Introduction

This privacy notice describes how Zobec collects, uses and shares the information you provide to us and the information we collect in the course of operating our business.

Zobec consists of Zobec Trust Company Limited, Zobec Services Limited, and CAMMCO Limited. In this Notice, where we refer to “Zobec” (or “we”/”us”/”our”), we mean each of the relevant members of Zobec as engaged by you.

References in this notice to “your information” are also to personal information that you provide to us or which we otherwise gather in the course of operating our business.

The Information We Collect

We may collect and process various types of personal data about you, including:

  • Name, address, email address, telephone number and other contact information;
  • Date and place of birth;
  • Nationality;
  • Gender;
  • Occupation;
  • Your professional and employment information (which may include your level of education and professional qualifications, your employment, employer’s name and details of directorships and other offices which you may hold);
  • Your family relationships (which may include your marital status, the identity of your spouse and the number of children that you have);
  • Copies of identity documents (such as passport, national ID card, driver’s license, employee identification numbers);
  • Utility bills and/or bank statements;
  • Financial information, sources of wealth and your assets (which may include your bank details and your credit history);
  • Tax residency;
  • Details of shareholdings and other assets which are legally or beneficially owned by you;
  • Details of directorships and information required to be held under applicable companies legislation;
  • Details of people or organisations which may be connected to you (by family or otherwise);
  • Your personal identification information (which may include your name and passport information, personal data relating to claims, court cases and convictions, politically exposed person (PEP) status, personal data available in the public domain and such other information as may be necessary for Zobec to provide its services and to complete its CDD process and discharge its anti-money laundering and anti-criminal financing obligations);
  • Technical data such as your Internet Protocol (IP) address, login data, browser plug-in types and versions, operating system and platform and any passwords and user names which you are required to create when accessing any of our password protected platform services.  To learn more about our use of cookies or similar technology, please visit our cookies policy which can be found here: https://www.zobec.bm/cookies-policy/
  • Any other personal information that you may provide to us.
  • We may also collect and process personal data regarding people connected to you, either by way of professional (or other) association or by way of family relationship.
  • If you apply for a position with us we may collect personal information relating to your past employment, professional qualifications and education, your nationality and immigration/residential status, opinions from third parties about you (such as references) and other details about you which may be gathered during the recruitment process.  We may also review publicly available information about you on your social media accounts.

Please note this list is not exhaustive and that we may also collect and process other personal data to the extent that it is useful or necessary for the provision of our services.

Where We Obtain Your Personal Information

We collect your personal information from the following sources:

  • personal information which you give to us directly, such as:
    • through your use of this website
    • as part of such other forms and documents as we may request that are completed in relation to the administration/management of any of our services
    • information gathered through the processing of client due diligence (e.g. passports and proof of address etc.) carried out as part of our compliance with regulatory requirements
    • any personal information provided by way of correspondence with us by phone, e-mail or otherwise
  • personal information we receive indirectly from third party sources, such as:
    • entities in which you or someone connected to you has an interest
    • your legal and/or financial advisors
    • financial institutions who hold and process your personal information
    • credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements
    • information that is publicly available over the internet
    • personal information received in the course of dealing with advisors, regulators, official authorities and service providers by whom you are employed or engaged or for whom you act.

Information That We Collect Through our Website

You are not required to provide any personal information on the public areas of our website; however you may choose to do so by completing any of the forms which are included on the following pages:

  • Homepage
  • Contact

In addition to the information you knowingly provide, Zobec collects the domain names and IP addresses of its visitors, along with usage statistics, analytics and browsing history.  This data is used to promote our services.  Please see our cookies policy for more details about this.  You may also provide us with personal information if you contact us by email, telephone or letter.

