Privacy Statement and Disclaimer (UK)
Imperium Trust Company (UK) Limited
Imperium Trust Company (UK) Limited (Imperium UK) is an HMRC-registered Trust or Company Service Provider, based in the UK.
When you request a service, we will collect some personal information about you, including; your name, address, contact telephone numbers, email address date of birth, your sex, your ethnicity.
We require this information for several different reasons including, communicating with you as we provide our service to you, communication on your behalf with third parties, anti-money laundering and counter-terrorist financing due diligence purposes, reporting and research purposes and for marketing and other activities.
Imperium UK has created this privacy statement to comply with the UK Data Protection Act 2018 (DP2018). The statement is for your information, and it covers how we collect, use, disclose, transfer and store your personal data.
1. Introduction and General Terms
Imperium UK is committed to protecting your personal information when you are using our goods and services. We want our services and products to be safe, transparent and reliable. This privacy statement relates to our use of any personal information we collect from you. It also relates to our use of any personal information you provide to us by phone, SMS, email, and letters and other correspondence and in person.
To provide you with the full range of Imperium UK services, we sometimes need to collect information about you. This privacy statement explains the following:
- what personal information we collect about you
- how we use information collected about you
- when we use your details to contact you
- under which circumstances we may disclose your personal details to any third party
- your choices around what personal information you provide to us.
Imperium UK is committed to safeguarding your personal information. Whenever you provide such information, we are legally obliged to use your information in line with all applicable laws concerning the protection of personal information, including the DP2018. No system of data storage can be completely secure; if you have any concerns or complaints that your personal data held by the Imperium UK could have been compromised: someone could have discovered your personal details held by us, please contact us immediately. Our contact details are in section 12 of the statement.
2. What information will Imperium UK collect about me?
When you get in touch with us either via email, a telephone call or when you visit us at our office, we will collect some personal information about you. This can consist of information such as your name, email address, postal address, telephone or mobile number, gender, date of birth and ethnicity as well as information collected about the services we provide you.
Imperium UK will use the information provided by you, or a family member, alongside any information available from Publicly Available Sources. From time to time, we may request a professional background report about your circumstances to provide further information for our client due diligence process.
3. How will the Imperium UK use the information collected about me?
Imperium UK will use your personal information for several purposes, including the following:
Ensuring we have accurate information so that we may communicate with you and keep you updated of developments as we provide a service to you.
Ensuring that we have explicit consent from you [CV1] and that we hold accurate information so that we may contact you at a future date for quality control, surveys or other research purposes, and fundraising and marketing activities.
Ensuring that we have accurate information for internal reporting, for example, reporting to our director/board or trustees/shareholders, all reporting to other interested stakeholders.
4. When will Imperium UK contact me?
Imperium UK may contact you about any communication we receive from you or any other parties involved in the service we provide for you.
5. Will I be contacted for marketing purposes?
Imperium UK will only send you marketing emails or contact you where you have agreed to this by giving us your consent. From time to time we may also contact you and ask your views about the service Imperium UK has provided to you.
6. Will Imperium UK share my personal information with anyone else?
We will keep your information within Imperium UK except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies), where sharing is required to fulfil the contract between us or where you have consented to share your information with other parties involved in the service we provide to you, including, for example, Banks, Investment Houses, Lawyers, Accountants and other professionals.
We will use your information within Imperium UK and will share it outside Imperium UK when required for delivering services to you or where you have requested it via a data portability request or given your consent. Imperium UK requires all third parties to comply strictly with its instructions, and Imperium UK requires that they do not use your personal information for their own business purposes and only use your information for reasons associated with the goods or services we provide for you.
7. How long will Imperium UK keep my personal information?
We will hold your personal information on our systems for as long as is necessary for the purpose of the supply of goods or services and any legal requirements. It is anticipated that we will hold your personal information for at least six years from the cessation of our business relationship with you; this is a legal requirement which we have to meet.
Six years from the cessation of our business relationship, we shall destroy all records of your personal data in accordance with our file destruction policy, except where we are prevented from doing so by law (for example by government bodies or law enforcement agencies).
8. Can I delete my personal information?
You can always ask for your information to be deleted by Imperium UK. However, please bear in mind that we are required to hold certain data for at least six years from the cessation of our business relationship with you for legal reasons.
Deleting the data Imperium UK holds about you will erase any personal data we have about you and it will mean any data we hold about you after your request that we use in future, will be made anonymous.
9. Can I find out what personal information Imperium UK holds about me?
Under DP2018 you have the right to request a copy of the personal information Imperium UK holds about you and to have any inaccuracies corrected. (We require you to prove your identity with two pieces of approved identification). We have a legal duty to supply, correct or delete personal information about you on our files. Please address requests and questions about this or any other question about this privacy statement to the Data Protection Officer, lmperium Trust Company (UK) Limited, 25 Bedford Square, London, WC1B 3HH.
We will need two copies of forms of identification, which can be:
- passport
- driver’s licence
- birth certificate
- utility bill (from last three months)
- current vehicle registration document
- bank statement (from last three months)
10. Changes to Imperium UK privacy statement
This privacy statement may be updated from time to time, so you may wish to check it each time you submit personal data to Imperium UK. If you do not agree to any changes, please do not continue to use the Imperium website or submit your personal data to Imperium UK. You can also request to delete your personal data that Imperium UK holds at any time (subject to any legal reasons we may have to keep some of the data we hold about you).
11. Sharing of your data with others
As part of the service that we provide, it may be necessary to share data we hold about you with third parties as set out in section 6.
You also have the right to ask us to share your personal data with anyone you wish. To exercise this right to data portability, please write to us, giving full details, using the contact information provided in section 14 of this statement.
12. Contacting Imperium UK about this privacy statement
If you have any questions or comments about the Imperium UK privacy statement, please contact:
The Data Protection Officer
Imperium Trust Company (UK) Limited
25 Bedford Square
London
WC1B 3HH
Telephone +44 (0)20 3026 5667 or email grant.twine@imperiumtrust.com
13. Information Commissioner’s Office
If you wish to raise any complaint with regard to the manner in which we handle your data, you can do this by contacting the Information Commissioner’s Office.
Telephone +44 (0) 303 123 1113 or by visiting www.ico.org.uk/make-a-complaint/