It is important to ensure the privacy of your data and this privacy notice describes how Affinity Private Wealth ('we', 'us') collect and process personal information about you; how we use and protect this information, and your rights in relation to this information. Affinity Private Wealth is a registered business name for each of APW Investors Limited and Affinity Trust Limited. Where we provide services to you, the data controller will be the member of the Affinity group which enters into the contract with you for those services.

This privacy notice applies to all personal information we collect about you. Personal information is information, or a combination of pieces of information, that could reasonably allow you to be identified.

1. Information we collect

We may collect your personal information from a variety of sources, including information we collect from you directly (e.g. when you contact us in relation to the provision of services), and information we collect about you from other sources, including commercially available information, such as public databases (where permitted by law).

Certain personal information is required as a consequence of any contractual relationship we have with you, to enable us to carry out our contractual obligations. Failure to provide this information may prevent or delay the fulfilment of these obligations.

1.1. Information we collect directly from you

(a)    personal details (e.g. name, age, place and date of birth);

(b)   contact details (e.g. phone number, email address, postal address or mobile number);

(c)    occupation details (e.g. role; employer or business name);

(d)   due diligence, such as nationality, gender, marital status, copies of identity documents, source of wealth and tax status/residency.

1.2. Information we collect from other sources

The following are examples of the categories of information we may collect from other sources (such as business partners, intermediaries, the Internet, KYC6 or commercial registers):

(a) personal details (e.g. name, age, date of birth);

(b) contact details (e.g. phone number, email address, postal address, mobile number);

(c) occupation details (e.g. role, employer or business name);

(d) business connections (e.g. directorships).

2. How we use your personal information and the basis on which we use it

We use your personal information to:

(a) carry out background checks prior to accepting you as a client;

(b) contact you with questions and other information regarding the services we are providing to you;

(c) ensure that our records are kept accurate and up to date;

(d) ensure we issue accurate invoices for our services;

(e) send you information about products and services which we think will be of interest to you (unless you notify us that you do not consent to your personal information being used for this purpose); and

(f) comply with legal or regulatory obligations to which we are subject.

We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:

(a) to fulfil our contractual obligations to you through the provision of services;

(b) to comply with our legal obligations to you or to a third party;

(c) to meet our legitimate interests so that: we are able to provide the services you request; our services function correctly in relation to your needs; any complaints or concerns can be promptly relayed to you; we can respond to any questions or concerns you might have; we may carry out research and analysis to ensure products and services we offer are relevant to you; and our records are kept up to date and accurate; and

(d) to send you direct electronic marketing messages to the extent you have consented to receiving such messages in accordance with applicable law. You have the right to object to the processing of your personal information for such direct marketing activities.

We do not envisage that any decisions will be taken about you using fully automated means.

3. Your rights over your personal information

By continuing to use our services and the website, you consent to our holding and using your personal data in accordance with this privacy notice.

Please let us know if any of the personal information that we hold about you changes, is inaccurate or incomplete so that we can correct and update the information on our systems.

You can view, request erasure of, correct or update the personal information you provide to us by contacting us using the details set out below. At any time you may request access to any of your personal information which we hold in electronic or paper form. Where you make such an access request by electronic means, we will provide the information by electronic means where possible, unless otherwise requested by you. In certain circumstances you may object to specific processing activities, require us to restrict how we process your personal information, or ask us to share your personal information in a usable format with another company. Where you have given your consent to a particular type of processing, you may withdraw that consent at any time and it is as easy to withdraw consent as it is to give it.

To exercise any of the above rights, please contact us using the details set out below.

4. Information sharing

In general, we do not share your personal information with third parties (other than service providers acting on our behalf) unless we have a lawful basis for doing so.

We may disclose or transfer personal data collected by us to our group companies insofar as is reasonably necessary for the purposes of our service offering or for bona fide compliance purposes as well as on the legal basis set out in this Privacy Notice.

We rely on third-party service providers to perform a variety of services on our behalf, such as website hosting, electronic message delivery, payment processing, data analytics and research and electronic storage of data on their servers. This may mean that we have to share your personal information with these third parties. When we share your personal information in this way, we put in place appropriate measures to make sure that our service providers keep your personal information secure.

Other situations in which we may disclose your personal information to a third party, are:

(a) to perform other services we request from service providers;

(b) where permitted by law, to protect and defend our rights and property; and

(c) when required by law, and/or public authorities.

We may also share aggregated information that cannot identify you for general business analysis, e.g. we may disclose the number of visitors to websites or services.

5. Information security

We have implemented appropriate technical and organizational measures, which include generally accepted standards of technology and operational security, to protect personal information from loss, misuse, alteration or destruction. We require all employees and principals to keep personal information confidential and only authorised personnel have access to this information.

We will retain your personal information in accordance with our data retention policy, which sets out data retention periods required or permitted by applicable law.

6. Information transfer

Your personal information may be transferred to, stored and processed in a country other than the one in which it was provided. When we do so, we transfer the information in compliance with applicable data protection laws.

