This Privacy Statement explains and describes our practices for collecting, using, maintaining, protecting, and disclosing personal information that we may receive or that you may provide when you visit our websites. If you have additional questions regarding the processing of your personal information or information security, please contact us at enquiry@relyon-trustee.com.

Our Personal Data Policy applies to RelyOn Trustee Limited. In this PrivacyStatement, ‘RelyOn’ refers to RelyOn Trustee Limited. This Privacy Statement explains how RelyOn collects, uses, maintains, protects, and discloses personal information from our websites or as part of our services. Please note that depending on the nature of the services we provide to you, this Privacy Statement will be supplemented with specific privacy policies and notices as required by applicable laws.

‍

Types of Personal Information Collected

This Privacy Statement explains our practices with regard to“Personal Information” collected by RelyOn for its business purposes. Personal Information include any information that can be used (directly or indirectly) to identify, locate or contact you from that information alone or in combination with other information we process or can reasonably access. We may collect the following types of Personal Information:

• your personal identification information (which may include your name and passport information, your IP address, politically exposed person (PEP) status, personal data available in the public domain, details of your financial information, sources of wealth and your assets and such other information as may be necessary for RelyOn to provide its services and to complete its client due diligence process and discharge its AML/CFT obligations).
• "Contact Information" that allows us to communicate with you, such as your name, username, mailing address, telephone numbers, email address or other addresses that allow us to send you messages.
• "Relationship Information" that helps us do business with you, such as the types of products and services that we provide to you or that may interest you, information on your company’s size, geographic locations, creditworthiness  and demographics.
• "Transaction  Information" about how you interact with RelyOn, including purchases, inquiries, customer account information, and information about how you use the RelyOn’s websites and applications.
• if  you apply for a position with us we may collect 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 publically available information about you on your social media accounts.

We will not collect and process your sensitive personal information (which includes data relating to race or ethnic origin, religious beliefs, physical or mental health, or sexual orientation) unless we have obtained your explicit consent as may be required under applicable law.

‍

Methods of Collecting Personal Information

In the majority of cases, we collect Personal Information directly from you or from third parties. For example, we may collection your Personal Information from your authorised representatives and advisor(s), your employer, our corporate clients where we are providing services to them, our service providers of referees, in the case of prospective employees. We may ask you for Personal Information (includingContact Information and Relationship Information) when you interact with us, such as registering on our websites, signing up to receive a newsletter, or making a purchase. We may collect additional Relationship Information from third party search information suppliers who can help us better understand our customers.

We collect Transaction Information when you purchase services or products from RelyOn. We also collect Transaction Information when you visit our website, use our applications or contact us, such as for customer service purposes.

If you interact with us online, we use cookies and other technological tools to collect information about your computer and your use of our website and applications. We treat this information as Personal Information when it is associated with your Contact Information. For more information about cookies and other technologies, please see the section Cookies and Other Data Collection Technologies below.

‍

Use of Personal Information

RelyOn may use your Personal Information to:

• Fulfill your requests for services or products and for related activities, such as `service and product delivery, customer service, account management, support and training and to provide other services related to your relationship with RelyOn;
• Provide our corporate clients with services  or products and for related activities, such service and product delivery, customer service, account management, support and training and to provide other services related to their relationship with RelyOn;
• Provide you with direct marketing communications and offers for services and products from RelyOn and in some cases, our partners, including offers targeted based on your interests, business characteristics and location, in each case, subject to your consent (which includes an indication of no objection) where required under applicable law;
• Comply with laws, regulations, and guidelines applicable to us;
• Administer surveys, market research, and promotional events;
• Determine if you are eligible for certain products, services, or offers;
• Provide you with additional information that may be of interest, such as our news and announcements and technical service bulletins;
• Manage our everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, forum management, fulfillment, analytics, security and fraud prevention, corporate governance, reporting and legal compliance, business continuity and complaint, claim or litigation management; and
• consider job applicants for employment.

We may not always rely on consent as a legal basis for processing your Personal Information although we will seek your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

‍

If You Fail to Provide Personal Information

Where we need to collect Personal Information by applicable law or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with goods or services). In those circumstances, we may have to cancel a product or services you have with us. We will seek to notify you if this is the case at the relevant time.

Direct Marketing

In connection with direct marketing, RelyOn intends to use your Personal Information, which include but not limited to your name, contact information (such as phone number, email address and mailing address), business characteristics and geographical location in order to send to you marketing communications on the services and products that are offered by RelyOn from time to time through telephone, text (SMS), email, post, push notification and any other electronic means. Such services and products may include but not limited to business, corporate, investor, human resources & payroll, corporate trust & debt services, tax advisory and compliance, and governance advisory.

