STONEHAGE FLEMING SA

This Privacy Notice explains how Stonehage Fleming SA (“us”, “we”) and other companies in the Stonehage Fleming Group collect, use and disclose your personal data, and your rights in relation to the personal data being held by us and other Group companies.

We may amend this Privacy Notice from time to time, to reflect any changes in the way that we process your personal data. This Privacy Notice supersedes any previous version of this notice with which you may have been provided or have had sight of before the date at the end of the last section of this notice as well as anything to the contrary contained in any agreement with us.

Your rights

You have the following rights:

To obtain access to, or copies of, or details of, the personal data that we hold about you;
To require that we cease processing your personal data if the processing is causing you damage or distress;
To require us not to send you direct marketing communications;
To require us to erase your personal data;
To require us to restrict our data processing activities;
To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
To require us to correct the personal data we hold about you if it is incorrect.

The above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. Also, where a Group Company is located outside of the European Economic Area not all of these rights may apply.

If you have any questions about how we or any other Group companies use your personal data, or you wish to exercise any of the rights set out above, please contact our Privacy Officer or, where applicable, the Privacy Officer in the relevant jurisdiction. Contact details are set out in the last section of this Privacy Notice. If you are based in Switzerland and believe our processing contradicts the applicable data protection laws you may lodge a complaint with the Swiss Federal Data Protection and Information Commissioner, Feldeggweg 1, 3003 Berne, Switzerland (https://www.edoeb.admin.ch).

How we share your data

We may use other Group companies to provide services to you and we may share your personal data for the reasons set out elsewhere in this Privacy Notice. The companies in the Group (“other Group companies”) which may be involved in delivering services to you or processing your personal data in a related manner are:

Service	Company
Investment management, investment advice, treasury and dealing services	Stonehage Fleming Investment Management Limited (United Kingdom) Stonehage Fleming Dealing and Treasury (Jersey) Services Limited Stonehage Fleming Dealing and Treasury Services (UK) Limited Stonehage Fleming Investment Management (Suisse) AG Stonehage Fleming Investment Management (South Africa) (Pty) Limited Stonehage Fleming Investment Management (Liechtenstein) AG Stonehage Fleming Asset Management (Pty) Ltd (South Africa)
Financial services, estate administration, trust and other services and art management	Stonehage Fleming Financial Services Limited (United Kingdom) Stonehage Fleming (Israel) Financial Services Limited Stonehage Fleming Financial Services (Pty) Limited (South Africa) Stonehage Fleming Wealth Planning Limited (United Kingdom) Primafides (Suidde) SA Alto Trust Limited Heritage Trustees SARL Stonehage Fleming Executors Limited (South Africa) Stonehage Fleming Services (IOM) Limited (Isle of Man) Stonehage Fleming Trustees (Pty) Ltd (South Africa) Stonehage Fleming Trustees Limited (Isle of Man) Stonehage Fleming (Mauritius) Limited SF Trust (Liechtenstein) AG Stonehage Fleming SA (Switzerland) Stonehage Fleming (Canada) Incorporated Stonehage Fleming Fiduciary Limited (South Africa)
United States tax, legal advice and related services	Stonehage Fleming US LLC (United States) Stonehage Fleming Law US (United States) Stonehage Fleming Advisory (Pty) Ltd (South Africa) Stonehage Fleming Advisory (IOM) Limited (Isle of Man)
Insurance services	Stonehage Fleming Insurance Services Limited (Jersey)
Administration services	Stonehage Fleming Trust Holdings (Jersey) Limited SF Trust Protectors (Switzerland) SARL Chasseral (Directors) Limited Stonehage Fleming Secretarial Limited (Mauritius) Stonehage Fleming (Mauritius) Management Services Limited
Fund Administration, Corporate Trustee services	Stonehage Fleming Corporate Services Limited (Jersey) Stonehage Fleming Corporate Services Luxembourg S.A. (Luxembourg) Stonehage Fleming Corporate Services (Pty) Limited (South Africa) Stonehage Fleming (Mauritius) Corporate Services Limited Stonehage Fleming (Guernsey) Limited
United Kingdom tax and legal advice	Stonehage Fleming Law Limited (United Kingdom)

We may share your information with Group companies in Switzerland, Israel, Jersey, Liechtenstein, Luxembourg, Guernsey, Malta, the Isle of Man, the United Kingdom and Canada. These countries provide an adequate level of protection for your personal data. Where we share your data with one or more of our offices in a third country (i.e. a country that does not provide an adequate level of protection for your personal data) we make use of standard contractual clauses, as a safeguard, to protect your data, or will share your data with your explicit consent. The Group has offices in the following third countries: United States of America, South Africa, Monaco and Mauritius.

