Hawksford Group Privacy Notice
Hawksford is committed to protecting your personal data. This privacy notice describes how Hawksford collects, uses and shares the personal data you provide to us or that we collect during the course of our business activities, including from our websites.
This privacy notice is issued on behalf of Hawksford Group Holdings Limited and other companies within the Hawksford Group. Accordingly, references to “Hawksford”, we”, “us” or “our” in this privacy notice are to the relevant company in the Hawksford Group responsible for processing your data. A list of Hawksford Group companies can be found below.
Hawksford operates in jurisdictions that are outside the European Union, some of which have not been deemed adequate by the European Commission (namely Hong Kong and Singapore). Where we share your data with Hawksford Group companies we do so on terms where such data is to be kept secure and confidential.
Hawksford may collect information from you through your use of our websites, when you request information from us or otherwise in the course of our business.
Hawksford’s Global Data Protection Officer (DPO) may be contacted in relation to questions arising in relation to this privacy notice or if you have any questions in relation to exercising your legal rights. The DPO may be contacted on the details below:
Email address: email@example.com
Postal address: Hawksford House, 15 Esplanade, St Helier, JE1 1RB
Telephone Number: +44 1534 740174
The data we collect about you
Personal data, means any information about an individual from which that person can be identified it includes information that you provide to us or which we gather in the course of operating our business.
Hawksford may collect various types of personal data about you including:
- Identity data (which may include your title, name and passport/driving license/national identification card information, personal data relating to convictions, politically exposed person (PEP) status, personal data available in the public domain and such other information as may be necessary for Hawksford to provide our services meet our legal obligations as to the prevention and detection of fraud, money laundering and other crimes);
- Contact data (which may include postal address, email address and telephone numbers);
- Professional/employment data (which may include your education background, professional qualifications, employment, details of directorship and other offices which you may hold);
- Financial data (which may include sources of wealth, details of your assets, shareholdings and beneficial interest in assets, bank account details, credit history);
- Family relationships data (which may include your marital status, the identity of your spouse/partner and any children you may have);
- Data collected to enable us to meet our contractual obligations (which may include health, family matters, individuals connected to you, religion, race or ethnicity, political opinions);
- Technical data (which may include your internet protocol (IP) address, how you use our website, browser type and version, time zone setting and location, and other technology available from the devices you use to access our websites);
- Marketing and communications data (which may include your preferences in receiving marketing from us and our third party providers and your communication preferences).
If you apply for a position with Hawksford either through our website or directly via email or post we may collect personal data relating to your past employment, education and professional qualifications, your nationality and immigration/residential status, opinions from third parties about you (such as references), publicly available information including but not limited to information on social media accounts and any other personal data which may be gathered during the recruitment process.
If you fail to provide personal data
Where Hawksford is required to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or propose to enter into with you.
How is you personal data collected?
We use different methods to collect data from you and about you including but not limited to:
- Direct Interactions. You may give us your information by filing in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Apply for our services;
- Subscribe to our services or publications;
- Request material be sent to you.
- Third Parties or Publicly Available Sources. We may receive personal data about you from various third parties and public sources including but not limited to:
- personal data gathered through client due diligence undertaken to meet regulatory requirements (including through credit reference agents);
- personal data from publicly available sources such as a Companies Registry;
- personal data received in the course of dealing with advisors, lawyers, regulators, official authorities and service providers;
- our clients in connection with the services we are providing (for example a settlor may provide personal data on beneficiaries);
- legal and/or financial advisors;
- other financial services providers (including from other trust and companies administration service providers);
- personal data on potential candidates may be obtained from recruitment agencies, past or current employers, educational institutions and/or professional bodies;
- analytics providers such as Google based outside the EU.
Information that we collect through our websites
Hawksford has four websites:
You are not required to provide any personal data in order to access our websites.
You may voluntarily choose to provide personal data by signing up for news letters or other publications.
Our websites collect the domain names, IP addresses, user statistics, analytics and browsing history of all visitors. For further information please see our Cookies Policy. Hawksford uses this data to promote our services.
How Hawksford use your information
Hawksford provide corporate, private client and fund administration services to our clients and we use your personal data for those purposes. The purposes for which we use your personal data should be clear when we collect that data. Hawksford will use your personal data to:
- perform a contract that we are about to enter into or have entered into with you;
- comply with a legal or regulatory obligation;
- respond to requests, enquiries or complaints received from you or someone connected to you;
- establish, exercise or defend legal proceedings and/or Hawksford’s legal rights;
- conduct administrative or operational processes within Hawksford;
- compile statistics in relation to the use of our websites;
- send you marketing material;
- for other legitimate business purposes;
- enable us to display relevant targeted advertisements to you about products and services that may be of interest;
- review and process any application you make in relation to recruitment.
Hawksford do not generally rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
Disclosure of your personal data
Hawksford may share your personal data with the parties set out below for the purposes listed above.
