Paget-Brown Trust Company Ltd.
Data Privacy Statement

Introduction

The purpose of this notice is to provide you with information on our use of your Personal Data in accordance with the Data Protection Law of the Cayman Islands (the “DPL“). In this document, “we”, “us” and “our” refers to Paget-Brown Trust Company Ltd. (“PBT“) and its or their affiliates and/or delegates. Please take the time to read this notice, which contains important information about the way in which we process personal data. Reference in this Privacy Policy to “Personal Data” means any information that identifies, or could reasonably be used to identify, a living individual, either on its own or together with other information.

What personal data do we collect from you?

As providers of corporate, trust, fund, fiduciary and regulatory services, we may act as the data controller in the provision of some of those services. Where we act as the data controller, we may collect the following personal information which constitutes Personal Data within the meaning of the DPL:

  • Basic information, such as your name, your employer, your profession, title or position and your

relationship to a person or entity;

  • Contact information, such as your physical address, email address and phone/fax number(s);
  • nationality, place of birth, date of birth, tax identification number and documents to verify such data; this may include, where it may arise, sensitive personal data such as any criminal record, your status as a politically exposed person, or any sanction enacted against you;
  • passport number, bank account details, source of funds details and details relating to your investment activity
  • Cookies, web browser type, operating system etc., should you use our website; and
  • Any other information relating to you which you may provide to us.

How is your Personal Data collected?

We may process Personal Data from the following sources:

  • from you directly when you provide details to us via email, telephone, post or in-person;
  • from persons including your professional and other advisors who may provide us with your Personal Data on your behalf;
  • from publicly available sources such as websites, registers and databases.

How and why we may use your Personal Data?

Where PBT collects and processes Personal Data in order to provide our services as the data controller, we may collect, store and use Personal Data for lawful purposes, including, in particular:

  • where this is necessary for the performance of our obligations under Services Agreements with our clients;
  • where this is necessary for compliance with a legal and regulatory obligation to which PBT or its clients are subject (such as compliance with anti-money laundering and FATCA/CRS requirements); and/or
  • where this is necessary for the purposes of our legitimate interests and such interests are not overridden by your interests, fundamental rights or freedoms.
  • Where you have provided consent for PBT to use your Personal Data for any other purpose (for example, marketing purposes),you may withdraw your consent at any time by contacting us at the address under the section ‘Getting in Touch’ in this notice

Should PBT wish to use Personal Data relating to its clients or employees for other specific purposes (including, if applicable, any purpose that requires your consent), we will contact you. All Personal Data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. PBT will comply with our obligations and safeguard your rights under DPL at all times.

Why we may transfer your Personal Data?

In certain circumstances PBT and/or our authorized affiliates or delegates may be legally obliged to share Personal Data with the relevant regulatory authorities such as the Cayman Islands Monetary Authority or the Tax Information Authority. They, in turn, may exchange this information with foreign authorities, including tax authorities. In certain circumstances, Personal Data may be shared with professional and other service providers acting in relation to the services being provided to you.

The global nature of our business as an international corporate services provider may necessitate the transmission of Personal Data outside of the Cayman Islands. These destinations may not have laws that protect your Personal Data to the same degree as the DPL.

What data security measures do we take?

We have installed appropriate technical and physical measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also have procedures in place to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach in accordance with our obligations

How long will we retain your Personal Data? 

We will retain your Personal Data for as long as is necessary for us to fulfil our legal obligations in relation to our duties under the terms of our engagement with our clients. We may retain the information beyond the term of our engagement where we consider this to be necessary and to comply with our legal obligations, in particular, AML/CTF obligations. After this period, we will destroy or otherwise erase your personal data in accordance with our policy and applicable laws and regulations.

What are your legal rights?

In certain circumstances and subject to a range of legal conditions and exemptions the DPL affords you the following rights:

  • Request access and obtain copies of your personal data held by us upon your written request and subject to certain conditions, including our right to verify your identity.
  • Request correction of any incomplete or inaccurate personal data that we hold about you.
  • Request erasure of your personal data where there is no legal basis for us continuing to process it.
  • Object to or request the restriction of the processing of your personal data. You also have the right to object where we are processing your personal data for direct marketing purposes.

 

Getting In Touch

Should you have any queries or wish to discuss your data protection rights with us please contact our Head of Regulatory Services on +1 345 949 5122 or by email at info@PagetBrownTrust.ky.  

If we are unable to resolve any issues you might have with this Privacy Policy, you have the right to make a complaint to the Ombudsman

To make a complaint to the Ombudsman, you can do so by visiting the following URL on their website:

https://ombudsman.ky/make‐a‐complaint