Who We Are
- Why we collect your personal information
- What information we collect and how we collect it
- Information we collect from our website
- Use of our App
- How we use your personal data
- Your rights
- Sensitive information
- Sharing and disclosing your personal information
- Safeguarding measures
- Transfers outside the Isle of Man and the European Economic Area
- Consequences of not providing your data
- How long we keep your data
- Lodging a complaint
Ramsey Crookall’s registered office is 38-42 Athol Street, Douglas, Isle of Man, IM1 1QH and is a company registered in the Isle of Man under company number 046435C. Ramsey Crookall is registered on the Information Commissioner’s Office Register; registration number N000209. Rene’s registered office is 38-42 Athol Street, Douglas, Isle of Man, IM1 1QH and is a company registered in the Isle of Man under company number 001751C. Rene is registered on the Information Commissioner’s Office Register; registration number N000641. We act as the data controller when processing your data. Our designated Data Protection Officer is Perry Downward, who can be contacted by post at Securities House, 38-42 Athol Street, Douglas, Isle of Man IM1 1QH or by email at firstname.lastname@example.org
Why we collect your personal information
We collect your personal information to meet our legal, statutory and contractual obligations and to provide you with our services. We will endeavour to never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this policy.
It is necessary to collect personal information when considering potential clients for our services or when considering 3rd party service agreements.
We collect personal information to manage any third party arrangements required in order to run our business and provide our services to you.
We collect personal information when considering any applications for employment or sponsorship.
What information do we collect from you and how do we collect it
In order to become a client of ours, there is certain information and documentation that we are required to collect in order to comply with our contractual, legal and regulatory responsibilities. This includes information about you like your name, address, date of birth, telephone number, email, some understanding of why you want to do business with us, some information about your wealth profile and a copy of your picture identity document and address verification document. We will collect this from you when you complete our registration form or through your contact with us whether in person or via email or other form of communication or from a third party like an intermediary. Some of this information might be used to undertake public source searches and searches against paid for databases in order that we can fully demonstrate compliance with relevant regulatory requirements.
Our contractual, legal and regulatory responsibilities extend to the automatic exchange of information for taxation purposes. Whilst a lot of the information that we collect, as set out in the paragraph above, is used for these purposes too, we also collect your tax identification number as we are required to use that for reporting purposes.
If you are seeking employment with us we will collect information about you including your name, address, date of birth, telephone number, email, previous employment history (which may include salary), education details, personal tax information, Isle of Man worker status and character references. We may collect information from publicly available sources such as the internet or public register.
Information that we collect from our website
We anonymise your IP data on our website. This means that we do not track your IP address and you remain anonymous. You will never need to provide personal information to access our website. Personal information will only be collected when you use the enquiry form and it will always be clear why that personal information is being obtained. The information you provide through the enquiry form is held securely and for the purpose of answering your enquiry. We only retain your data for as long as is necessary and in accordance with our retention policy. If you wish to obtain further information about our retention policy please contact our DPO at email@example.com
Use of our App
No additional personal data is required by us when you use our App. You cannot have access to the App unless you are a client of ours and have an account with us. Log on and password details are sent separately to enable you to use the App. The App does not display any details that can identify you and the only data currently available through the App is your asset holding position and value.
How we use your personal data
We take your privacy very seriously. We only retain your data for as long as is necessary and for the purpose(s) specified in this policy. We do not usually rely on ‘consent’ to process your personal data as there is usually a legal basis for the information we request. However, where we do process information based on consent, we will obtain consent on a case by case basis and you have the right to withdraw that consent at any time. The purposes and reasons for processing your personal data are detailed below:
- We collect and store your personal data in the performance of a contract or to provide a service or to respond to a request made via our website
- We collect and store your personal data as part of our legal obligation for tax reporting purposes
- We will occasionally send you marketing information where we have assessed that it is beneficial to you as a customer and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests
You have the right to access any personal information that we process about you and to request this information. If you wish to see the data processed about you by us, please contact firstname.lastname@example.org
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws. Where applicable, you have the right to data portability of your information.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
An important right that you have is the right to object to processing. This right applies where, after careful consideration, we have decided that it is in the legitimate interests of Ramsey Crookall and Rene to process data about you. We process data for our legitimate interests where it is necessary for the smooth operation of your account with us or where we are using your data for marketing purposes.
