Circumference Holdings - Privacy Policy

This privacy policy has last been updated on30 September 2019.

This Privacy Policy is intended for clients of Circumference Holdings.

This policy will explain areas of this website that may affect your privacy and personal details, how we process, collect, manage and store those details and how your rights under the GDPR (General Data Protection Regulation), Cayman Islands Data Protection Law, are adhered to.

We are firmly committed to protecting your personal, financial and business data. We outline herein:

• What personal information we collect about you;
• How we obtain your personal information;
• How we use your personal information;
• on what basis we use your personal information;
• With whom we share your personal information;
• The countries to which we transfer your personal information;
• How long we keep your personal information; and
• Your rights regarding your personal information.

What personal information do we collect about you?

The information we may collect from you includes:

• Information establishing your identity (for example, name, email address, contact details) and personal background (which include personal information concerning your family members, if provided to us);
• Information related to transactions or financial behavior arising from your relationship with and through us, and from other financial institutions;
• Information you provide on an application form for any products and services; and
• In respect of corporate or institutional clients (including partnerships), details about persons with an interest in clients, including but not limited to shareholders, partners, trustees, settlors, protectors, beneficiaries, staff and corporate contacts.

Non-personal identification information

We may collect non-personal identification information about users whenever they interact with our website. Non-personal identification information may include the browser name, the computer OS and technical information about users means of connection to our website, such as the operating system and the Internet Protocol address of your Internet service provider.

How do we obtain your personal information?

We may collect and confirm your information during the course of our relationship with you and will only use personal information which constitutes personal data in accordance with the relevant laws.

We may obtain this information from a variety of sources including from you, from service arrangements you make with or through us from financial institutions, from registries, from references you provide to us and from other sources.

How do we use your personal information?

We may use or process your information for the following purposes:

• To verify your identity;
• To facilitate or otherwise assist in the provision of services provided by us to you;
• To meet our regulatory and/ or legal and/or financial and/or other reporting obligations in the Cayman Islands;
• To comply with laws, regulations, or court orders in any jurisdiction (whether or not the same is strictly binding or capable of being enforced);
• To prevent or detect fraud, money laundering, terrorist financing or other criminal conduct (including, without limitation, compliance with our internal know your client, anti- money laundering and anti-bribery and corruption policies);
• To recover a debt;
• To assess and manage our operations and financial and insurance risks;
• To maintain the accuracy and integrity of information held by a credit reporting agency and to perfect any security interest granted over an account with us.
• We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
• Internal record keeping;
• We may use the information to improve our services;
• Where we have clearly stated and made you aware of the fact, and where you have given your express permission, except for where we have legitimate interests in doing so, we may use your details to send you information related to our services/products/newsletter through a mailing list system. This is done in accordance with the regulations named above.

On what basis do we use your personal information?

• To comply with legal and regulatory obligations;
• To perform our contractual obligations to you;
• For legitimate business purposes. Using your personal information helps us to operate and improve our business and minimize any disruption to the services that we may offer to you;
• Because you have given your consent (if we expressly ask for consent to process your personal information, for a specific purpose); and
• To prevent and detect crime, or for reasons of substantial public interest, and for the establishment, exercise or defense of legal claims or proceedings.

With whom do we share your personal information?

We will only disclose or transfer your information for the purposes set out in this document to:

• Our employees, agents and service providers and other companies within our Group, who are required to maintain the confidentiality of this information;
• Companies and organizations that assist us to process transactions including, but not limited to, stock exchanges and clearing houses;
• Regulatory, police authorities or law enforcement and fraud prevention agencies, where we or the Group are compelled or permitted or required to do so by order of a court or governmental or administrative tribunal or by law, regulation or any other legal requirement;
• Any person to whom we may assign or transfer our rights and/or obligations under our agreement with you or any third party as a result of a restructuring, sale or acquisition of the Group or any of its direct or indirect subsidiaries, provided that the recipient uses the information for the same purpose as it was originally supplied to us and/or used by us;
• Such persons as we believe are necessary where a failure to make such disclosure would result in damage to our reputation or good standing, expose us to civil or criminal prosecution in any jurisdiction; or
• Where failure to make such disclosure would in our opinion be prejudicial to us, or the Group, our nominees, advisors or agents; or
• To such other person that we or the Group believe in good faith have a right to make a request for disclosure; and
• Any other person where disclosure is made at your request or with your consent (including your advisors or agents), or if otherwise permitted under our agreement with you.
• We do not sell, trade, or rent users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.

