BKS Privacy Notice

MAY 2018

This website is operated by BKS Family Office Limited (“BKS”) of Second Floor, Charles Bisson House, 30-32 New Street, St Helier. Jersey JE1 8FT also referred to in this Privacy Notice as “we” or “us”. BKS is committed to protecting and respecting your privacy. This privacy notice describes how we will collect and process data, whether on individuals (including personal data in respect of individuals who are clients, intermediaries or other third parties that BKS interact with, or any individual who is connected to those parties) or otherwise and the rights you have in relation to your information.

We may collect information from you about your preferences through your use of this website, when you request information from us, or engage with us for professional services, or as a result of your relationship with one or more of our clients.

By using any of our services, including this website, and by providing us with any personal information, you are consenting to the use of your personal information as set out in this Notice. Please do not send us any personal information if you do not want that information to be used in this way.

References in this notice to “your information” are also to personal information that you provide to us. BKS is the data controller of any information provided via this website or through engaging with us for professional services and our contact details together with details of our registration with the Jersey Office of The Information Commissioner are set out below.

INFORMATION WE COLLECT

BKS processes data in order to provide and market our professional services, we are regulated by the Jersey Financial Services Commission to conduct trust company business and funds services business.

When you use our website: BKS may ask for and collect from you personally identifiable and other information at certain points via this website, for example, on our “further Information” button or “sign up to our newsletter” online form. Depending on the information and/or services you request, you may be asked to provide your name, email address and other information. In addition to the information you knowingly provide, BKS collects the domain names and IP addresses of its visitors, along with usage statistics, such as what pages your device visited and the time that you visited our website. This data may be used to promote our services. BKS may combine this information with the personally identifiable and other information it collects.

When you use our services: BKS will collect and process data you provide directly to us. The types of data we may collect includes:

From our contacts (collectively intermediaries, client/potential client, media and marketing contact, industry body, supplier) details, including names, job titles, email addresses, postal addresses and telephone numbers. Information required for BKS to meet legal and regulatory requirements, in particular in respect of anti-money laundering information, including information on source of wealth and source of funds. Information provided in the course of the provision of our services (for example, customer due diligence, tax information, and family and wealth information). Financial Information, such as payment related information. Professional interests and events that are attended. Meetings with BKS and visits to our offices. Any other information that you may provide to us.

HOW WE USE YOUR INFORMATION

At BKS we are committed to protecting and respecting your privacy and will only use your personal information:

to enter into client relationships and provide and improve our trust company services or fund services to you:

to compile anonymous statistics, for example, website usage statistics;

to market our services;

to manage our client, intermediary and other business relationships;

to fulfil our regulatory and legal obligations;

to process and respond to inquiries;

to alert you to new features, special events, and service offerings; and

for other legitimate business purposes.

EMAIL MARKETING LIST AND MARKETING MESSAGES

We operate an email mailing list program, used to inform you about products, services and/or news we supply/publish through our newsletters. You can change your preferences for receiving newsletters, emails and other information from us at any time. You can unsubscribe at any time through an automated online service or, if this is not available, by using the address below. Email marketing messages may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored subscriber data.

HOW AND WHY WE SHARE YOUR INFORMATION

Please note that we may on occasion be required to share your information with other third parties who provide services to us or on your behalf. Some examples of the potential recipients of your information are: Other providers of services (such as banks or other financial institutions, legal or tax advisors), agents or service providers of BKS, third parties whom BKS engages for hosting events, regulators or other governmental or supervisory bodies with a legal right to the material, any registrar of a public register where the data is to be included in a public registry.

This may entail a transfer of your information from a location within the European Economic Area (the “EEA”) to outside the EEA, or from outside the EEA to a location within the EEA. The level of information protection in countries outside the EEA may be less than that offered within the EEA, however we have procedures in place to ensure the protection of your information. We have taken steps to ensure that all such entities keep your personal information confidential and secure and only use it for the purposes that we have specified and have informed you of.

CONFIDENTIALITY

We acknowledge that the information you provide may be confidential. We do not sell, rent, distribute or otherwise make personal information commercially available to any third party, except that we may share information with our service providers for the purposes set out in this Privacy Notice. We will maintain the confidentiality of and protect your information in accordance with our Privacy Notice and all applicable laws.

COOKIES

Upon entering the BKS website your computer may automatically be issued with a Cookie. This is a file that identifies your computer (but not your individual identity). The information we obtain may include your Internet Protocol or “IP” address (a unique number assigned to each computer connected to the Internet), the date, time and duration of your visit. BKS utilise Google Analytics, a web analysis service provided by Google, to better understand your use of our Website. BKS will onlythis information for the purpose of monitoring the use of its website and may update the website accordingly to make it more user-friendly.

RIGHT TO REFUSE COOKIES

You have the option to deactivate Cookies within your Internet settings. The procedure for doing so will vary depending on the system you are operating. By way of example, if you are using Internet Explorer 6.0 to browse the Internet, you may deactivate Cookies by selecting ‘Tools’, ‘Internet Options’, choosing the ‘Privacy’ tab, clicking on ‘Advanced’, checking the ‘Override Automatic Cookie Handling’ box, and choosing ‘Block’ or ‘Prompt’ as appropriate

HOW WE PROTECT INFORMATION

BKS attempts to protect against the loss, misuse and alteration of your personal information. BKS has implemented reasonable administrative, technical and physical measures to protect your personal information.

YOUR RIGHTS

Data subjects in the European Union (or any jurisdiction with equivalent legislation to the European Union General Data Protection Regulation (“GDPR”), such as Jersey) have certain rights in respect of their personal data.

Any individual wishing to exercise any rights under the Data Protection (Jersey) Law 2018 and the Data Protection Authority (Jersey) Law 2018 or other GDPR legislation (including the right to withdraw any consent to processing previously given; the right of access to data; or to have data corrected, updated, rectified or erased; or for access to data to be restricted or provided to any third party; or to object to any particular processing) should send the request in the first instance to info@bksfamilyoffice.com

In any case in which an individual chooses not to provide any personal data or where any of the rights set out above are exercised to limit the processing of personal data BKS may be unable to provide relevant services, or there may be a restriction on the services which can be provided.

TRANSFERRING INFORMATION WHEN THERE IS A CHANGE TO OUR BUSINESS

If in the future we re-organise or transfer all or part of our business we may need to transfer your information to new BKS entities or to third parties through which the business of BKS will be carried out.

IF YOU DO NOT WANT TO RECEIVE INFORMATION FROM US

If you receive marketing materials from us, you may withdraw your consent for us to send these to you at any time and free of charge by sending an e-mail to info@bksfamilyoffice.com. You may also unsubscribe from our newsletter by clicking on the unsubscribe button.

CHANGES TO THIS NOTICE

From time to time, we may change this Notice. Changes to this Notice are effective as of the effective date stated above, and indicates the last time this Notice was revised or materially changed. Your continued use of this website indicates your consent to the changes to this Notice.

CONTACT INFORMATION

If you have any questions in relation to this Privacy Notice, or if you would like to contact us to exercise your rights as stated in this Privacy Notice, you may contact us at info@bksfamilyoffice.com

BKS is registered with the Jersey Office of the Information Commissioner Information under the following OIC Registration Number: 18249