We may also share your personal data with other companies or service providers, in the above mentioned countries, that we have engaged to assist us in providing services to you. These companies or service providers may be located in jurisdictions which currently do not provide the same level of protection to your personal data as provided within Switzerland, for example the British Virgin Islands. Where we share your personal data with a company or service provider in a third country jurisdiction we will do so using standard contractual clauses, another available safeguard, or with your explicit consent.

If you wish to receive details regarding the companies or service providers which we have engaged to assist in delivering services to you or to entities in respect of which you are connected or have an interest and with whom we have shared your information please contact us at swissprivacyofficer@stonehagefleming.com

How we collect your data

We and other Group companies may collect your personal data in a number of ways, for example:

From the information you provide to us when you meet with us;
From an employee or employees of one of our Stonehage Fleming Group (“Group”) companies or from a family member;
When you communicate with us or when we communicate with you by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
When you or your agent complete or we complete on your behalf client on-boarding or application or other forms;
From other companies in our Group;
From intermediaries, your agents, advisers and individuals in the organisation with which you are associated;
From the trustee(s) of any trust in respect of which you are a settlor or a beneficiary or with which you are otherwise connected;
From your agents and advisers, insurance companies, fund managers, investment managers and custodians of your assets;
From publicly available sources or from third parties where we need to conduct background checks about you.

The categories of data we collect

We and other group companies may collect the following categories of personal data about you:

All Group companies	Your name, date of birth, passport or national identity card details; Country of birth, domicile and citizenship; Contact information such as residential or business address, email address and telephone number; Biometric data such as CCTV images when you visit our offices; Gender, marital status; Information about your employment, education, family, personal circumstances and interests; Information relating to your tax affairs including your tax status and tax identification number; Information, some of which is collected daily, to assess whether you may represent a money laundering, terrorist financing or reputational risk to the Group. This includes whether you are a Politically Exposed Person, are involved in a high risk business, have been arrested, charged or convicted of a crime, are on a sanctions list or expose us to tax, litigation, bribery or corruption risk. Information relating to you and your financial situation such as your industry and marketing segment, the services we offer which may be of interest, your net worth, income, expenditure, assets and liabilities, sources of wealth and your bank account details; Information about your knowledge and experience in the corporate or investment field; Information regarding your goals and objectives in connection with your wealth; With your consent, information concerning your health where relevant to services provided
Art services	Details of your art collection
Insurance services	Where you have provided your written consent, information concerning your health where you seek assistance in obtaining life insurance or medical cover; Information relating to risks and exposures which may include details of your assets and liabilities.
United States Companies	We do not knowingly request or collect personal data from any person under 16 years of age without prior verifiable parental consent. If you believe that your child under the age of 16 has provided personal data to us without prior verifiable parental consent, please email usprivacyofficer@stonehagefleming.com so that we can take steps to delete the personal data that she or he has provided as required in accordance with applicable law.

Basis for processing your data, how we use that data and with whom we share it

We may process your personal data because it is necessary for the performance of a contract to deliver the services you have engaged us for or in order to take steps at your request prior to entering into a contract.

Our other Group companies may also process your personal data where it is necessary for the performance of a contract to deliver the services we have engaged them for or in order to take steps at your or our request prior to entering into a contract.

