The lmperium Trust Company Limited (ITCL) is a regulated Trust Company, based in Guernsey.

When you request a service we will collect some personal information about you, including; your name, address, contact telephone numbers, email address date of birth, your sex, your ethnicity.

We require this information for a number of different reasons including, communicating with you as we provide our service to you, communication on your behalf with third parties, reporting and research purposes and for marketing and other activities.

ITCL has created this privacy statement to comply with the Data Protection (Bailiwick of Guernsey) Law 2017. The statement is for your information and it covers how we collect, use, disclose, transfer and store your personal data.

1. Introduction and General Terms

ITCL is committed to protecting your personal information when you are using our goods and services. We want our services and products to be safe, transparent and reliable. This privacy statement relates to our use of any personal information we collect from you. It also relates to our use of any personal information you provide to us by phone, SMS, email, and letters and other correspondence and in person.

In order to provide you with the full range of ITCL services, we sometimes need to collect information about you. This privacy statement explains following:

  • what personal information we collect about you
  • how we use information collected about you
  • when we use your details to contact you
  • under which circumstances we may disclose your personal details to any third party
  • your choices around what personal information you provide to us.

 

ITCL is committed to safeguarding your personal information. Whenever you provide such information, we are legally obliged to use your information in line with all applicable laws concerning the protection of personal information, including the General Data Protection Regulations 2017. No system of data storage can be completely secure; if you have any concerns or complaints that your personal data held by the ITCL could have been compromised: someone could have discovered your personal details held by us, please contact us immediately. Our contact details are at section 12 of the statement.

2. What information will lTCL collect about me?

When you get in touch with us either via email, a telephone call or when you visit us at our office we will collect some personal information about you. This can consist of information such as your name, email address, postal address, telephone or mobile number, gender, date of birth and ethnicity as well is information collected about the services we provide you.

ITCL will use information provided by you, or a family member, alongside any information available from Publically Available Sources. From time to time we may request a professional background report with regard to your circumstances to provide further information for our client due diligence process.

3. How will the ITCL use the information collected about me?

ITCL will use your personal information for a number of purposes including the following:

  • Ensuring we have accurate information so that we may communicate with you and keep you updated of developments as we provide a service to you.
  • Ensuring that we have consent and that we hold accurate information so that we may contact you at a future date for the purposes of quality control, surveys or other research purposes and for fund raising and marketing activities.
  • Ensuring that we have accurate information for internal reporting, for example, reporting to our director/board or trustees/shareholders, all reporting to other interested stakeholders.

 

4. When will lTCL contact me?

ITCL may contact you in relation to any communication we receive from you or any other parties involved in the service we provide for you.

5. Will I be contacted for marketing purposes?

ITCL will only send you marketing emails or contact you where you have agreed to this by giving us your consent. From time to time we may also contact you and ask your views about the service ITCL has provided to you.

6. Will lTCL share my personal information with anyone else?

We will keep your information within ITCL except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies), where sharing is required to fulfil the contract between us or where you have consented to sharing your information with other parties involved in the service we provide to you, including, for example: Banks, Investment Houses, Lawyers, Accountants and other professionals.

We will use your information within ITCL and will share it outside ITCL when required for the purpose of delivering services to you or where you have requested it via a data portability request, or given your consent. ITCL requires all third parties to comply strictly with its instructions and ITCL requires that they do not use your personal information for their own business purposes and only use your information for reasons associated with the goods or services we provide for you.

7. How long will ITCL keep my personal information?

We will hold your personal information on our systems for as long as is necessary for the purpose of the supply of goods of services and for any legal requirements. It is anticipated that we will hold your personal information for a period of up to ten years; this is a legal requirement which we have to meet.

8. Can I delete my personal information?

You can always ask for your information to be deleted by ITCL. However, please bear in mind that we are required to hold your data for a minimum period of up to ten years for legal reasons.

Deleting the data ITCL holds about you will erase any personal data we have about you and it will mean any data we hold about you after your request that we use in future; will be made anonymous.

9. Can I find out what personal information ITCL holds about me?

Under the general data protection regulations 2017 you have the right to request a copy of the personal information ITCL holds about you and to have any inaccuracies corrected. (We require you to prove your identity with two pieces of approved identification). We have a legal duty to supply, correct or delete personal information about you on our files. Please address requests and questions about this or any other question about this privacy statement to the Data Protection Officer, lmperium Trust, PO Box 635, St Peters House, Le Bordage, St Peter Port GYl lBR.

We will need two copies of forms of identification, which can be:

  • passport
  • driver’s licence
  • birth certificate
  • utility bill (from last three months)
  • current vehicle registration document
  • bank statement (from last three months)

 

10. Changes to ITCL privacy statement

This privacy statement may be updated from time to time so you may wish to check it each time you submit personal data to ITCL. If you do not agree to any changes, please do not continue to use ITCL website or submit your personal data to ITCL. You can also delete your personal data that ITCL holds at any time (subject to any legal reasons we may have to keep some of the data we hold about you).

11. Sharing of your data with others

As part of the service that we provide it may be necessary to share data we hold about you with third parties as set out in section 6.
You also have the right to ask us to share your personal data with anyone you wish. To exercise this right to data portability please write to us, giving full details, using the details provided at section 14 of this statement.

12. Contacting ITCL about this privacy statement

If you have any questions or comments about ITCL privacy statement please contact: The Data Protection Officer, Imperium Trust, PO Box 635, St Peters House, Le Bordage, St Peter Port, Guernsey, GY1 1BR.

Telephone 01481 728380 or email Rhona.Humphreys@imperiumtrust.com

13. Guernsey Data Protection Authority

If you wish to raise any complaint with regard to the manner in which we handle your data, you can do this with the local office of the The Data Protection Authority.

Telephone 01481 742074 or email enquiries@odpa.gg