This privacy notice explains how we, Ravenscroft (IOM) Limited, collect and use your personal information. Ravenscroft (IOM) Limited is the controller of personal information processed, unless otherwise stated. You may contact us by writing to the Data Protection Officer, Ravenscroft (IOM) Limited, St George’s Tower, Hope Street, Douglas, Isle of Man, IM1 1AR.
We primarily collect information about you when you complete our Application Form and related forms, during meetings, and ongoing communications by phone, emails, and letters.
We may also collect personal information from your Financial Advisor if they introduced you to us. Your Financial Adviser should tell you that they will be passing your information on to us, and you should have given you Financial Advisor consent to do so.
We also collect information from other sources such as open source intelligence and third parties to fulfil our legal obligations, such as financial crime prevention.
Information collected typically include personal information from which you could be identified, directly or indirectly, including your name, contact details, date of birth, identification and tax numbers, location data, bank details and financial circumstances. The information we collect may also include special categories of information such as information about your health.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
We will primarily collect and process your information, including special categories of information, to perform the agreement between us and to fulfil our legal obligations.
The information that we collect about you is necessary for us to provide you with the services that you require from us. Without collecting your personal information, we would not be able to provide you with the service you required.
We require your explicit consent to collect and process special categories of information such as health data. We will process this information to determine the suitability of the service you require from us.
We will also process your information to fulfil our legal obligations include those in respect of financial crime prevention, tax reporting and suitability.
If you consent, we may process your information to send you marketing communications which may including investment presentations, social events, investment updates and monthly factsheets. Your consent for us to process your information for marketing communications may we withdrawn at any time. If you wish to do so, please either unsubscribe to the received email or contact: dataprotection@ravenscroftgroup.com
In limited circumstances, we may process your information for our legitimate interest, such as analysing the cost and efficiency of the services we provide to support the development our business.
We will use your information to:
1. Facilitate the opening of the account you requested, along with ongoing administration of the account.
2. Undertake enquires and assessments for the purpose of suitability and financial crime prevention.
3. Open accounts with the SEI who will act as your administrator and custodian (if appointed) according to the agreement between us.
4. Undertake tax reporting.
5. Undertaking ongoing reviews to ensure proper management of your portfolio.
6. Providing you with information you may require regarding your portfolio and sending you valuations.
7. Disclose information third parties such as auditors, regulatory authorities, and law enforcement if required.
We do not use process information using automated processing or profiling.
In order to provide you with the services you require, we may send your information to third parties.
We will share your information with companies within the Ravenscroft Group, who facilitates us in the provision of our services, such as the provision of information technology services. Ravenscroft Limited, including their agents, their actual and prospective successors or transferees and their respective data processors wherever these may reside, will act as data processors. We have an agreement in place with Ravenscroft Limited ensure compliance with data protection, confidentiality, and security standards.
In accordance with the Terms of Business and Application Form, we may share your information with SEI, who will act as a separate controller of information received.
We may also send your information to third parties such as those that we engage for professional compliance, accountancy or legal services as well as the product and platform providers that we use to arrange the services we provide to you. Where third parties are involved in processing your information, we will have a service agreement in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your information and that they will only act in accordance with our written instructions.
If we are required to provide your personal information to a third party, we will use appropriate security measures to protect your personal information in transit.
We won’t share your information for marketing purposes with companies outside the Ravenscroft Group of companies.
Information provided to third parties, as set out above, may involve the transfer of information to jurisdictions outside the EEA, which may not have equivalent data protection requirements.
We will not transfer information to such third parties located in jurisdiction outside the EEA, unless the country has an adequacy decision for the purpose of data protection, or we have an arrangement in place to maintain an appropriate level of protection over the information transferred and processed.
We should not hold your personal information for longer than is required under the terms of the agreement between us. However, we are subject to minimum regulatory retention periods for information processed. We also reserve the right to retain information for such longer period as we consider reasonable, taking into account the nature of the service provided and the investments involved. In the majority of cases, once the regulatory retention periods have passed we will securely destroy or destruct the information.
Our normal practice is to retain documents relating to client agreements for six years after the end of the relationship.
1. Right of subject access: You have the right to request a copy of the information that we hold about you.
2. Right to rectification: We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct information that you think is incorrect or incomplete.
3. Right to erasure: You have the right to request us to remove or delete information where there is no compelling reason for us to continue processing it.
4. Right to restrict processing: You have the right to ask us to restrict the processing of your information.
5. Right to object: you have the right to object us processing your information on a legitimate interest basis.
6. Right to data portability: When your personal information is processed by automated means, you have the right to ask us to move your personal information to another organisation for their use.
If you would like to exercise any of these rights, please write to our Data Protection Officer using our contact details under the ‘How to Contact us’ section.
We will not charge a fee if you wish to exercise any of these rights, unless the request is manifestly unfounded, excessive, or repetitive. To enable us to fulfil your request we will ask for information to verify your identity.
We will comply with your request, subject to the restrictions of our regulatory requirements and the contractual and legal obligations noted above.
We hope that you won’t ever need to, but if you do want to complain about our use of your personal information, you can write to our Data Protection Officer, using our contact details under the ‘How to Contact us’ section.
You also have a right to lodge a complaint with the supervisory authority for data protection.
Information Commissioner’s Office
PO Box 69
Douglas
Isle of Man
IM99 1EQ
www.inforights.im
We may change this policy from time to time.
This privacy policy was updated on 21/08/2020.
If you have any questions about this privacy notice, you would like to exercise your rights, or would like to complain about our use of your personal information, you can write to our Data Protection Officer, either at:
Ravenscroft (IOM) Limited, St George’s Tower,
Hope Street, Isle of Man IM1 1AR, or
email: IOMDPO@ravenscroftgroup.com