	We and other group companies use your personal data for the following:	We and other group companies may share your personal data with the following:
This and other Group Companies	To prepare preliminary information or a proposal for you regarding the services we offer; To provide you with the services as set out in our terms of engagement with you or as otherwise agreed with you from time to time; To deal with any complaints or feedback you may have; To book transport from and to our offices when you are visiting us; For any other purpose for which you provide us with your personal data.	Your advisers or agents or employees of firms with which you are associated; Companies, partnerships, other entities or the trustees of trusts, and the directors and/or employees of such companies, partnerships, other entities or trustees of trusts, in respect of which fiduciary and/or administrative services are provided, and in respect of which you are connected or have an interest. Other third parties such as banks, intermediaries, insurance companies, fund managers, investment managers or administrators; Registered agents; Our advisers where it is necessary for us to obtain their advice or assistance; Companies within our Group; Payment processors where we are making payments on your behalf; Transport companies and travel agents; Our data storage providers.
Art services	To arrange for the insurance, acquisition, transportation and exhibition of art.	Insurance brokers where we are instructed to arrange insurance; Museums, galleries and auctioneers where you wish art to be exhibited; Storage facilities where you wish art to be stored.
Corporate finance	To provide you with corporate finance and/or direct investment opportunities or as otherwise agreed with you from time to time.	Potential counterparties and their advisers in relation to our corporate finance or direct investment opportunity services.
Stonehage Fleming Law Limited	To provide you with legal services.	Third party service providers who we may engage on your behalf, for example, e-disclosure service providers and/or forensic data investigators; Advisers or agents where it is necessary for us to obtain their advice or assistance, for example, foreign legal advisers and/or counsel or other specialists; The Office of the Public Guardian; Relevant tax authorities.

We and our other group companies may also process your personal data because it is necessary for our legitimate interests.

We and other group companies use your personal data for the following:

We and other group companies may share your personal data with the following:

To run, grow and develop our business;
To ensure a safe environment for our employees and visitors, including website visitors;
To provide client services;
To conduct market research and carry out business development activities;
To train our staff or monitor their performance;
For the administration and management of our business including carrying out internal group administrative functions and recovering money you owe to us;
To seek advice and guidance on our rights and obligations, such as where we require our own legal advice;
To make disclosures to external service providers and any regulatory authorities outside of the country where any structure includes an entity incorporated outside Jersey;
To mitigate the risks we face.

Our advisers, agents, settlors or protectors of trusts where it is necessary for us to obtain their advice or assistance;
With third parties and their advisers where those third parties are acquiring, or considering acquiring all or part of our business;
Any regulatory authority or service provider;
Our advisers where it is necessary for us to obtain their advice or assistance;
Our auditors where it is necessary as part of their auditing functions;
With third parties who assist us in conducting background checks;
With relevant regulators or law enforcement agencies if we are required to do so.

If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your personal interests or fundamental rights and freedoms which require protection.

We and our other group companies may also process your data for our compliance with a legal obligation which we and they are under.

We and other group companies use your personal data for the following:	We and other group companies may share your personal data with the following:
To meet our compliance and regulatory obligations, such as compliance with anti‐ money laundering and countering terrorist financing regulations, tax reporting and beneficial ownership reporting requirements.	Our advisers where it is necessary for us to obtain their advice or assistance; Our auditors where it is necessary as part of their auditing functions; With third parties who assist us in conducting background checks about you, such as whether you are on sanctions lists; With relevant regulators, tax authorities and law enforcement agencies where we are required to do so.

The retention of your data

We may retain your personal data for as long as necessary for the purposes for which it was collected, in order to provide you with services, to carry out our legitimate business interests, to meet our regulatory and legal obligations, and where otherwise required by law. We and other Group companies retain your personal data as follows:

United Kingdom

For a period of seven years after the termination of our relationship with you in case any claims arise out of the provision of our services to you. However:

Where we have collected personal data as required by anti-money laundering legislation, we retain your personal data for five years after the termination of our relationship, unless we are required to retain this information for a longer period by another law/regulation or for the purposes of court proceedings.
Where we have provided advice relating to a pension transfer, pension conversion, pension opt-out or free-standing additional voluntary contribution, we will keep your personal data relevant to this indefinitely as we are required to do so by the Financial Conduct Authority.
In certain circumstances we will retain your data for as long as we reasonably believe it is appropriate to do so in your or our interests.

Other jurisdictions

We retain your personal data for a maximum period of 10 years after the termination of our relationship with you in order to meet our regulatory and legal obligations. Where we act as trustees or directors we retain certain records indefinitely to demonstrate how effectively the entities have been managed.

