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 Fortress. The definition of personal data includes any expression of opinion about you and any indication of the intentions of Fortress or any other person in respect of you.
What personal data is processed and how is it used?
If you are a client
In order to become a client of ours, 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, address etc, some understanding of why you want to do business with us, some information about your wealth profile and a copy of your picture identity document and address verification document. We will collect this from you if you are going to be a shareholder, an ultimate beneficial owner, a director or someone that can provide instructions to us in relation to a client. We will use it for client take on procedures and for ongoing compliance monitoring purposes. This can include public source searching and searching against paid for databases.
Our legal and regulatory responsibilities extend to the automatic exchange of information for taxation purposes and for the purposes of inclusion on any central register with which we are obliged to file information. Whilst a lot of the information that we collect, as set out in the paragraph above, is used for these purposes too, we also collect your tax identification number as we are required to use that for reporting purposes.
We will use your contact information, any preferences and interests as well as any other information relevant to customer surveys and offers, to send you Terms of Business and to keep in touch with you. This might include advising you of new products or services, inviting you to events or sending you our periodic newsletter. As part of assisting you, 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.
Our policy is to only collect the personal data necessary for agreed purposes. Where we need to process personal data to provide professional services, we ask our clients to provide the necessary information to the data subjects regarding its use. We may collect personal data from our clients or from a third party acting on the instructions of the relevant client.
If you are a visitor to our website and/or potential client
We may collect your name as well as contact information if you provide that information to us by way of our contact form or any other means. We use this information to respond to any enquiry in the most efficient manner possible. We also use it to send you periodic marketing information which might be of interest to you. This might include advising you of new products or services, inviting you to events or sending you our periodic newsletter.
You will always have the option of opting out of receiving marketing related contacts from us. We may also use your data to provide analysis of progress against business goals.
If you are a business contact
We may hold a small amount of personal data about you such as your name, company, role, contact details and any preferences and interests. We will use those to keep in touch with you and to send you periodic marketing information. This might include advising you of new products or services, inviting you to events or sending you our periodic newsletter. You will always have the option to opt out of receiving this information from us.
Where is the data stored?
All of the data that we process about you is held in the Isle of Man office in paper form and/or electronically or may be archived offsite in a secure storage facility. You should be aware that some of this data may be accessible to our staff, when they have the correct permissions, from mobile or laptop devices.
Who can see the information?
If you are a client
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.
As noted above, we are legally obliged to exchange certain information with the Income Tax Division of the Isle of Man and with the Companies Registry for the purposes of the Beneficial Ownership Act. There may be other instances where we are legally obliged to file information in other countries, for example with company registries or tax bodies.
If as part of our service to you, we need to engage with professional advisors 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 your company is incorporated in another jurisdiction that is not the Isle of Man. 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 visitor to our website
Your data will only be available to those Fortress staff who need to have access to it. Some data may be visible to our website provider.
If you are a business contact
Your data will only be available to those Fortress 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.
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 website or any other means and this does not proceed to a business relationship, we will destroy the data provided one year after the date of your enquiry unless you provide us with consent to hold your data for marketing purposes.
If you have specific queries in relation to retention periods, please email our Data Protection Officer at the contact details below.
If you wish to see the data processed about you by Fortress, please contact our Data Protection Officer at the contact details below.
You have additional rights under the Data Protection Act 2018 or any legislation which replaces it 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 it is in the legitimate interests of Fortress to process data about you. We process data for our legitimate interests when you are to be appointed as an external director on a client company and we ask for information to determine your suitability for the role. We also process data for our legitimate interests where we may obtain a copy of your CV and when we undertake searches against public sources and paid for databases to assist with our compliance obligations.
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 those rights, please contact our Data Protection Officer at the contact details below.
If you wish to make a complaint about how we have processed your data, please contact our Data Protection Officer at 2nd Floor, Exchange House54-62, Athol Street, Douglas, Isle of Man, IM1 1JD or email Dataprotection@thefortressgroup.co.uk. You can also contact the Information Commissioner on 01624 693260 or by emailing firstname.lastname@example.org
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