Privacy Statement

The Kasel Asset Management is a global provider of fiduciary and administration services to corporate, institutional and private investors and to private individuals. This global privacy notice ("notice") explains how we collect, manage and protect your personal data if we need to process it as a data controller for the purposes of providing services to our clients. References to "we", "us" and "our" in this notice are to one or more members of the Kasel Asset Management.

The Kasel Asset Management consists of Kasel Asset Management, a company incorporated in Jersey with registered number 52417, whose registered office is at 26 New Street, St Helier, Jersey JE2 3RA and its subsidiaries, its ultimate holding body, all subsidiaries of its ultimate holding body and any corporate entity managed or controlled any of those entities. A full list of all the members of the Kasel Asset Management can be found here. You can contact any member of the Kasel Asset Management using the details provided on our here. You can also contact our Data Privacy Officer using the details provided at the end of this notice.

We collect and process your personal data if you are:

• a client that is an individual receiving services in your own capacity (an "individual client"), for instance, related to a trust or a foundation, from us; or

• associated with a corporate client because you are (for instance) an owner, director, officer, employee or contractor of the corporate client, or an investor in it, or if you are the subject of, for example, share plan administration services that we provide to our client, your employer.

We also collect your personal data if you represent other entities or organisations that we deal with, such as advisers, governmental and judicial bodies, regulators, suppliers or anyone that makes any form of enquiry in relation to us or our services or if you personally make any enquiry in relation to (for instance) our services or employment with us.

If you are an individual client, the data controller of your personal data is the member of the Kasel Asset Management named in the engagement agreement you have agreed with us.

If you are not an individual client and a member of the Kasel Asset Management is a data controller in relation to personal data collected from you, the data controller is the member of the Kasel Asset Management which has collected that personal data.

This notice does not apply to the collection or use of personal data by any member of the Kasel Asset Management as a data processor acting on instructions from a client. Where this applies, the client will be the data controller and its privacy notice and/or the terms of an agreement as to processing agreed between us will apply.  
  

Purpose of Data Protection

The purpose of data protection law is to protect your rights and privacy when we process your personal data. Personal data is any information relating to an identified or identifiable natural person. A person is "identifiable" if he or she can be identified, directly or indirectly, not only by things such as a name or an identification number, but also by things such as location data or some factor specific to (for example) the physical, physiological or social identity of that person.

More common examples of personal data include names, identification numbers, contact information, identity documents, medical records and photographic images and it may be contained in written document or in a recording, voicemail, for example. "Processing" covers any activity involving personal data and includes such things as the collection, recording, storage, adaptation, use, disclosure and destruction of personal data.

Because of the broad definition of "processing", we will in many cases need to start processing personal data about you before you or an entity with which you are associated or otherwise connected, actually become(s) a client or a supplier, as the case may be. Therefore, where the context allows, references in this notice to "clients", "suppliers" and others are to be read as including references to potential clients, suppliers and so on, even if you or they never actually become(s) a "client" or a "supplier" and so on. The only exception to this is in relation to "potential employees", who are dealt with separately below.  
  

Data We Collect About You

Clients & Persons Connected to Clients

If you are an individual client, are associated with a corporate client1 or are otherwise connected with  
client (whether private or corporate) because (i) you are a legal or beneficial owner, investor, a settlor,  
protector or beneficiary or (ii) you are a director, officer, employee or contractor of a client or (iii) you  
are the subject of, for example, share plan administration services that we provide to our client, your  
employer, we collect and process your personal data for various purposes connected with our  
services.

What personal data we collect and for what purpose will depend on our relationship with the client in  
question and/or you but will include:

• Name and Contact Details: Information that we require for the purposes of managing our relationship, including your names and your postal addresses, email addresses and telephone numbers.

• Due Diligence & Regulatory Details: Information that we require to meet our legal and regulatory obligations, particularly anti‐money laundering legislation, and to assess the risk associated with providing services to the client in question, including:

1. Identity information including your current and former names, aliases, date of birth, country of birth, place of birth, gender, nationality and a copy of your valid passport and/or birth certificate (including issue date and expiry date, where applicable).