Contact details

Switzerland

Privacy Officer: Sebastien Masgonty
By post: Rue Du Puits-Godet 12, PO Box 763, 2002 Neuchatel, Switzerland
By email: swissprivacyofficer@stonehagefleming.com
By telephone: +41 32 723 1038

Jersey

Privacy Officer: Paul Le Bihan
By post: Floor 4, Liberation House, Castle Street, St Helier Jersey, JE1 4HH Channel Islands
By email: jerseyprivacyofficer@stonehagefleming.com
By telephone: +44 1534 823 109

United Kingdom

Data Protection Officer: Cesare Milani
By post: 6 St James's Square, London SW1Y 4JU
By email: ukdataprotectionofficer@stonehagefleming.com
By telephone: +44 (0) 207 087 0136

United States

Privacy Officer: Jeff Hollownicsky
By post: 1700 Market Street, Suite 3010, Philadelphia PA19103
By email: usprivacyofficer@stonehagefleming.com
By telephone: +1 215 665 7270

Guernsey

Privacy Officer: Paul Le Bihan
By post: 3rd Floor, 1 Le Truchot, St Peter Port, GY1 1WD, Guernsey
By email: guernseyprivacyofficer@stonehagefleming.com
By telephone: +44 1534 823 109

Isle of Man

Data Protection Officer: Cesare Milani
By post: Falcon Cliff, Palace Road, Douglas, Isle of Man, IM2 4LB
By email: isleofmandataprotectionofficer@stonehagefleming.com
By telephone ‐ +44 207 087 0136

Israel

Privacy Officer: Roni Bar-Zeev
By post: 2 Zarhin Street, 5th Floor, PO Box 4214, Raanana, 4366507, Israel
By email: israelprivacyofficer@stonehagefleming.com
By telephone: +972 9 970 1000

Malta

Privacy Officer: Maha Arebi
By post: 4th Floor, Avantech Building, St Julian’s Road, San Gwann, SGN 2805, Malta
By email: maltaprivacyofficer@stonehagefleming.com
By telephone: +356 22486207

Monaco

Privacy Officer: Chris Durham
By post: Monte Carlo Sun, 74 Boulevard d’Italie, MC 98000, Monaco
By email: monacoprivacyofficer@stonehagefleming.com
By telephone: +377 97 97 31 80

Mauritius

Privacy Officer
By post: 1st Floor, Les Fascines Building – Block B, Vivéa Business Park, Rue des Fascines, Moka, Mauritius
By email: DPOMauritius@stonehagefleming.com
By telephone: +230 210 9334

South Africa

Information Officer
By email: sainformationofficer@stonehagefleming.com
By telephone: +27 21 301 0800

Luxembourg

Privacy and Data Protection Officer
By post: 58 Rue Charles Martel, L-2134 Luxembourg
By email: luxprivacyofficer@stonehagefleming.com
By telephone: +352 2744 7300

Liechtenstein

Privacy Officer: Thomas Stejskal
By post: Landstrasse 123, 9495 Triesen, Liechtenstein
By email: liechtensteinprivacyofficer@stonehagefleming.com
By telephone: +423 399 02 53

South Africa

Information Officer: Johann Louw
By post: 54 Glenhove Road, Melrose, Johannesburg, 2196, South Africa, or, First Floor, North Block, Waterway House, 3 Dock Road, V&A Waterfront, Cape Town, 8001, South Africa
By email: sainformationofficer@stonehagefleming.com
By telephone: +27 21 446 2132

APPOINTED REPRESENTATIVES

Our appointed representative in the European Union is Sturdon Holdings Luxembourg SARL. The Privacy Officer in Luxembourg may be contacted using the following email address or telephone number:

Email: luxprivacyofficer@stonehagefleming.com

Tel. +352 2744 7300

Our appointed representative in the United Kingdom is Stonehage Fleming Services Limited. The Data Protection Officer in the United Kingdom may be contacted using the following email address or telephone number:

Email: ukdataprotectionofficer@stonehagefleming.com

Tel. +44 207 087 0136.

Version: 8 August 2024

Privacy notice