We may transfer the personal information we collect about you to countries outside Jersey, the European Union and the European Economic Area in order to perform our contract with you. Normally we will only transfer your data to a country where there is an adequacy decision by the European Commission in respect of those countries. This means that the countries to which we transfer your data are deemed to provide an adequate level of protection for your personal information. Where we propose to transfer your data to a country that does not have an adequacy decision, we will ensure that your personal information is protected through the use of appropriate contractual terms or other means permitted by law.

7. Website and Personal Data

We may request and collect through the website certain personally identifiable information in respect of any person to whom our services may relate from time to time such as name, phone number, fax number and e-mail address. All personal data is processed in accordance with the applicable law in relation to data protection applicable in the jurisdiction in which we are processing such information.

The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") and may be transferred to, held by and processed by third parties including governmental organisations or bodies. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the provision of support services. By submitting your personal data to us through the website, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to make sure that your personal data is treated securely and in accordance with this privacy notice. You should be aware that the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Save as set out in this section 7 above, we will only disclose information collected on and through the website where we have your prior written approval, where we are compelled to do so by applicable law, where it is necessary to protect the interests of the Affinity Private Wealth group, where the information is already in the public domain, where it is deemed to be in the public interest or where it is necessary to promote fraud prevention. We may make information concerning users of the website available to law enforcement personnel and agencies when requested to do so or as required by applicable law. By providing any personal data to the website, you fully understand and unambiguously consent to the transfer of such personal data to, and the collection and processing of such personal data in Jersey and other appropriate countries or territories.

8. Website and Cookies

Cookies

We gather information from users of this website automatically and when you decide to provide us with information, for example, when you complete a form on www.affinitypw.com. This information is treated with confidence, and is only used by Affinity Private Wealth as per the terms of this Privacy Notice.

We may use "cookies" to keep, and sometimes track, information about you.

About cookies

Cookies are small text files which are downloaded to your computer or mobile device when you visit a web site or application. Your web browser (such as Internet Explorer, Mozilla Firefox or Google Chrome) then sends these cookies back to the website or application on each subsequent visit so that they can recognize you and remember things like personalised details or user preferences. Cookies do not damage your system. You can reset your browser so as to refuse any cookie or to alert you to when a cookie is being sent.

To improve your experience and to make our service to you better we use cookies for the purposes of system administration and analytics of our website. This gives us information about the number of visitors to different parts of our website. We may use cookies to customise your experience on the website. We may also use cookies to record how many times you have visited the website and what pages you have accessed. You may, however, disallow receiving cookies at any time by activating the setting in your web browser which allows you to refuse the setting of cookies. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our website. It is not our intention to use cookies to retrieve information that is unrelated to the website or your interaction with the website.

We may collect information about your computer, including where available your IP (Internet Protocol) address, operating system and browser type to help diagnose problems with our server, and to administer the website. An IP address is a number that is assigned to your computer when you use the Internet. This information does not contain any personally identifiable information about you. Your IP address is also used to help identify you during a particular session and to gather broad demographic data.

We do not share this data with third parties. Our cookies do not store sensitive information such as your name or address, they simply enable us to see behaviour on the website to help us improve your experience. However, if you’d prefer to restrict, block or delete cookies from www.affinitypw.com, or any other website, you can use your browser to do this. Each browser is different, so check the ‘Help’ menu of your particular browser (or your mobile phone’s handset manual) to learn how to change your cookie preferences.

How to control my cookies

There are various ways that you can control and manage cookies which are discussed in more detail below. Please remember that any settings you change will not just affect www.affinitypw.com cookies. These changes will apply to all websites that you visit (unless you choose to block cookies from particular websites).

Managing cookies in my browser

Most modern browsers will allow you to:

• See what cookies you’ve got and delete them on an individual basis

• Block third party cookies

• Block cookies from particular websites

• Block all cookies from being set

• Delete all cookies when you close your browser

You should be aware that any preferences will be lost if you delete cookies. This includes where you have opted out from cookies, as this requires an opt-out cookie to be set. Also, if you block cookies completely many websites will not work properly and some functionality on these websites will not work at all.

Managing analytics cookies

It is possible to opt out of having your anonymised browsing activity within websites recorded by analytics cookies. www.affinitypw.com uses Google Analytics and you can opt out of their cookies by visiting the Google Analytics opt-out page. Please note that this will take you to Google Analytics website and generate a ‘no thanks’ cookie, which will stop any further cookies being set by those third parties.

Further information about cookies and how to manage them If you’d like to learn more about cookies in general and how to manage them, visit aboutcookies.org*

*Please note that we are not responsible for the content of external websites.

9. Contact Us

If you have questions or concerns regarding the way in which your personal information has been used, please contact us by email at connect@affinitypw.com. Alternatively you can write to us at Affinity Private Wealth, 27 Esplanade, St. Helier, JE4 9XJ, Jersey.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the Jersey data protection authority which may be contacted as follows:

Address: Office of the Information Commissioner 2nd Floor 5 Castle Street St Helier Jersey JE2 3BT

Telephone: +44 (0)1534 716530

Email:         enquiries@jerseyoic.org

website:     www.jerseyoic.org

10. Changes to the Privacy Notice

You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time and changes and additions to this privacy notice are effective from the date on which they are posted. Please review this privacy notice from time to time to check whether we have made any changes to the way in which we use your personal information.