Client Privacy Policy

This Privacy Policy explains what personal information we collect and how we use it. For the avoidance of doubt this Privacy Policy will cover aspects of the personal data being processed by ILS World as a result of your enquiry or request for services directly from an operational subsidiary. For specific information relating to data processed on the website, please see the website privacy policy https://www.ils.world/legal/privacy-policy

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, London, Shanghai and Dubai. We also have a representative office in Portugal. You can discover more about ILS World through our website https://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
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:

• Customers and/or their representatives
• Advisors or professionals
• Individuals attached to suppliers, advisors, consultants and other professional experts
• Persons making enquiries about our services or an open position within an office of ILS World
• Directors, shareholders, beneficial owners, settlors, protectors, beneficiaries, and any other person that may have significant control over a structure we administer
• We may need to collect data on children when they are beneficiaries to a trust. This is due to a legal obligation or legitimate interest to prevent financial crime.

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:

• Marketing and advertising. We may use your personal information for marketing purposes if we think our services would interest you. We will seek permission from new customers and other parties that are not customers before we send you marketing material. This includes client surveys and market research.
• Services provided under contract. This may include (but is not limited to) personal data whilst we are providing fiduciary services, accounting services that contains personal data and preparation and submissions for visa/work applications which you have sought under terms and conditions with ILS World. For more information in relation to these services please see our website https://www.ils.world.This will include communications and reporting, any billing and service e-mails and transactional data processed as a consequence of our services.
• Provision of Trust and Corporate Services. We may also use personal data to submit directors and shareholders details to companies' registries, process and submit VAT applications or submit beneficial owner details (or persons of significant control) under beneficial owner register acts in the Isle of Man and elsewhere. This is both a consequence of the provision of our services under contract and a legal requirement under relevant company, trust, VAT and tax law or other legislative obligations. We may also process personal data where we assist with licence applications for e-gaming companies or designated businesses as a consequence of providing the corporate services to these businesses.
• AML/CFT, Regulatory or AEIO adherence - ILS World Subsidiaries. We may use personal data for the purposes of adhering to Anti Money Laundering /Countering Financing of Terrorism (AML/CFT) and Bribery and Corruption (B&C) obligations and also the international obligations in respect of Automatic Exchange of Information (AEOI).
• Complying with/supporting compliance with legal and regulatory requirements of our corporate and trust service agents. In order to establish the company, trust or other legal structure in a jurisdiction where ILS does not have an office, a subsidiary office may be required to provide certain identity, tax or other information or documents to an agent. In many situations failure to provide this information will mean the agent cannot form or continue to provide services to the structure.

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:

• Helping to prevent and detect crime such as fraud and money laundering/terrorist financing. Where we operate in a location and are not licenced for anti-money laundering or terrorist financing we will be dealing with suppliers, agents, banks or other bodies that are licenced and it is in our legitimate interest to undertake checks on your identity to protect our business from exposure to crime. We will endeavour to keep these requests proportionate and limit the inconvenience caused.This also includes obtaining information for the purposes of adhering to Automatic Exchange of Information (AEOI) obligations of our subsidiaries or our agents forming the structure where we do not have an ILS presence.
• Reporting to the Group office and providing support functions to ILS subsidiaries. There may be occasions where information is provided by the subsidiary offices to the Group office to enable sufficient oversight of the subsidiary offices. There may also be occasional where assistance is provided by the Group office to its subsidiaries regarding a particular client, client structure or identity documents obtained. There will also be exchanges of transactional information which may include personal information to support the accounting function within ILS World.
• Complaint and dispute resolution. There may be occasions when ILS World will use customer data whilst looking into queries and complaints involving a subsidiaries office where the individual has contacted the Group office or we are assisting a subsidiary office.
• Marketing and advertising our own services. There may be occasion where we feel that there is a reasonable expectation for you, as the customer or previous customer, to receive marketing material from us in regard to other or similar services provided by ILS World. In these situations we will continue to send you marketing material unless you have indicated your desire to be removed from the marketing list or you have unsubscribed. You can opt out of marketing communications at any time by following the instructions in the email by contacting us at enquiries@ils.world

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:

• Companies within the ILS group. ILS World's head office is based in the Isle of Man. We have offices in and outside the European Economic Area, so we may access your personal information from or transfer it to these locations as well. Such transfers or access from an ILS World office is necessary in order to answer an enquiry or otherwise facilitate services that may be provided by ILS World. If an ILS World office has access to your data it will only be accessed by those who need to have access to it.
• Suppliers that provide services to ILS. Suppliers may require access to your personal information to facilitate the services ILS World is providing to you e.g. other agents, lawyers, accountants, auditors, banks and other professional firms as is necessary to complete your instructions (or the instructions of your service provider) which may include providing information or documentation because of the agent's AML/CFT or other legal requirements in the relevant jurisdiction.
• Providers of software packages or our IT providers. We maintain some of the personal data to enable us to facilitate the provision of Trust and Corporate Services or other ancillary services that we may provide from time to time. An example of this is our company secretarial package that we use to assist with preparing the necessary paperwork to maintain a company's status.
• Companies registries. We may share your personal information with companies' registries as a consequence of providing company and trust services.
• VAT authorities, Income Tax authorities, visa/work permit authorities. Where we assist clients with this service as a consequence of providing the corporate services and ancillary services like VAT agent or accounting services.
• Competent authorities. Personal data may be accessed by authorities in the relevant jurisdiction under their function for AML / CFT, regulatory supervision, through a court order or other production mechanism as may be used by the relevant competent authority under their powers of supervision, investigation or enforcement.

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.

Your rights
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.

Complaints
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

Changes to this Privacy Policy
We can update this Privacy Policy at any time. We won't alert you to every little change, but if there are any really important changes to the Policy, or how we use your information, we will keep you informed.

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