2. Documents providing proof of your identity and address(es), such as copies of government issued documents, bank statements, utility bills and similar documents.

3. Detailed tax status information, including your tax domicile, tax identification number, copies of tax returns and tax advice received.

4. Proof of the source of your wealth and funds, such as bank statements, pension plans, property sales agreements and loan documents.

5. Occupation and employment information, including details of legal entities you are employed by or associated or otherwise connected with.

6. Details of criminal convictions and disqualifications, history of bankruptcy and details of investigations by any official body and/or if you are named on a sanctions list.

7. Details of involvement in high‐risk or high‐profile activities and of any activities of a political nature.

8. Other due diligence information gathered from checking tools we use and from searching information in the public domain.

• Share Plan Details: If you participate in an employee share plan which we administer on behalf of your employer, we will also collect information such as the number of shares that you own and their value at any particular point in time.

• Records of Correspondence: personal data contained in communications that take place between you and us and/or the client in question and us, including emails, letters, meetings minutes and telephone call and voicemail recordings.

• Other information: Additional information that (a) you provide to us or that the client in question (or someone else on its behalf) to provides us; (b) we collect; or (c) we create when providing services to the client in question. We collect personal data from information we learn about you through our relationship and from you from third parties, including the client's professional advisers, due diligence and risk assessment screening service providers and from the public domain, including from internet searches.

The types of data we collect may include data relating to your race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health and your sex life or sexual orientation ('special category personal data') and data relating to criminal convictions or offences.

1 In this notice a "corporate client" includes any entity, organisation or other body, whether incorporated or  
not, that is not an individual that is a client of Kasel in his or her own capacity.  

Professional Adviser, Regulators & Suppliers   

We work with entities or organisations that provide professional advice or services to us or to our clients, those that supervise and regulate us, and our clients and other suppliers of products and services to our business. We will collect personal data about you if you work for one of these organisations.   

The personal data that we collect will include professional and/or personal contact details, including addresses, telephone numbers and email addresses, and records of communications that take place between you and/or others at the organisation for which you work and us, including emails, letters, minutes of meetings and recordings of telephone calls (where made) and voicemails. In addition, we also, we collect personal data that you provide us with or that is created by us during our relationship with the entity or organisation for which you work.

Potential Employees  
If you are an applicant for a job with us (a potential employee), the personal data that we process about you will include:

• your name, address and contact details, including telephone numbers and email address(es);

• details of your qualifications, skills, experience and employment history;

• information about your current level of remuneration, including entitlement to benefits;

• whether or not you have a disability that we may need to make adjustments for during the recruitment process;

• information about your entitlement to reside and/or work in the place where you have applied for a job; and

• equal opportunity monitoring information, including information about your ethnic origin, sexual orientation, health and religion or beliefs.

If your application for a job with us is unsuccessful, we will retain your personal data for 6 months after the date on which we inform you (or any recruitment agency through which you have applied to us) that your application was unsuccessful, unless you ask us to retain your details on file for a longer period. We will delete any personal information no longer required, and will do so in an appropriate and secure manner.

If your application for a job with us is successful, our retention of your personal data will be governed by our separate policy on staff personal data, which will be made available to you by our HR department as part of your becoming a member of staff.

Enquirers & Website Visitors  
If you contact by us by telephone, email, using a contact form or via our social media channels we will collect the personal data that you provide to us and use it to respond to your enquiry. This personal data typically includes your name, your organisation and your professional and/or personal contact details.

When you visit our website, we will automatically collect data about you, including:

• technical information including the Internet Protocol (IP) address used to connect your computing device to the Internet, your browser type and version, time zone setting, operating system and platform;

• information about your visit, which may include the pages viewed and page response times; and

• your country of location by reference to a look‐up of your IP address against public sources.

Our website also uses cookies and/or similar technologies to collect and store certain information about your interaction with our website.

Marketing Communications  

 
If you subscribe to our marketing communications or your details have been otherwise lawfully added to one of our contact lists, we will collect and process your name, job title and company name, location and contact details in order to provide you with promotional update communications about us or our services.