Minerva group (“Minerva”) – Privacy Notice
This privacy notice tells you what to expect when Minerva collects and processes your Personal Data, or in some cases Personal Data of other individuals which you have provided to Minerva. We may collect your Personal Data if we provide services to you or if you have registered to receive our newsletter. Personal Data includes data such as an individual’s name, address, email address and processing includes collecting, storing, using or disclosing Personal Data. Minerva is bound by data protection legislation in each jurisdiction within which it operates and is committed to protecting and respecting your privacy. This Privacy Notice (“Notice”) sets out the basis on which the Personal Data collected from you, or that you provide will be processed by us.
We use your data strictly in accordance with all applicable laws concerning the protection of Personal Data and you can be assured that any data provided will only be used in accordance with this Notice. In it we explain:
• Who we are;
• What data we may collect about you and when;
• How we might use your data;
• How we protect your data; and
• Your rights regarding the data you provide.
For the purposes of this privacy notice references to the ‘Minerva group’ includes the following entities and subsidiaries:
• Minerva Trust Company (Switzerland) SA
• Minerva Middle East DMCC
• Minerva Fiduciary Services (Mauritius) Limited
• Professional Trust Company (UK) Limited, trading as Minerva Fiduciary Services
• Minerva Fiduciary Services (Singapore) Pte Limited
• Minerva Trust & Corporate Services Limited
How Personal Data will be collected
We have clients that are individuals and clients that are corporate bodies, including limited liability partnerships, government departments and agencies and other public bodies. Even where our clients are not themselves individuals, they will be represented by individuals and they may be owned by individuals and invested in by individuals. As a result, we will inevitably process Personal Data in the course of our relationships with those clients too.
If you are a client, the data we process about you will include personal and/or professional contact details (addresses, telephone numbers, email addresses), copy identity documents and proofs of address, copy professional and educational certificates, details of bank accounts and/or other payment details, details of financial standing and investment objectives. Depending on the services we provide, we may additionally process details of family wealth, names, addresses and other personal details concerning family members and/or those employed by families or family members and other data categorised as “special category data”, such as data about an individual’s race; politics; religion; and health.
Minerva makes every effort to maintain the accuracy of Personal Data, although you must assist with this by promptly contacting Minerva if there are changes to the Personal Data you have previously provided or if you become aware that Minerva holds inaccurate Personal Data.
We may also obtain Personal Data about you, or another person you have provided us Personal Data for, under a legal basis from sources other than from you. The sources and categories of Personal Data, along with whether these are publically accessible are listed below:
Due diligence screening providers: Names, addresses, age, financial or economic data, social standing, crime or security related matters. This is publicly available.
Internet search engines and public data sources: Names, addresses, age, financial or economic data, social standing, crime or security related matters. This is publicly available.
Those authorised to act on behalf of a client including an advisor or attorney: Name, address, financial data, identifier code, age, gender. This is not publicly available.
Purpose and basis for collection
If you are a client, Minerva collects your Personal Data, or that of other individuals provided by you, in order to provide you with the services you have requested under the Terms of Business you have entered into with Minerva and also to meet certain legal obligations. We do not collect more data than we need in order to provide you with the services. If you do not provide the data that we ask for, we may not be able to provide you with the services that you require.
We may also (but only when you request this by signing-up or contacting us) use your Personal Data to provide you with newsletters or other forms of communication that will contain information about Minerva, including latest news and other Minerva services that we think may be of interest to you.
We may also seek your consent to publish any client testimonial you provide on the Minerva website, or in other marketing materials. Where consent is required to process Personal Data of an individual who has not reached the required age to provide consent under the applicable data protection law, Minerva will obtain consent from a person with parental responsibility for that individual.
If you are a visitor to our Site (including completing a form), make a new business enquiry or contact us with a general enquiry, we will process your data for the purpose of our legitimate interest in responding to those enquiries.
