At Quilter International Business Services Limited, Quilter International Trust Company Limited, Quilter International Isle of Man Limited and Quilter International Ireland dac, we are committed to protecting your privacy and ensuring that your personal information is collected and used appropriately, lawfully and transparently.
This privacy notice explains:
- Who we are
- What personal information we collect
- How we use your personal information
- Who we share your information with and why
- How we keep your information secure
- Your rights
- How to contact us
Quilter International Business Services Limited, Quilter International Isle of Man Limited and Quilter International Ireland dac provides wealth management products and services through a network of companies and businesses based around the world. More information about who we are can be found in the About us page.
We collect certain personal information about you, this includes your name, address, or phone number and other information. We collect this information about you when you:
- use our website and secure online services
- contact us about products and/or services
- apply for and receive services
- visit a financial adviser
- register to receive one of our newsletters
The type of personal information we collect will depend on the purpose for which it is collected and will include:
- your contact details
- information to verify your identity
- family, lifestyle and health information
- financial and bank details
- employment information
We collect personal information directly from you. For example, we ask for personal information at the start of our relationship (eg: when you apply for a policy or service) and in subsequent communications in order to check your identity. This is a legal requirement and is important to help safeguard you and us against potential crime.
Where we provide our services to trusts, we collect the personal information listed for the settler, beneficiaries and trustees of that trust. Where we provide our services to companies we may collect personal information for Directors, Shareholders and Beneficial Owners of the company.
Where it is necessary we collect more sensitive information (such as criminal convictions or detailed health information). If this is the case we will explain what information we require and why it is needed.
We may also collect information about you from other sources such as:
- your adviser
- another agent (if you have one)
- external third parties (e.g. to verify your identity)
We keep your personal information only as long as is necessary for the purpose for which it was collected, or for legal or regulatory reasons. Personal information will be securely disposed of when it is no longer required in accordance with our Personal Data Retention and Disposal Schedule.
We process your information for the following purposes.
To perform our contract with you and to support and maintain that relationship. This includes the following:
- assessing and processing an application for our services
- providing our products and/or services to you, including the management of our relationship with you and your adviser, or any other agent (if you have one)
- carrying out transactions you have requested
- monitoring or recording telephone calls with you to resolve any queries or issues
- record keeping to ensure our products and/or services operate within the law and relevant regulatory requirements
- providing other services (e.g. enhanced due diligence, underwriting, reinsurance, data hosting, online services, and payments or reporting of any tax or levy)
- Profiling activity – using basic identifiers about you such as your name and address and matching this with information from Experian Marketing Services to create demographics and infer customer ‘types’. This helps us define groups based on factors like interests, age, location and more so we can better understand our customers to adapt and improve our products and services. If you would like to know more about the information we get from Experian Marketing Services, you can visit their Consumer Information Portal which explains who Experian Marketing Services are, what they do and why.
To comply with legal and regulatory requirements. These requirements include the following:
- confirming your identity for regulatory purposes
- detecting and preventing fraud, money laundering, terrorist financing, bribery or other malpractice
- to meet tax reporting obligations such as Common Reporting Standards (CRS) and the US Foreign Account Tax Compliance Act (FATCA).
For specific business purposes to enable us to provide you with appropriate products and services and a secure experience. Our business purposes include the following:
- verifying your identity for security purposes
- enhancing, modifying and personalising our services for your benefit
- providing communications which we think will be of relevance to you
- customer satisfaction research or statistical analysis
- audit and record keeping purposes
- enhancing the security of our network and information systems
- maintaining effective management systems including internal reporting to our parent company and other members of our corporate group.
You have the right to object to us processing your personal data for the business purposes listed above.
Where necessary we share your information to help us to provide our products and/or services to you or to meet our legal and regulatory requirements:
- other companies within the Quilter group
- your financial adviser , third party data providers used by your adviser and any other party authorised by you
- third parties who perform tasks for us to help us provide our services to you or to allow us to meet legal and regulatory requirements, including any necessary tax reporting (these third parties may be based in countries outside the EU)
- a third party to verify your identity, in line with money laundering or other requirements
- organisations, including the police and fraud prevention agencies, to prevent and detect fraud
- regulatory or governmental agencies such as the IOM Financial Services Authority or Central Bank of Ireland
- an appointed discretionary asset manager or custodian to meet their legal or regulatory requirements
- a prospective buyer (or its advisors), for due diligence purposes, if we are considering a sale of any of our business or assets
- other agencies where required by law, court order or regulation.
We are committed to ensuring the confidentiality of the personal information that we hold and we continue to review our security controls and related policies and procedures to ensure that your personal information remains secure.
When we contract with third parties, we require that they have appropriate security, privacy and confidentiality measures in place to ensure that personal information is kept secure.
If we work with third parties in countries outside the EU we ensure these are countries that the European Commission has confirmed have an adequate level of protection for personal information, or the third party receiving the personal data has provided adequate safeguards and agrees to treat your information with the same level of protection as we would.
You have the right to ask us:
- for a copy of the personal information we hold about you
- to update or correct your personal information
- to delete your information
- to restrict processing of your personal information where appropriate.
In certain circumstances you also have the right to:
- object to the processing of your personal information
- object to automated decision making and profiling
- data portability
Information about your individual rights, including how to correct, restrict, delete, or make changes to your personal information, can be found on our Data Protection page.
If you wish to request a copy of the personal information we hold about you please use our Data Subject Access Request (DSAR) online form
More information about your data protection rights can be found here:
For the Isle of Man - https://www.inforights.im/
For Ireland - https://www.dataprotection.ie/docs/Home/4.htm
If you have questions about this notice, or need further information about our privacy practices, please contact our Data Protection Officer.
Data Protection Officer
Quilter International Business Services Limited/Quilter International Isle of Man Limited/Quilter International Trust Company Limited, King Edward Bay House, King Edward Bay Road, Onchan, Isle of Man, IM99 1NU
Telephone: + 44 (0) 1624 655555
If you wish to raise a complaint about how we have handled your personal data, please contact our Group Data Protection Officer who will investigate the matter.
Group Data Protection Officer
Old Mutual House
If you are not satisfied with our response you can complain to our regulators:
The Isle of Man Information Commissioner, First Floor, Prospect Hill, Douglas, Isle of Man, IM1 1ET.
Ireland Data Protection Commissioner, Canal House, Station Road, Portarlington, R32 AP23 Co. Laois, Ireland.