Some personal information is classed as sensitive under the Isle of Man Data Protection Legislation and Regulation and referred to as ‘Special Category’ data. This includes information about health, race, ethnic origin, political opinions, religious/philosophical beliefs, sexual orientation, trade union membership and genetic and biometric data.
During the normal course of business with you we do not need to collect sensitive data, however, sometimes we will be passed documents, for example court registered Enduring Powers of Attorney or Receivership documents, for your account which will be required by us to allow us continue our services to you.
Sharing and disclosing your personal information
Our client file may be selected by our auditors, regulatory body or bankers for review as part of any checks that they are required to carry out in relation to our compliance with laws, regulations or conditions of service. We will ensure, however, that these parties only have access to the data that they are obliged to review.
As noted above, we are legally obliged to exchange certain information with the Income Tax Division of the Isle of Man.
If as part of our service to you, we need to engage with professional advisers such as lawyers, accountants or tax advisors, some personal data may be shared with them for the purposes of obtaining the advice. We may also have to share personal data with any bank or investment house with which we are opening an account. We will ensure, however, that we only share the data that we need to and we will conduct appropriate due diligence in advance of sharing the data.
If you are a current or former employee, we may pass information to future employers who seek references about you. Future employers will need your consent to request a reference from us.
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this policy or where there is a legal requirement.
We take your privacy seriously and take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place. If you require any further information in relation to our security measures please contact email@example.com
Transfers outside the Isle of Man and EEA
It is not usually necessary during normal course of business to transfer your information outside the Isle of Man or European Economic Area (‘EEA’). However, in the event that it is necessary to transfer your information outside the Isle of Man or the EEA, it will be done so in accordance with the Isle of Man Data Protection Legislation and Regulation. These requirements include the condition that the recipient of your personal data must have the same level of protection in place as you are entitled to on the Isle of Man or in the EEA. We will advise you in the event that your personal data is to be transferred in this manner.
There are two exceptions to this; we utilise an email server that is hosted in Australia for the purpose of marketing information where we have assessed that it is beneficial to you as a customer and in our interests or where you have requested that we provide you with information such as our Daily Market Report. We have ensured that this provider uses the necessary level of protection for your information and abides by strict agreements and measures set out by us to protect your data and comply with the relevant Isle of Man Data Protection Legislation and Regulation. The email server that we use only acts on our instructions and will not pass your email address to any other party.
The other exception is if you, as a client, live outside the Isle of Man or the EEA and we are sending your personal information to you; this will be necessary in order for us to communicate with you and provide you with our services.
Consequences of not providing your data
You are not obligated to provide your personal information to us, however, as this information is generally required for us to provide you with our services, we will not be able to offer our services without it. Please note that you do have the right to object to our processing as set out above.
How long we keep your data
We only ever retain personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We will maintain records and data to comply with our statutory, legal and regulatory responsibilities as well as what we deem to be reasonable practice where there is no record keeping period set down in law or other rules. We will destroy client data in line with these retention periods and our commencement date for any retention period will normally be the end of the client relationship.
If you have specific queries in relation to retention periods, please contact firstname.lastname@example.org
Lodging a complaint
Ramsey Crookall & Co Limited
Mr Perry Downward
Securities House, 38-42 Athol Street, Douglas, Isle of Man, IM1 1QH
Telephone: +44 1624 673171
Isle of Man Information Commissioner
First Floor, Prospect House, Prospect Hill, Douglas, Isle of Man, IM1 1ET
Telephone: +44 1624 693260