How Personal Data will be used
Minerva is the Data Controller for the Personal Data you provide to us and we will process your data in connection with providing the relevant services under a contract. We may also need to transfer Personal Data to third parties to be processed in connection with the services we provide to you, or to fulfil legal or regulatory requirements as necessary. If we do, any third parties that process your Personal Data are assessed by us to ensure they adhere to the requirements of applicable data protection requirements.
The Personal Data you provide to us will only be used for the purpose specified. Minerva does not and will not sell, rent or trade your Personal Data.
The Personal Data may be used in a number of ways, including to:
• verify your identity
• verify identity of others authorised to act on your behalf
• perform due diligence screening
• provide you with services and to contact you
• manage your transactions
• meet financial crime prevention requirements
• meet regulatory or legal obligations of Minerva
• register or subscribe you to receive Minerva newsletters
• publish news or your service testimonial on the Minerva website or in other marketing materials (where you have provided consent and agreed wording)
• when you fill out forms on the Minerva website
• when you contact Minerva with a request
• to provide you with details of Minerva’s services and products.
Transfer of Personal Data to third parties
When Minerva uses your Personal Data for the purposes outlined we may transfer and disclose it to third parties who either process the Personal Data on our behalf in connection with the services we provide to you; to a third party who requires the data under a legal requirement (where Minerva is legally obliged to provide the Personal Data); where we have a vital or legitimate interest for sharing your Personal Data or where you have provided consent. The third parties may include:
• another Minerva group company
• authorities (including Government departments, financial regulators, law enforcement)
• financial service providers
• audit firms
• due diligence screening firms
• other persons authorised to act on your behalf or in relation to the services provided (including legal and tax advisors)
• a third party involved with marketing activity including the Minerva website provider (where you have made a request or provided consent for this purpose)
In certain cases, Minerva may need to transfer Personal Data to other countries where we have operations or where our service providers are located. Where such transfers are made outside Jersey and the European Economic Area, we will make sure that appropriate contractual arrangements are in place with those entities.
In the case of transfers between members of the Minerva group, this will be subject to Minerva’s internal data protection policies and procedures.
Security and data retention
We take appropriate measures to ensure that any Personal Data are kept secure. Unfortunately, the transmission of data via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data when transmitted to Minerva; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.
To safeguard against unauthorised access to Personal Data, all electronic Personal Data held by us is maintained on systems protected by secure network architectures that contain firewalls and intrusion-detection software. The servers holding Personal Data are “backed-up” on a regular basis in an effort to avoid any inadvertent erasure or destruction of such Personal Data and are stored in facilities with appropriate security and fire-detection and response systems.
Your data is only accessible by those who need access to it and they are required to keep the data secure and confidential.
We only keep your Personal Data for as long as is required to operate the service you have signed up for, and in accordance with legal requirements, regulatory requirements, tax and accounting rules. Where your data is no longer required, we will ensure it is disposed of, deleted (insofar as is possible to do so) or cached in a secure manner.
How long is the Personal Data retained?
Any Personal Data you provide to Minerva will be retained by us for as long as we need it for the purposes for which it was collected and subject to any applicable law or other legal obligation that may apply.
Your rights in relation to your Personal Data are included within applicable data protection requirements, which include the following:
• General Data Protection Regulation 2016 (EEA)
• Data Protection (Jersey) Law 2018 (Jersey)
• Data Protection Act 2018 (United Kingdom)
• Data Protection Act 2017 (Mauritius)
• Federal Act on Data Protection 1992 (Switzerland)
• Personal Data Protection Act 2012 (Singapore)
Dependant on where you reside and because of the implementation of one of the above, you have rights as an individual which you can exercise in relation to the Personal Data we hold about you. Your rights are listed below:
Right of access: You have the right to know what type of Personal Data we hold about you and details about how we use it. You also have the right to obtain copies of your Personal Data.