Transfers of your personal information outside of your home country

This may result in certain of your personal information being transmitted through or stored or processed in other jurisdictions which may be outside the Cayman Islands and the EU, and also being subject to the laws of those jurisdictions, whether or not those jurisdictions have equivalent or adequate data protection legislation.

We will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred, in accordance with applicable data protection and privacy laws.

The measures include:

• In the case of transfer of personal information to a Group company in the United States of America, entering into EU Standard Contractual Clauses with that Group company. Further details of EU Standard Contractual Clauses can be found at
  https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
• Ensuring that the jurisdictions into which your personal information is transferred contain equivalent data protection legislation and requirements to those of the EU; and
• In the case of transfer of personal information to a third party in the United States of America, obtaining certification under the EU-US Privacy Shield. You can find more information about the EU-US Privacy Shield at https://www.privacyshield.gov/.

How long will we keep your personal information?

We will only retain the information we gather from you for a period of seven years from the date of termination of our relationship with you, or for such other period as may be required from time to time under relevant laws and regulations, including those relating to record keeping and prescription periods. Such information may be retained after your relationship with us has ended, and for client identification purposes in accordance with our record keeping policy.

Use of cookies

This website uses cookies to better understand the users’ experience while visiting the website. Cookies are small files saved to the user’s computer’s hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server, to provide the users with a tailored experience within this website.

Users are advised that if they wish to deny the use and saving of cookies from this website onto their computer’s hard drive they should take necessary steps within their web browser’s security settings to block all cookies from this website and its external serving vendors or use the cookie control system if available upon their first visit.

Measuring website usage(Google analytics)

We use Google Analytics software to collect information about how you use this website. We do this to help make sure the site is meeting the needs of its users and to help us make improvements.

Google Analytics stores information about:

• the pages you visit
• how long you spend on each page
• how you got to the site
• what you click on while you’re visiting the site
• Your behavior on website

We do not collect or store your personal information (for example your name or address) so this information cannot be used to identify who you are. We do not allow Google to use or share our analytics data.

Google Analytics sets the following cookies in accordance with Google’s privacy policy

Website analytics and target advertisement

Circumference Holdings together with the third-party service providers like Google uses cookies that are tenaciously placed in your browser to collect data, which include but is not limited to the operating software you use, your web browser, your location and IP address. This gives you a unique user identity on our website and also helps us improve our services and offer you personalized website experience based on your past visits and preferences. The collected information of users will be stored with us for 2 years and with Google until 14 months from your last session.

The personal data such as name, contact details, email etc. is not collected through cookies. However, you can manage and block such use of cookies by simply changing the settings in your browser or by choosing third party tools like Ghostery, Skyblocker-software, Disconnectand others. However, if you do so, note that some parts of the website may not function properly.

We use targeted advertisements, Advertising Reporting feature of Analytics. We also use Remarketing feature of Google Analytics tool.

Circumference Holdings makes use of either Google's Interest-based advertising (Personalized Advertising), 3rd-party audience data.

You can also download the Google Analytics opt-out browser Add-on here

Privacy policy changes

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes to your rights.

Your rights

If you believe that any of the centrally held information, including your personal information, is incorrect or inaccurate, you should notify us so that the information can be updated or corrected, as appropriate.

You have the right to:

• Access your personal information
• Request correction, restriction, portability or erasure of the information that we process about you.

These rights are subject to any applicable exemptions under the data protection laws.

You may seek to exercise these rights at any time by clicking on the following link DPL Privacy Removal and completing the attached form.

You can withdraw your consent to the processing of your personal information (where we are processing your personal information based on your consent). If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. However, this may limit or prevent us from providing the products or services you have asked for. It may also make it more difficult for us to advise you or suggest appropriate alternatives.

If you feel that we do not comply with applicable privacy rules you have the right to lodge a complaint with a competent data protection authority.

Contact us

We can be contacted at : alan.turner@circumferenceholdings.com