We respect privacy and your rights to control your personal data. Our principal guidelines are simple. We will be clear about the data we collect and why. We do not and will not sell your data to Third Parties. This Privacy Notice describes why and how we collect and use your personal data and provides information about your rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this Privacy Notice, or as otherwise stated at the point of collection.

In this Privacy Notice, your information is sometimes called “personal data” or “personal information”, and is any information relating to an identified or identifiable living person. We also sometimes collectively refer to handling, collecting, protecting or storing your personal information as “processing” such personal information. We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.

When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please go to the relevant sections of this Notice.

WHO WE ARE

This Privacy Notice is issued by Sentient International Limited (collectively referred to as “we”, “us” and “our” in this Privacy Notice), the data controller.

We gather and process your personal information in accordance with this Privacy Notice and in compliance with the relevant data protection Regulation and Laws. This Notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

INFORMATION THAT WE COLLECT

We process your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this Notice.

We may collect and use some or all of the following types of personal data about you and, in some circumstances, your spouse, civil partner, partner or dependents:

• Your full name, address and contact details;
• Your date of birth;
• Your gender;
• Your marital (or relationship) status;
• Your National Insurance Number / Tax Identification Number;
• Your passport number;
• Details of your bank account;
• The source of your wealth;

You may also need to provide us with personal data relating to other people. When you do so, you will need to check with them that they are comfortable for you to share their personal data with us, and for us to use it in accordance with this Privacy Notice.

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.

We may collect information in the below ways:

• You may provide information directly to us;
• Third Parties may provide personal information to us; and
• We may also capture certain personal data in the public domain.

HOW WE USE YOUR PERSONAL DATA

We take your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by Law. We only retain your data for as long as is necessary and for the purpose(s) specified in this Notice. Most commonly, we will use your personal data in the following circumstances, and on the following legal bases:

• In the performance of the contract we have entered into with you;
• Where required for your product or service;
• Where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world;
• With debt collection agencies;
• With credit reference and fraud prevention agencies;
• With other companies that provide you with benefits or services associated with your product or service;
• Where required for a proposed sale, reorganisation, transfer, financial arrangement, asset disposal or other transaction relating to our business and/or assets held by our business;
• In anonymised form as part of statistics or other aggregated data shared with third parties; or
• Where permitted by law, or it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed.

We may less often also need to use your information to establish, exercise or defend our legal rights or on the basis of your consent where you have subscribed to any of our mailing services.

YOUR RIGHTS

You have the right to access any personal information that we process about you, and to request information about:

• What personal data we hold about you (commonly known a “data subject access request”);
• The purposes of the processing;
• The recipients to whom the personal data has/will be disclosed;
• How long we intend to store your personal data for; and
• If we did not collect the data directly from you, information about the source.

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. Where consent is the basis for holding your information, you have the right to withdraw that consent at any time.

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; as well as to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object on those grounds. In addition, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use, currently we do not use any automated decision-making.

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. If your request is made by electronic means, we will respond using the commonly used electronic form unless you specifically requests otherwise. When requested, and provided that it is practical and commercially feasible to comply with the request and there is no legal or regulatory need for us to keep the information, we will delete identifying information from current operational systems.

To request access to any personal data we hold, please contact us by telephone on +44 (0) 1624 616544 or write to us at Suite 3, 1st Floor, The Jet Centre, Isle of Man Airport, Isle of Man, IM9 2RJ.

SHARING & DISCLOSING YOUR PERSONAL INFORMATION

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this Notice or where there is a legal requirement.

Examples of those we may share your personal data with are: Regulators, Tax authorities, professional advisors e.g. financial advisers, lawyers, accountants and tax advisers and other financial institutions such as banks, insurance and investment companies.

TRANSFERRING INFORMATION

We may transfer your information to organisations in other countries on the basis that anyone to whom we pass it protects it in the same way we would and in accordance with applicable laws.

In the event that we transfer information to countries outside of the European Economic Area (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway), we will only do so where:

a) the European Commission has decided that the country or the organisation we are sharing your information with will protect your information adequately;
b) the transfer has been authorised by the relevant data protection authority; and/or
c) we have entered into a contract with the organisation with which we are sharing your information (on terms approved by the European Commission or our own Data Protection Authority) to ensure you information is adequately protected.

MARKETING INFORMATION – USING YOUR CONTACT DETAILS

Unless you have told us that you do not want to hear from us, from time to time, we may send you important notices about the products or services you have asked us to provide, changes to our policies or terms and conditions, or changes to laws or regulations that could affect the service we provide by mail, phone, email, text and other forms of electronic communication. This is important information that keeps you informed about the products or services you have asked us to provide.

We may also send you emails containing newsletters and articles, information about additional products or services provided by Sentient, or invitations to events we are organising, attending or sponsoring. You can opt-out of receiving these messages by contacting us here or by clicking on the unsubscribe link in those emails.

If you change your mind about how you would like us to contact you or you no longer wish to receive this information, you can tell us at any time using the contact details below.

We never sell or lease your personal information or share it with other organisations for marketing purposes.

SOCIAL MEDIA

Sentient uses a number of social media sites including Facebook, Twitter, LinkedIn and Instagram. We receive some information about you from these sites when you interact with us or access our social media content. The amount of information we receive is governed by your social media account privacy settings and the policies and procedures of each social media platform.

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. To determine the retention periods, we will take into consideration what is reasonable to comply with our legal obligations and our legitimate interest in being able to properly respond to future queries/complaints.

LODGING A COMPLAINT

We only process your personal information in compliance with this Privacy Notice and in accordance with the relevant data protection laws. We hope that you won’t ever need to, but if you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, please contact our Data Protection Officer in the first instance:

Data Protection Officer
Sentient International Limited
Suite 3, 1st Floor
The Jet Centre
Isle of Man Airport,
Isle of Man, IM9 2RJ

Tel: +44 (0) 1624 616544

You also have the right to lodge a complaint with the Isle of Man Information Commissioner, P.O. Box 69, Douglas, Isle of Man, IM99 1EQ Telephone: +44 1624 693260 Email: ask@inforights.im

CHANGES TO OUR PRIVACY NOTICE

This statement is subject to regular review and may be updated from time to time. We will inform you if we make any substantial changes to how we use with your personal data.

This Privacy Notice was last updated on 10 November 2021.

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