How We Use Your Information

At Zobec we are committed to protecting and respecting your privacy.  We provide trust, corporate and accounting services to our clients and we use your personal data for those purposes.  Normally the purposes for which we use your personal data will be clear when we collect that data.  We may hold and process your personal data on the following lawful grounds:

  • to perform a contract which we may have with you
  • to comply with our legal and regulatory obligations
  • for our legitimate business purposes

Your personal information may be processed for the purposes set out below:

  1. to conduct administrative or operational processes within our business and/or our service providers;
  2. to communicate with you as necessary in connection with our services;
  3. to provide you with personalised information;
  4. to provide and improve our services;
  5. to establish, exercise or defend the legal rights of Zobec or for the purpose of legal proceedings;
  6. to process and respond to requests, enquiries or complaints received from you or someone connected to you;
  7. to comply with legal or regulatory obligations imposed on us (including but not limited to AML/ATF/CFT obligations);
  8. to collect, process, transfer and store customer due diligence, source of funds information and verification data under applicable anti-money laundering and terrorist financing laws and regulations;
  9. to liaise with or report to any regulatory authority (including tax authorities) with whom we are either required to cooperate or report to, or with whom we decide or deem it is appropriate to cooperate in relation to the services we provide; and
  10. to review and process your application should you apply for a position with us.

How and Why We Share Your Information

Within Zobec

We share personal information within the Zobec Group of Companies.  As a result, your personal information may be shared with members of the Zobec Group of Companies other than those relevant members as engaged by you.

All Zobec staff agree to maintain the personal information obtained by us subject to conditions of confidence.  Only relevant staff are permitted access to customer personal information.  We disclose only the personal information that is necessary to deliver the services you require to those staff relevant to the task.  Zobec has a contract in place that requires those individuals to keep your personal information secure.

Outside of Zobec

We may also share your personal information outside Zobec. This may include disclosures to:

  • third party agents, suppliers or contractors, in connection with the processing of your personal information for the purposes described in this policy, which may include, but is not limited to:
    • Information Technology (IT) and communications service providers (including, without limitation, our software and/or platform providers in order to provide and maintain the performance of our services)
    • our own advisers such as auditors, accountants and legal advisors which we may instruct from time to time
  • third parties relevant to the services that we provide, which may include, but is not limited to:
    • counterparties to transactions
    • banks, investment managers and other custodians
    • other professional service providers
    • regulators
    • law enforcement agencies
    • governmental institutions
    • tribunals and courts
  • to the extent required by law, regulation or court order, for example if we are under a duty to disclose your personal information in order to comply with any legal obligation such as our anti money laundering and anticriminal financing (AML/ATF/CFT) obligations
  • we may disclose your personal information for the purposes of seeking references and confirmation of the details which you have provided should you apply for a position with us.

International Transfers

Where we transfer your personal information overseas, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information.  This can be done in a number of different ways, for instance:

  • the country to which we send the personal information may have been assessed by the relevant Bermuda Ministry, on the recommendation of the Bermuda Privacy Commissioner, as providing a comparable level of protection for personal data
  • we may employ contractual mechanisms, corporate codes of conduct including binding corporate rules, or other means to ensure that the recipient provides a comparable level of protection

In other circumstances, the law may permit us to otherwise transfer your personal information overseas.  In all cases, however, any transfer of your personal information will be compliant with applicable data protection law.

You can obtain more details of the protection given to your personal information when it is transferred overseas by contacting us using the details set out below.

Retention of Personal Information and Security

Your personal information will be retained for as long as required:

  • for the purposes for which the personal information was collected
  • in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations
  • as required by data protection laws and any other applicable laws or regulatory requirements.

We will ensure that the personal information that we hold is subject to appropriate security measures.

Access to and Control of your Personal Information

You have the following rights in respect of the personal information about you that we process:

  • the right to access and port personal information
  • the right to rectify personal information
  • the right to restrict the use of personal information
  • the right to request that personal information is erased
  • the right to object to processing of personal information.

You also have the right to lodge a complaint with us about the processing of your personal information.  See our complaints process here: https://www.zobec.bm/client-complaint-process/

Where we have relied on consent to process your personal information, you have the right to withdraw consent at any time.

If you wish to exercise any of the rights set out above, please contact us using the details set out below.

Inaccurate or Amended Information

Please let us know as soon as possible if any of your personal information changes (including your correspondence details).  Failure to provide accurate information or to update information when it changes may have a detrimental impact upon our ability to provide services to you.

Questions and Contact Information

If you have any questions in relation to this notice please contact our Designated Privacy Officer, April Thomas, by email at athomas@zobec.bm

Changes to This Policy

We may change this policy from time to time by updating this page.  You should check this page from time to time to ensure you are happy with any changes.  We last updated this policy on January 21, 2022.