Privacy Policy

This data privacy statement is issued by Stonewell Limited (“SL”), an Isle of Man company (105457C).

If you are a client of SL or a staff member you will have received a separate privacy statement. This privacy statement is, therefore, appropriate for the following:

• People who have a connection to our clients (including but not limited to client company directors, trustees, authorised persons, beneficiaries of trusts and other relevant individuals).
• People who have a connection to the SL (including but not limited to suppliers, professional advisors, intermediaries, regulators and bankers).
• People who seek to become clients of SL.

This statement is designed to help you understand how your personal data is processed by the SL and why.

What is personal data?

Personal data is data which relates to you when you can be identified from that data or from that data when combined with other information which is in the possession of or is likely to come into the possession of SL. The definition of personal data includes any expression of opinion about you and any indication of the intentions of the SL or any other person in respect of you.

What personal data is processed and how is it used?

If you are a person who has a connection to one of our clients, there is certain information and documentation that we are required to collect in order to comply with our legal and regulatory responsibilities. This includes information about you like your name and address as well as possibly a copy of your picture identity document and address verification document. Some of this information might be used to undertake public source searches and searches against paid for databases in order that we can fully demonstrate compliance with relevant regulatory requirements.

We will use your contact information to keep in touch with you if we need to. As part of that, we may have meetings or calls with you and take notes to assist with the provision of services to you. We may also hold your bank account details in the event that we need to make a payment to you or to demonstrate compliance with Source of Funds regulatory requirements.

If you are a person who has a connection to SL, we will hold contact information for you as well as relevant correspondence. We might also hold your bank account details if you are an individual supplier of services to SL.

If you are a person who has contacted us via letter, email, telephone or in person, we will use the information provided by you to make contact with you in response to your request.

Where is the data stored?

All of the data that we process about you is held by SL in paper form and/or electronically.

Who can see the information?

If you are a person who has a connection to one of our clients, you should be aware that our client file may be selected by our auditors, regulatory body or bankers for review as part of any checks that they are required to carry out in relation to our compliance with laws, regulations or conditions of service. We will ensure, however, that these parties only have access to the data that they are obliged to review.

If you are a beneficiary of a trust, we may be legally obliged to exchange certain information with the tax authorities of applicable country. There may be other instances where we are legally obliged to file information with registries in other countries and we will ensure that you are informed about any implications for you.

If as part of our service to our client, we need to engage with professional advisers such as lawyers, accountants or tax advisors, some personal data may be shared with them for the purposes of obtaining the advice. We may also have to share personal data with any bank or investment house with which we are opening an account. We will ensure, however, that we only share the data that we need to, and we will conduct appropriate due diligence in advance of sharing the data.

Some personal data, which is generally customer due diligence information and documentation, could be made available to registered agents where a company is incorporated. We will ensure that appropriate safeguards are in place for any such transfer of data and that we only transfer the data required.

If you are a person who has a connection to SL or a person who has contacted us, your data will only be visible to those staff who need to have access to it.

How long is the data kept for?

We will maintain records and data to comply with our statutory, legal and regulatory responsibilities as well as what we deem to be reasonable practice where there is no record keeping period set down in law or other rules. We will destroy client data in line with these retention periods and our commencement date for any retention period will normally be the end of the client relationship.

We will destroy business contact data when our business relationship with you comes to an end and if you have engaged with us via the web site and this does not proceed to a business relationship, we will destroy the data provided six months after the date of your enquiry.

If you have specific queries in relation to retention periods, please contact data.protection.officer@stonewell.im

Your rights

If you wish to see the data processed about you by SL, please contact data.protection.officer@stonewell.im

You may have additional rights under applicable data protection legislation/regulations including where applicable the Isle of Man Data Protection Act 2018 and the EU General Data Protection Regulation (“GDPR”) such as the right to rectification of incomplete data and the right of erasure of data.

An important right that you have is the right to object to processing. This right applies where, after careful consideration, we have decided that is in the legitimate interests of SL to process data about you.

• If you are a person who has a connection to one of our clients, we process data for our legitimate interests when we use your contact details to keep in touch, when we ask for certain due diligence information about you to assist with our compliance obligations, when we hold your bank account details in case we need to make a payment to you and where we maintain our internal records;
• If you are a person who has a connection to the SL or a person who has contacted us, we process data for our legitimate interests when we use it to keep in touch with you, to request your services (where applicable) or to reply to a contact made to us.

You have the right to receive the personal data you provide to us in a structured, commonly used and machine-readable format and have the right to transmit this data to another controller, without hindrance from us.

If you wish to exercise any of these rights, please contact: data.protection.officer@stonewell.im

If you wish to make a complaint about how we have processed your data, please contact: data.protection.officer@stonewell.im