Due to the structure and operations of ILS World it may be necessary for information to be passed to other companies within the group or for one of the subsidiaries to act as the data controller. If you have any questions regarding ILS World or which subsidiary is considered the data controller for any specific processing activity, please contact us using the contact details below.
Who is ILS
'ILS World' is a trading name of The ILS Group Limited and is based in the Isle of Man. The Group has operational subsidiaries in the Isle in Man, British Virgin Islands, Hong Kong and London. We also have a representative office in Portugal. You can discover more about ILS World through our website www.ils.world
The ILS Group Limited and ILS Fiduciaries (IOM) Limited are each registered with the Information Commissioner's Office in the Isle of Man whilst ILS Fiduciaries (UK) Limited is registered with the UK Information Commissioners office. ILS Fiduciaries (Hong Kong) Limited adhere to the Personal Data Privacy Ordinance monitored by the Hong Kong Privacy Commissioner for Personal Data.
Personal data is data (whether used on its own or together with other information) that can identify an individual. It is important therefore that the personal data we hold about you is accurate and up to date. Please keep us informed of any changes to your personal data.
Who we collect data on
We may collect data on:
What information we collect and how we use it
We collect a variety of details which includes names, residential address or other contact details, signature, nationality, tax number, date of birth, gender, place of birth, copies of the identification documents, bank account details (on occasion and if personal bank accounts are used), information about assets or net worth and funding (commonly referred to as source of funds and source of wealth). We do not intentionally collect details about your race, ethnicity, religious or philosophical beliefs or information on your health, genetic or biometric data (commonly referred to as sensitive data or special categories of data under the General Data Protection Regulation). However such information may be contained within the Identity documents or other information you provide through correspondence, meetings, telephone calls or completion of application forms provided by you or you. We may also process data from web searches such as news articles. This data will be obtained indirectly from the internet searches and/or intelligence database services used by ILS World.
We process personal data for a variety of reasons, including:
We can also use personal information where the benefits are not outweighed by the interests or fundamental rights or freedoms of the individual. This is commonly called the "Legitimate Interests" condition for processing. Where we rely on it, the benefits being pursued by ILS World are:
Who we share your personal information with
We only share your personal information with those businesses and organisations who need to handle it so we can establish or administer your structure or answer your query. When necessary we also share information with other organisations, for example:
Transfers of data
There may be situations where it is necessary to send personal data outside the EEA. For example when data is required to initiate an enquiry with a company formation agent in a non EEA jurisdiction and ILS does not have a presence. In these situations we will endeavour to process the data in accordance with data protection principles. This may include putting into place an agreement between various ILS World offices and / or the service provider's containing standard model clauses approved by European Commission to ensure equivalent rights and protections are afforded to your personal data.
You have rights under data protection legislation which include your right to withdraw consent, where we have relied on this as a legal basis. This does not impact the data processed following your consent. You have the right to object to our processing of your personal data where the legitimate interest basis has been used, for example direct marketing. You have the right to request your personal data to be erased or corrected and you have the right to access your data in a commonly used machine readable form which can be transferred to another controller. You also have the right to restrict the use of your personal data where, for example, the accuracy of the data is contested.
Exercising your rights
If you want to exercise any of the above rights, please see the contacts section below. You will not usually be charged a fee for access but there may be a fee if the request is excessive, unfounded or repetitive and we can also refuse to act on such a request in these circumstances. Where an access request is received we will endeavour to provide the information within one month.
How long do we keep your data
ILS World will process personal data for as long as is necessary. We maintain records to comply with our legal, regulatory and statutory obligations or what we determine as reasonable business practice where there are no legislative requirements. The data relating to AML/CFT obligations for example will be maintained by the subsidiary offices and held for at least five years following closure or termination of our relationship in accordance with AML/CFT legislation. The retention period may, for example, also be dependent on the jurisdiction where you have chosen to incorporate. Once the retention period has come to an end the data will be destroyed in line with our policies.
Securing Your Personal Data
ILS World is committed to protecting your personal data and has appropriate technical and organisational measures in place.Personal data obtained is held in electronic form on the servers located in the Isle of Man at a data centre in a private cloud environment and is only accessible by members of staff through secure login protocols. The servers are located at a data centre on the Isle of Man with the ISO27001 accreditation. Manual files relating to the structure administered will be maintained at the subsidiary office providing the services and are maintained in a secure manner.
You have the right to complain if you have concerns about the processing of your data being undertaken by ILS World. Please contact us using the contact details below. You will receive an initial acknowledgment within seven working days. You also have the right to complain to the Isle of Man Information Commissioner at https://www.inforights.im
For complaints relating to EU individuals or customers of the UK office, please contact the United Kingdom Information Commissioner's office at https://ico.org.uk
For complaints regarding customers of the Hong Kong office, please contact the Privacy Commissioner for Personal Data https://www.pcpd.org.hk
Who to contact
Please contact our Data Protection Officer at DPO@ils.world for any questions surrounding the aspects covered in this policy or requests for personal information we hold. You can also contact the office providing services to you directly at https://www.ils.world/contact