Privacy, Data Protection and Compliance Statements

VISITORS TO THE WEBSITE.

All users may visit this website anonymously and without revealing any personal information unless they specifically contact us. We may monitor visitors’ jurisdictions, domains, browsers, internet service providers and other available data but we do not collect any personal information. We may analyse the data collected for market research purposes. We may also collect data provided to us by visitors’ browsers about the type of systems they use. This privacy statement does not extend to anything that is inherent in the operation of the internet and beyond our control. We do not use cookies to identify users. Cookies are pieces of information that a website transfers to a visitor’s hard drive for record keeping purposes. Unless required to do so by law, we will not disclose any information obtained as above.

CLIENT DUE DILIGENCE, ANTI-MONEY LAUNDERING, COUNTERING THE FINANCING OF TERRORISM AND ANTI-BRIBERY AND CORRUPTION

We are required to verify the identity and obtain other information on all our clients and connected persons in relation to entities we administer.

We recognise our local and international responsibilities to prevent any use of the financial system for purposes connected to the proceeds of crime or corruption. We take a zero-tolerance approach to bribery and corruption and are committed to upholding all applicable laws in relation to countering bribery and corruption. We will report to the relevant authorities any knowledge or suspicion of money laundering, including that relating to drugs, terrorism, bribery or indictable crime in line with our statutory duties. These duties override the duty of client confidentiality.

DATA PROTECTION

For the purposes of the Data Protection (Bailiwick of Guernsey) Law, 2001, the data controller is Harbour Trustees Limited.

We will principally collect information from you such as name, date of birth, address, telephone and other contact details, driver's licence or passport details, debit or credit card details, financial information and employment information. This will generally be collected directly from you, for example when you fill out a form or correspond with us.

Personal data transferred to Harbour may be used in a number of ways, including in order to enable Harbour to maintain the relationship with you or for statistical analysis and fraud prevention and to enable us to comply with our statutory obligations. This may involve the disclosure of personal information to third party institutions such as banks or professional advisers (including those persons connected to entities we administer and those appointed by Harbour). We will otherwise not disclose your personal data to third parties unless required to do so by law.

All personal data supplied to and processed by Harbour will be processed in accordance with The Data Protection (Bailiwick of Guernsey) Law, 2001, as amended. Harbour may need to transfer the personal data to a jurisdiction outside of Guernsey (and in certain circumstances outside the EEA, to a jurisdiction which may not ensure adequate levels of protection for the rights and freedoms of data subjects). Harbour will take steps to ensure that a high level of protection is afforded against any unauthorised or accidental disclosure, access or deletion.

To update your personal information, please contact us mail@harbour.gg. You have the right to access your personal data and request correction or deletions under Guernsey law and we endeavour to honour such requests as specified under Guernsey law.

Should you wish to access a copy of your personal data, please contact us in writing at Harbour Trustees Limited, PO Box 73, St Peter Port, Guernsey GY1 3DD with proof of identity and enclosing a fee of £10.