Legal

The Fortress Group is an Isle of Man registered business name of a group of owner managed businesses that are registered in the UK and the Isle of Man. The partners include Fortress Management Services Limited and Fortress Management Services (UK) Limited. All partners of the group are responsible for meeting their respective regulatory obligations in the territories within which they operate.

Fortress Management Services Limited (FMSL) is licensed by the Isle of Man Financial Services Authority (www.iomfsa.im).

FMSL is incorporated in the Isle of Man, Company Reg. No. 70312C; VAT Reg. No. 001 2120 71

FMSL Registered Office: 2nd Floor, Exchange House, 54-62 Athol Street, Douglas, Isle of Man, IM1 1JD

FMSL Executive Directors: E.R. Bennett LL.B.(Hons), TEP and E.M. Hall BSc. (Hons), ACIS.

FMSL Non-Executive Directors: R.J. Bennett LL.B.(Hons), and S. Trimble FICA, ACol, ACSI.

Privacy Policy

This policy is designed to help you, as a client of Fortress Management Services Limited (“Fortress”), a user of our website or a business contact to understand how your personal data is processed by Fortress and why. Fortress is strongly committed to protecting personal data. This privacy policy describes why and how we collect and use personal data and provides information about individuals’ rights.

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.

Your rights

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 ask@inforights.im

How we use cookies

Please see our dedicated cookies page.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy policy. You should exercise caution and look at the privacy policy applicable to the website in question.

Terms and Conditions

  1. User obligation

Use of this site constitutes your acknowledgement and acceptance of these Terms and Conditions of Use, which take effect on the date on which you first use the site. By accessing, or using the materials from this site, you agree on your own behalf and on behalf of each entity and person on whose behalf you act to abide by the terms and conditions set out below. Fortress Management Services Limited reserves the right to change these Terms and Conditions of Use at any time by posting changes online and it is your responsibility to refer and to comply with these terms on accessing the site. Your continued use of this site after changes are posted constitutes your acceptance of these terms and conditions as modified.

If these Terms and Conditions of Use are not accepted in full, you do not have permission to access the contents of this site and therefore should cease using this site immediately.

If there is any conflict between the Terms and Conditions and rules and/or specific terms of use appearing on this site relating to specific material then the latter shall prevail.

  1. Terms of Use

The use of this site and/or links to this site is only for lawful purposes, in a manner which does not infringe the rights of or restrict or inhibit the use and enjoyment of this site by any third party. Such restriction or inhibition includes, but is not limited to, conduct which is defamatory, or which may harass, cause distress or inconvenience to any person and the transmission of obscene or offensive content or interruption of the normal flow of dialogue within this site.

All information included on Fortress Management Services Limited’s website and/or links to this site is/or are intended for information purposes only and does not represent legal advice. Users are hereby placed under notice that they should take such appropriate steps to verify such information. No user should act or refrain from acting on the information contained in this web site without first verifying the information and as necessary obtaining legal and/or professional advice.

Fortress Management Services Limited makes no representation or warranties whatsoever as to the accuracy of the information contained within this website. In addition Fortress Management Services Limited does not warrant that the functions contained in the material on this website will be uninterrupted or error free, that defects will be corrected, or that this site or the servers that make it available are free of viruses or represent the full functionality, accuracy or reliability of the materials. In no event will Fortress Management Services Limited be liable for any loss or damage, or any loss or damage whatsoever arising from the use, or loss of use, of data, or profits arising out of or in connection with the use of Fortress Management Services Limited’s website.

  1. Disclaimer/ Limitation of Liability

The information and other materials included on this site may contain inaccuracies and typographical errors. Fortress Management Services Limited does not warrant the accuracy or completeness of the information and materials or the reliability of any statement or other information displayed or distributed through the site (including without limitation, the information provided through the use of any software). You acknowledge that any reliance on any such statement or other information shall be at your sole risk. Fortress Management Services Limited reserves the right to correct any errors or omissions in any part of the site and to make changes to the site and to the materials, products, programs, services or prices described in the site at any time without notice.

Fortress Management Services Limited expressly disclaims all liability for any direct, indirect or consequential loss or damage occasioned from the use or inability to use this web site whether directly or indirectly resulting from inaccuracies, defects, errors, whether typographical or otherwise, omissions, out of date information or otherwise, even if such loss was reasonably foreseeable. Consequential and indirect loss and damage shall include but not be limited to loss of profit, loss of goodwill, and wasted expenditure.

