This Privacy Notice sets out how RaEM Advisory Limited (RaEM) deals with your personal data which we collect in the course of you and people and entities connected with you interacting with RaEM. We take privacy and security of your 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.
Visitors to our website should review our Website Privacy Notice at www.raemadvisory.com.
2. Contact details
RaEM Advisory Limited has appointed Robert Surcouf as Data Protection Officer. He can be contacted by email – email@example.com
3. The personal information we process
We may collect various types of personal data about you, including:
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 data relating to claims, court cases and convictions, politically exposed person (PEP) status, personal data available in the public domain and such other information as may be necessary for RaEM to provide its services and to complete its CDD process and discharge its AML/CFT obligations;
2. Your tax status information, which may include your tax residency, tax ID and/or tax status;
3. Your contact information, which may include postal address and e-mail address and your home and mobile telephone numbers;
4. Your family relationships, which may include your marital status, the identity of your spouse and the number of children that you have;
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;
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;
7. We may also collect and process personal data regarding people connected to you, either by way of professional (or other) association or by way of family relationship.
4. Where we obtain your personal information
We collect your personal information from the following sources:
1. personal information which you give to us, including but not limited to:
1. such other forms and documents as we may request that are completed in relation to the administration/management of any of our services;
2. information gathered through client due diligence carried out as part of our compliance with regulatory requirements; or
3. any personal information provided by way of correspondence with us by phone, e-mail or otherwise.
2. personal information we receive from third party sources, such as:
1. entities in which you or someone connected to you has an interest;
2. your legal and/or financial advisors;
3. other financial institutions who hold and process your personal information; and
4. credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements; and
5. 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.
5. Why we collect and process your personal information
Lawful grounds for processing
We may hold and process your personal information on the following lawful grounds:
1. the processing is necessary for our legitimate interests, provided your interests and fundamental rights do not override those interests;
2. the processing is necessary to comply with our contractual duties;
3. the processing is necessary to comply with our legal and regulatory obligations;
4. where we have obtained your consent to processing your personal information for a specific purpose; and
5. on rare occasions, where it is needed in the public interest.
Purpose of processing
Pursuant to above, your personal information may be processed for the purposes set out below (“Purposes”)based on our legitimate interests:
1. facilitating the administration of our business and/or our service providers;
2. communicating with you as necessary in connection with our services;
3. monitoring and recording telephone and electronic communications and transactions for quality, business analysis, training and related purposes in order to improve service delivery; and
4. for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act)
5. disclosing your personal information to any bank or financial institution in providing our services;
6. to enforce or defend our legal and contractual rights or those of third party service providers;
7. to comply with legal or regulatory obligations imposed on us (including but not limited to AML/CDD obligations);
8. 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
9. 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 in relation to tax matters.
6. Sharing personal information
1. We may share your personal information with third parties, including banks, financial institutions or other third party lenders, IT service providers, auditors and legal professionals to facilitate the running of our business.
2. Where we share your information with a third party, we require the recipients of that personal information to put in place adequate measures to protect it
3. Where we transfer your personal information outside the European Economic Area, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. This can be done in a number of different ways, for instance:
4. the country to which we send the personal information may be approved by the European Commission as providing adequate protection for personal data;
5. by utilising a contract based on model contractual clauses which have been approved by the European Commission; or
6. where the recipient is located in the US, it may belong to the EU-US Privacy Shield scheme.
7. In other circumstances, the law may permit us to otherwise transfer your personal information outside the EEA.
8. If you would like further information about the safeguards we have in place to protect your personal information, please contact GDPR@raemadvisory.com.
7. Retention of personal information
1. Your personal information will be retained for as long as required:
2. for the purposes for which the personal information was collected;
3. in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations; and/or
4. as required by data protection laws and any other applicable laws or regulatory requirements.
8. Personal information – Your rights
You have the following rights (which may be exercisable depending on the circumstances) in respect of the personal information about you that we process:
1. the right to access and port personal information;
2. the right to rectify personal information;
3. the right to restrict the use of personal information;
4. the right to request that personal information is erased; and
5. the right to object to processing of personal information.
6. You also have the right to lodge a complaint about the processing of your personal information either with us or with the Office of the Information Commissioner in Jersey (https://oicjersey.org) in connection with RaEM
7. Where we have relied on consent to process your personal information, you have the right to withdraw consent at any time. You also have the right to object to processing on the basis of legitimate interests (although this right is subject to certain exceptions).
8. If you wish to exercise any of the rights set out in this paragraph, please submit a formal written request to the Data Protection Representative. Please refer the locations page for address details. Formal written requests may also be made via email to DSAR@raemadvisory.com. Please note that we shall only respond to email requests where the address corresponds to that which we have on file.
9. Inaccurate or amended information
Please let us know as soon as possible if any of your personal information changes (including your correspondence details) by contacting us at GDPR@raemadvisory.com. Failure to provide accurate information or to update information when it changes may have a detrimental impact upon our ability to provide our services. When receiving updated information we must also comply with all local laws and regulations with respect to anti-money laundering and associated verification and these legal obligations override any rights under GDPR.
10. Communications and Media
People who email us
We monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law. You should be aware that not all emails we send or receive may be protected in transit. Please contact us for further detail should you require it.
Visitors to our website
Our website uses Google Analytics to help analyse how users use the site. The tool uses “cookies,” which are text files placed on your computer, to collect standard Internet log information and visitor behaviour information in an anonymous form. The information generated by the cookie about your use of the website (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the website and to compile statistical reports on website activity for RAEM.
You can opt-out of Performance and Advertising cookies by deleting or blocking these in your browser settings at any time.
If you have any questions about this data protection Privacy Notice or how we handle your personal information or if you would like to make a complaint, please contact the Data Protection Representative either by email (GDPR@raemadvisory.com) or post – RaEM Advisory limited, First Floor Liberation Station, Esplanade, St. Helier, Jersey, JE2 3AS.
12. Changes to our Privacy Notice
We keep our privacy notice under regular review. This privacy notice was last updated on 3 July 2019.
RaEM Advisory Limited