If at any time you do not wish for us to continue to use your Personal Information for direct marketing purposes and do not wish to receive any direct marketing materials, you may opt out from direct marketing by notifying us at the contact information set out below.

How and Why WeShare Your Information

We share Personal Information within RelyOn's international network. RelyOn may include disclosures or transfers to third party agents, suppliers or contractors, in connection with the processing of your Personal Information for the purposes described in this Privacy Statement. For example, we may disclose or transfer your Personal Information to third party agents who provide administrative, storage, information technology, security, communication, compliance, payment and other data processing services. Where necessary, RelyOn will endeavour to take reasonable steps to ensure that data processing agreements are entered into with such third party agents, suppliers or contractors to ensure that they process your Personal Information, on our behalf, with the same level of security and confidentiality as applied by RelyOn.

We may also provide your Personal Information to other parties to the extent required or provided 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 or regulatory obligation such as our AML/CFT obligations or if we have agreed to assist with any tax or other regulatory filing requirements.

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.

RelyOn may further more disclose or transfer Personal Information when we received your consent to do so or for one of the other purposes described in this Privacy Statement.

Cookie, Google Analytics and Other Data Collection Technologies

When you visit our website or use our mobile applications, we collect certain Transaction Information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons.

For example, when you visit our website, we place cookies on your computer. Cookies are small text files that websites send to your computer or other internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available.

We collect many different types of information from cookies and other technologies. For example, we may collect information from the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address assigned to the device you use to connect to the internet. An IP address is a unique number that devices use to identify and communicate with each other on the internet. We may also collect information about the website you were visiting before you came to RelyOn and the website you visit after you leave our site.

In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference toPersonal Information. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns.

In some cases, we do associate the information we collect using cookies and other technology with your Personal Information. This Privacy Statement applies to the information when we associate it with your Personal Information.

One of the third party vendor used by RelyOn is Google Analytics. For information on how Google Analytics uses data please visit “HowGoogle uses data information from sites or apps that use our services”, located at https://policies.google.com/technologies/partner-sites.

‍

Your Rights and Privacy Choices

You have the following rights in respect of the Personal Information about you that we process:

• the right to access 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;
• the right to opt out from direct marketing; and
• the right to withdraw consent to process your Personal Information at any time. 

In addition, you may have the right to make a complaint with the local supervisory authority with respect to the way RelyOn is processing your Personal Information or the way RelyOn is handling your rights.

You can always limit the information you provide to RelyOn.You can also limit the communications that RelyOn sends to you. To opt-out of commercial or marketing emails, simply click the link labelled “unsubscribe” at the bottom of any email we send you.

Please note that even if you opt-out of promotional emails, we may still need to contact you with important Transaction Information about the services or products we are providing or will provide to you or the organisation you work for. For example, even if you opt-out of emails, we may still send you activity confirmations and account statements.

If you have any questions about your rights, choices or if you need any assistance with opting-out, please contact us via email to enquiry@relyon-trustee.com. You can also write us at the address in Our Contact Information section below. If you send us a letter, please provide your name, address, email address, and information about the communications that you do not want to receive.

Security of Your Information

RelyOn has implemented an information security program that contains administrative, technical, and physical controls that are designed to safeguard your PersonalInformation. For example, we use industry-standard encryption technology to secure sensitive Personal Information when it is being collected and transmitted over the internet as well as firewalls, site monitoring and intrusion detection software.

Please note that you should also take steps to protect yourself and your Personal Information, especially online. When you register at RelyOn websites, choose a strong password, and do not use the same password that you use on other sites. Do not share your password with anyone else. RelyOn will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail. Also remember to sign out of the website and close your browser window when you have finished your work. This is to ensure that others cannot access your Personal Information and correspondence if others have access to your computer.

Third Party Privacy

This Privacy Statement only addresses the use and disclosure of information by RelyOn. Other websites that may be accessible through this website have their own privacy policies and data collection, use and disclosure practices. Our affiliates, suppliers and business partners have their own privacy policies too. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.

Change of Purpose

We will only usePersonal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use any Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process Personal Information without your knowledge or consent, in compliance with the above, where this is required or permitted by law.

Changes to This Statement

From time to time, we may update this Privacy Statement to reflect new or different privacy practices. We will place a notice online when we make material changes to thisPrivacy Statement. Additionally, if the changes will materially affect the way we use or disclose previously-collected Personal Information, we will notify you about the change by sending a notice to the primary email address associated with your account.

Data Retention

We will only retain PersonalInformation for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for Personal Information, we will consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of Personal Information, the purposes for which we process Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Our Contact Information

If you have any questions, comments or requests about our commitment to data protection, please contact the Privacy Officer of RelyOn TrusteeLimited at enquiry@relyon-trustee.com.

Copyright © 2022 RelyOn Trustee Limited

All Rights Reserved

‍