Fortress Management Services Limited make all reasonable attempts to check and test material at all stages of production, and to exclude viruses from this website. It is always wise for you to run an up to date anti – virus programs on all the material downloaded from the Internet.

By accessing Fortress Management Services Limited’s website, you agree that material downloaded or otherwise accessed through the use of this web site is obtained entirely at your own risk and the you will be entirely responsible for any resulting damage or disruption to your data, software or computer systems and any resulting damage to software or computer systems or any resulting loss of data, even if such loss and damage was reasonably foreseeable and that Fortress Management Services Limited had been advised of the possibility of the same.

Fortress Management Services Limited does not accept any liability in connection with any third party web sites that can be accessed through this web site and does not endorse or approve the contents of any such site.

If any provision of these Terms of Conditions is found to be invalid by any court having competent jurisdiction, the invalidity of the remaining provisions which shall remain in full force and effect.

Fortress Management Services Limited’s omission to exercise any right under these Terms and Conditions shall not constitute a waiver of any such right unless expressly accepted by Fortress Management Services Limited in writing.

  1. Copyright

Except where expressly stated to the contrary, copyright of the content of this website is owned by or licensed to Fortress Management Services Limited. Permanent copying and/or storage of the whole or part of this web site or the information contained therein or reproduction or incorporation of any part of it in any other work or publication whether paper or electronic media or any other form is expressly prohibited without the express permission of Fortress Management Services Limited.

  1. Governing Law and Jurisdiction

The Terms and Condition shall be governed by and construed in accordance with the laws of the Isle of Man and the user and Fortress Management Services Limited agree to submit any dispute arising out of the use of this web site to the exclusive jurisdiction of the Manx courts.

Fortress Management Services Limited (FMSL) is licensed by the Isle of Man Financial Services Authority (www.iomfsa.im).

FMSL is incorporated in the Isle of Man, Company Reg. No. 70312C; VAT Reg. No. 001 2120 71

FMSL Registered Office: 2nd Floor, Exchange House, 54-62 Athol Street, Douglas, Isle of Man, IM1 1JD

FMSL Executive Directors: E.R. Bennett LL.B.(Hons), TEP and E.M. Hall BSc. (Hons), ACIS.

FMSL Non-Executive Directors: R.J. Bennett LL.B.(Hons), and S. Trimble BSc (Hons), PG Dip (GRC), FICA

Cookie Policy

Our website uses a number of cookies to store data on our visitor’s computers.

To find out how to control the cookies that are created on your device please see this page. To find out how to delete cookies please see this page. For more information about managing cookies, please see http://www.aboutcookies.org/.

Cookies created by this website

This website creates a number of cookies, which are refered to as first party cookies as they are specific to the host site that created them. All the first-party cookies which are created do not store any personal or sensitive information, or anything that makes you personally identifiable to us. They are used for essential functionality such as security when processing form data or for analytics which helps us use anonymous visitor data to gain a better understanding of how people use our website.

Analytics

We use Google Analytics, which creates a number of first-party cookies, all prefixed __utm:

__utma contains a unique and anonymous identifying ID, which allows us to ensure that subsequent visits to our website are recorded as belonging to the same (unique) visitor. This cookie expires after two years.

__utmb used to establish and continue a unique user session. Each time you request another page from the website the cookie is updated to expire after 30minutes.

__utmc works with __utmb to determine when to create a new session for a website visitor. This is a session cookie and expires when you exit the browser.

__utmz tracks how you found us and is used to calculate traffic and navigation within the website.

__utmv You may also sometimes find this cookie is created which relates to custom reporting segments, a feature which we occasionally use on Google Analytics

Full details of the cookies which Google Analytics uses can be found in Cookies & Google Analytics in documentation for Google’s Analytics tracking code. You can also read Google’s Privacy Policy for Google Analytics.

We don’t share the data that Google Analytics collects, and we don’t believe that our use of Google Analytics is privacy-intrusive. We use the data that is collected in the following ways:

to report, in aggregate, how our visitors find and use our website;

to understand overall visitor behaviour; and

to inform how we update and improve our website.

