for quality, business analysis, training and related purposes in order to improve service delivery; and
(b) for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act);
6.2.4 disclosing your personal information to any bank or financial institution in providing our services;
6.2.5 to enforce or defend our legal and contractual rights or those of third party service providers;
6.2.6 to comply with a legal or regulatory obligations imposed on us;
6.2.7 collecting, processing, transferring and storing customer due diligence, source of funds information and verification data under applicable anti-money laundering and terrorist financing laws and regulations; and
6.2.8 liaising with or reporting to any regulatory authority (including tax authorities) with whom we are either required to cooperate or report to, or with whom we decide or deem it is appropriate to cooperate.
7. SHARING PERSONAL INFORMATION
7.1 We may share your personal information with third party service providers, including, banks, financial institutions or other third party lenders, IT service providers, auditors and legal professionals to facilitate our business and services which we provide. The third party service providers to whom your personal information may be transferred are based in the following jurisdictions: Jersey
7.2 Where we share your personal information with a third party service provider outside the European Economic Area, we require the recipients of that personal information to put in place adequate measures to protect it, including by entering into appropriate data transfer agreements such as the EU standard contractual clauses. If you would like further information about the safeguards we have in place to protect your personal information, please contact firstname.lastname@example.org
8. RETENTION OF PERSONAL INFORMATION
8.1 Your personal information will be retained for as long as required:
8.1.1 for the purposes for which the personal information was collected;
8.1.2 in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations; and/or
8.1.3 as required by data protection laws and any other applicable laws or regulatory requirements.
9. ACCESS TO AND CONTROL OF PERSONAL INFORMATION
9.1 You have the following rights (some of which may only be exercisable in appropriate circumstances in respect of the personal information about you that we process:
9.1.1 the right to access and port personal information;
9.1.2 the right to rectify personal information;
9.1.3 the right to restrict the use processing of personal information;
9.1.4 the right to request that personal information is erased; and
9.1.5 the right to object to processing of personal information.
9.2 You also have the right to lodge a complaint about the processing of your personal information either with us, with the Office of the Information Commissioner in Jersey (https://oicjersey.org) or the data protection authority in the EU member state of your usual residence or place of work.
9.3 Where we have relied on consent to process your personal information, you have the right to withdraw consent at any time.
9.4 If you wish to exercise any of the rights set out in this paragraph 9, please contact email@example.com
10. INACCURATE OR AMENDED INFORMATION
Please let us know as soon as possible if any of your personal information changes (including your correspondence details). Failure to provide accurate information or to update information when it changes may have a detrimental impact upon our ability to provide services.
11. SOCIAL NETWORKING
The views and opinions of Pavilion Fiduciary Directors and employees published on social networking websites such as, but not limited to; linkedin.com twitter.com and facebook.com do not necessarily reflect those of Pavilion Fiduciary. Social networking website posts are not intended as legal or financial advice and should not be relied on as such.
Reference to any specific commercial products, processes, or services by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement or recommendation by Pavilion Fiduciary, Nor shall any information or statements contained on social networking websites be used for the purposes of advertising, or to imply an endorsement or recommendation.
With respect to any documents available from social networking websites, neither Pavilion Fiduciary nor any of its employees make any warranty, express or implied, including but not limited to the warranties of merchantability and fitness for a particular purpose. Further, neither Pavilion Fiduciary nor any of its employees assume any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product or process disclosed; nor do they represent that its use would not infringe privately owned rights.
The copyright in this site is owned by Pavilion Fiduciary. The pages in this site may be viewed, copied and printed but any copying or printing of the pages or of any part of the pages must include the copyright notice or must otherwise identify Pavilion Fiduciary as the owner of the copyright.
13. YOUR ACCEPTANCE OF THIS POLICY
If you have any questions about this Data Protection Notice or how we handle your personal information (e.g. our retention procedures or the security measures we have in place), or if you would like to make a complaint, please contact firstname.lastname@example.org