Right to rectification: You have the right to have any errors or incomplete Personal Data corrected.
Right to erasure (to be forgotten): In certain circumstances, you have the right to request the deletion of all Personal Data relating to you.
Right to restriction of processing: You have the right to restrict how we use your data e.g. you can request that we do not process your data for a particular purpose.
Right to object to processing: You have the right to object to our use of your Personal Data (including for direct marketing purposes).
Right to withdraw consent: If you have previously given us consent to process your data for a particular purpose, you have the right to withdraw that consent at any time.
Right to data portability: You have the right to be supplied with all of your Personal Data you have given to us in a structured, commonly used and machine readable format. You also have the right to have your Personal Data transferred from one controller to another.
Right to lodge a complaint: You have a right to lodge a complaint with the relevant Data Protection Authority.
When you exercise your rights Minerva will consider any exemptions that may apply. It is possible an exemption may affect how we are able to respond to your request, if this is the case Minerva will explain this to you in writing.
If you would like to exercise any of the above rights please contact the relevant person in your location, their details are available under the ‘How to contact us’ section below.
Complaints or queries
Minerva aims to meet the highest standards when collecting and using Personal Data, your rights and interests are important to us. For this reason we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of Personal Data is unfair, misleading or inappropriate. Minerva is happy to provide any additional information or explanation required.
If you want to make a complaint about the way we have processed your Personal Data you can contact the Data Protection Officer in Jersey whose details are provided at the end of this notice. You also have the right to complain to the relevant Data Protection Authority. The authority for each Minerva group office is listed below:
Jersey: The Office of the Information Commissioner at Brunel House, Old Street, St Helier, Jersey JE2 3RG. Minerva Trust & Corporate Services Limited is registered with the Information Commission with number 17085.
United Kingdom: The Information Commissioner’s Office at 46 Sarehole Road, Birmingham, B28 8DR. Professional Trust Company (UK) Limited, trading as Minerva Fiduciary Services is registered with the Information Commissioner’s Office with reference ZA341553.
Mauritius: The Data Protection Office at 4th Floor, Emmanuel Anquetil Building, Corner Sir Virgil Naz & Sir William Newton Street, Port Louis.. Minerva Fiduciary Services (Mauritius) Limited is registered with the Data Protection Office.
Dubai: No registration required at present.
Geneva: No registration required at present.
Singapore: No registration required at present.
Changes to this privacy notice
We keep our privacy notice under regular review and we reserve the right to modify this Privacy Notice at any time. Any changes we may make to our Notice in the future will be notified and made available to you using the Website, or by contacting you directly.
How to contact us
All questions, comments and requests regarding this Notice should be addressed to your usual Minerva contact, the Data Protection Officer or Data Protection Contact person in your location directly on the details below:
The Data Protection Officer
Minerva Trust & Corporate Services Limited
The Le Gallais Building, 54 Bath Street
St Helier, Jersey JE1 8SB
Telephone: +44 (0)1534 702800
The Data Protection Contact
Minerva Fiduciary Services
25 Upper Brook Street
England W1K 7QD
Telephone: +44 (0)20 3411 9089
The Data Protection Contact
Minerva Middle East DMCC
Office 2102, Saba Tower 1
Jumeirah Lakes Towers
PO Box 24075
Dubai, United Arab Emirates
Telephone: + 971 (4)447 1170
The Data Protection Contact
Minerva Fiduciary Services (Mauritius) Limited
Suite 2004, Level 2 Alexander House
35 Cybercity Ebene
Telephone: +230 464 5100
The Data Protection Contact
Minerva Trust Company (Switzerland) SA
6, Place des Eaux-Vives
P.O. Box 3643
CH-1211 Geneva 3
Telephone: +41 (0)22 707 8740
The Data Protection Contact
Minerva Fiduciary Services (Singapore) Pte Limited
67 Mcnair Road
Telephone: +65 6291 1646
Last updated: 24 May 2018