To opt out of our use of Google Analytics you may wish to consider using the Google Analytics Opt-out Browser Add-on.

Paid Search Marketing

We use Google Adwords as a means of advertising our website. If you click on a sponsored advert on Google or visit a website which displays Ads by Google (Google Display Network), information about the ad and keywords that brought you to our website is stored in the __utmz cookie mentioned above. This helps us track visits from Google Adwords that led to an enquiry, so that we can determine the return on investment of our advertising spend. No personally identifiable information is stored in this cookie, however we may be able to associate a contact form you have submitted, with analytics data stored in the __utmz cookie. This information is used to determine which ads and keywords led to an enquiry, so that we can optimise the Adwords campaign accordingly.

When you visit our website, Google creates a cookie to identify your browser and then when visiting other websites on their Display Network, Google may present you with our ads rather than ads relating to the website you are visiting as it does by default.

You may opt out of Google’s use of cookies by visiting the Google advertising opt-out page.

Cookies created by external services

In addition to our first-party cookies, you may be served one or more of the following third-party cookies during your visit to our website. By using our website we’ll assume that you are happy to receive all cookies on our website, but we have provided information at the top of this page on how you can set your browser to prevent cookies being created.

Third party cookies are cookies created by an external service when you use a page on our website. These cookies are specific to the third-party’s domain and accordingly the data held in them can be seen and managed by the third party and not by us. We control whether or not we use the third-party service with our website, and how it is integrated and presented on our website. We do not have control over the cookies themselves. We carefully select 3rd party services to use on our website; ones that are not likely to abuse your privacy according to the terms of their privacy policies.

Google Maps

We may use Google Maps on our Contact Us page to provide detailed information on how to locate our offices. Google Maps stores up to four cookies: khcookie, NID, SNID and PREF. We use Google’s interactive maps because we believe they provide a helpful way for our visitors to identify how best to travel to us. We use the Google Maps tools on the basis that Google adheres to its privacy policy and its terms of service for Google Maps

Other cookies

From time to time we may use additional external services on our website which may create cookies on your device. As we add new services or make changes that use cookies, we will update this cookie policy with the details.

If you have any concerns about the cookies we create or the way we aim to attain consent from you, please contact us and we’ll be happy to answer your questions.

Email Disclaimer

This email and any attached files are confidential and may be legally privileged. If you are not the intended recipient, any disclosure, reproduction, copying, distribution, or other dissemination or use of this communication is strictly prohibited. If you have received this transmission in error please notify the sender immediately and then delete this email.

The email and any attachments may not be copied or forwarded without expressed written permission of the sender. In the event of any unauthorised copying or forwarding the recipient will be required to indemnify Fortress Management Services Limited, and any of its employees, against any claim for loss or damage caused.

Email transmission cannot be guaranteed to be secure or error free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore is in no way liable for any errors or omissions in the content of this message, which may arise as a result of email transmission. If verification is required, please request a hard copy.

The Firm does not endorse opinions, comments and other information in this e-mail that do not relate to the business of this firm. E-mails are subject to data corruption, delay, interception and unauthorised amendment. Nothing in the message is capable of or intended to create any legally binding obligation.

The Fortress Group is the trading name of Fortress Management Services Limited.

Fortress Management Services Limited is licensed by the Isle of Man Financial Services Authority.

Cybercrime Alert: Bank Details

Please be aware of the significant risk posed by cyber fraud, specifically affecting email accounts and bank account details. Please note that we will NOT change our bank details via email. Please be careful to check account details with us in person by phone if in any doubt. We will not accept responsibility if you transfer money into an incorrect account.

Fortress Management Services Limited (FMSL) is licensed by the Isle of Man Financial Services Authority (www.iomfsa.im).

FMSL is incorporated in the Isle of Man, Company Reg. No. 70312C; VAT Reg. No. 001 2120 71

FMSL Registered Office: 2nd Floor, Exchange House, 54-62 Athol Street, Douglas, Isle of Man, IM1 1JD

FMSL Executive Directors: E.R. Bennett LL.B.(Hons), TEP and E.M. Hall BSc. (Hons), ACIS.

FMSL Non-Executive Directors: R.J. Bennett LL.B.(Hons), and S. Trimble FICA, ACol, ACSI.