- Internal. Hawksford shares personal data with other companies in the Hawksford Group acting as joint controllers or processors and who are based in Jersey, Hong Kong and Singapore.
- External. Hawksford may share your personal data with the following third parties:
- Service providers acting as processors who provide IT and system administration services;
- Professional advisers acting as processors or joint controllers including lawyers, bankers, investment advisers, auditors, brokers, insurers and accountants who provide, legal, banking, advisory, audit, insurance and accounting services;
- Tax authorities, regulators and other authorities acting as processors or joint controllers who require reporting of processing or information for compliance.
- Fraud prevention agencies acting as joint controllers.
- Courts or to comply with legal obligations such as combating money laundering and terrorist financing where such parties would be acting as joint controllers.
- Organisations and individuals if you have applied for a role with Hawksford, in order for us to obtain references and confirmation of details.
Whenever Hawksford transfers your personal data outside of the European Economic Area (EEA), we will ensure a similar degree of protection is afforded to such data by ensuring that at least one of the following safeguards is implemented:
- Hawksford will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (this includes Jersey and Guernsey);
- Hawksford may require certain organisations to use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the United States (US), Hawksford may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
- Hawksford may rely on other circumstances where the law permits the transfer for example where the transfer is necessary for the performance of a contract. Hawksford will ensure any transfer of your personal data will be compliant with applicable data protection laws. Please contact the DPO if you require further information on the specific mechanism used by Hawksford when transferring your personal data outside of the EEA.
Hawksford will provide you with choices regarding certain use of your personal data, particularly around marketing and advertising. Hawksford may contact you by email or other means to inform you about news, market updates, services or events which we think may be of interest to you.
You have the right to ask Hawksford to stop sending you marketing messages at any time by adjusting your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time at firstname.lastname@example.org.
Hawksford has put in place appropriate security measures to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Hawksford has put in place procedures to deal with any suspected personal data breach and we will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
Hawksford will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data we process, you have the right to:
- access your personal data;
- rectify your personal data;
- restrict the use of your personal data;
- request your personal data is erased; and
- object to processing of your personal data.
Where we have relied on consent to process your personal data, you have the right to withdraw consent at any time.
If you wish to exercise any of the rights set out above please contact the DPO.
You also have the right to make a complaint at any time to a supervisory authority for data protection issues. These are:
Jersey - Office of the Information Commissioner in Jersey (https://oicjersey.org).
Hong Kong – Office of the Privacy Commissioner for Personal Data (www.pcpd.org.hk)
Singapore – Personal Data Protection Commission (www.pdpc.gov.sg)
You may also contact the authority in the EU member state of your usual residence or place of work.
We would, appreciate the chance to deal with your concerns before you approach any regulatory authority so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
We may make changes to this privacy notice from time to time. You should look at this page to ensure you are comfortable with any changes. This version was last updated on 26 September 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Hawksford Group Companies
The following Hawksford group companies are data controllers:
- People & Projects (Beijing) Business Consultancy Co Limited
- People & Projects (Shanghai) Business Consultancy Co Limited
- People & Projects (Suzhou) Business Consultancy Co Limited
The following Hawksford group companies are data controllers and have the registered address of Unit 305-7, 3/F, Laford Centre, 838 Lai Chi Kok Road, Cheung Sha Wan, Kowloon, Hong Kong:
- Hawksford (HK) Limited
- Orion Smart Partners Inc
- P-Comsec Limited
- People & Projects Limited
- Modus 3 Limited
- P&P-Iberam Limited
The following Hawksford Group companies are registered as data controllers and each have the registered address of Hawksford House, 15 Esplanade, St Helier, Jersey JE1 1RB:
- Hawksford Group Holdings Limited
- Hawksford Group Services Limited
- Hawksford Trust Company Jersey Limited
- Hawksford Trust Company No.2 (Jersey) Limited
- Hawksford Trustees Jersey Limited
- Hawksford Fiduciaries Jersey Limited
- Hawksford Secretaries Jersey Limited
- Hawksford Jersey Limited
- Hawksford Nominees Jersey Limited
- Hawksford Executors Limited
- Hawksford Fund Services Jersey Limited
- Genus Trust Company Limited
- Hawksford Foundations Jersey Limited
- Hawksford Directors 1 Limited
- Hawksford Directors 2 Limited
- Roanne Trust Company (Jersey) Limited
- Roanne Securities Limited
- Roanne (Nominees) Limited
- Key Nominees Limited
- Key Custodians Limited
The following Hawksford Group companies have the registered address of 16 Raffles Quay #33-02, Hong Leong Building, 048581, Singapore:
- Hawksford Singapore Pte Ltd
- Peak Wealth Advisor Ltd
- Silver Field Global Limited
- Hawksford Trust Services Pte Ltd
- Venture Century International Limited
- P &P Singapore Pte Limited
The following Hawksford Group companies have the registered address of 3rd Floor, Fairgate House, 78 New Oxford Street, London, WC1A 1HB:
- Hawksford UK Holdings Limited
- Hawksford UK Services Limited
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