Last Updated: November 2020
We are dedicated to protecting the confidentiality and privacy of information entrusted to us. As part of this fundamental obligation, we are committed to the appropriate protection and use of personal information (sometimes referred to as personal data, Personally identifiable information or PII), that has been collected online or provided to us by you or on your behalf through online or electronic communications.
1. Visiting the IS website
We collect some relevant data from anyone who visits our Site. When you enter the Site we collect industry standard log data that records information about your visit, such as your browser type, the URL of the page that referred you, the different pages you visited and time spent on those pages. IS uses Google Analytics to gather this data and we use this type of information to ensure our Site is working properly and make improvements; for example, we may expand upon the information on the most frequently visited pages. This data may be shared across jurisdictions with multiple IS entities in accordance with local laws. Google Analytics collects data from you through cookies. You can opt-out of having your anonymized browsing activity within websites tracked by Google Analytics cookies by clicking on the following link:
Links to third party websites
2. Collection and use of personal information
What information we collect
We may collect personal information such as your name and address, contact details, marital status and partner's name, date of birth, gender, nationality, photograph, signature, educational history, occupational history, job title, income, assets, other financial information, bank details, investment history, tax residency and tax identification information.
We collect or generate relevant personal information when you contact our mailboxes, register for certain services or express interest in employment with us. In some cases, you may have previously provided your personal information to us (if, for example, you provided one of our professionals with a business card and asked to be contacted).
We may also collect personal information from publicly available sources as permitted by law or it may be provided to us on your behalf (with your consent).
The legal grounds we have to use your personal information
We generally collect only the personal information necessary to fulfil your request to be
contacted by us and develop an, employment or other relationship with us.
Your personal information may be stored and processed by us for the following purposes:
general business administration, including communicating with you where relevant, communicating with service providers and counterparties, accountancy and audit services, risk monitoring, the administration of IT systems and monitoring and improving products;
compliance with legal and regulatory obligations and industry standards, including knowyour-client procedures, the automatic exchange of tax information and legal judgments; and
where information is shared with a relevant Client and their affiliates, their business activities relating to such Client and their affiliates such as investor relations, discussions with such Client's other service providers and counterparties, decision-making in relation to
such Client, and business strategy, development and marketing.
We are entitled to process your personal information in these ways for the following reasons:
processing may be necessary to discharge a relevant legal or regulatory obligation;
the processing will, in all cases, be necessary for our, the relevant Client's or another person's legitimate business interests, such as:
ensuring compliance with all legal and regulatory obligations and industry standards, and preventing fraud;
establishing, exercising or defending legal rights or for other purposes relating to legal proceedings;
ensuring the security of information systems; and
you have given your explicit consent (this basis is used only exceptionally).
IS does not carry out automated profiling and will not make any decisions based on the automated processing of data.
We may collect "sensitive" personal information only for customer due diligence purposes when required by law and standards of industry best practice.
Sensitive data we may collect, sometimes referred to as 'Special Categories of Data', includes:
any personal information relating to the political opinions of a politically exposed person; and
any proceedings for any offense committed, or alleged, to have been committed by you involving securities, commodities or other investments, and the disposal of any such proceedings or any sentence of a court in the Cayman Islands or elsewhere.
Any sensitive data collected and processed will be subject to additional safeguards.
Do not provide sensitive personal information to us unless you consent to our processing of such information including transfer and storage to and in our databases.
If you have any questions about whether the provision of sensitive information to us is, or may be, necessary or appropriate for particular purposes, please contact us using the details set out under "Contacting Us" below.
IS understands the importance of protecting children’s privacy. It is not our policy to intentionally collect or maintain information about anyone under the age of 13.
3. Sharing and transferring personal information
We may from time to time, in accordance with the purposes described above, disclose your personal information to other parties, including between ourselves and with the relevant Client and any of their affiliates, professional advisers such as law firms and accountancy firms, other service providers of such Client, including technology service providers, counterparties and courts, and regulatory, tax and governmental authorities. Some of these persons will process your personal information in accordance with our instructions and others will themselves be responsible for their use of your personal information. These persons may be permitted to further disclose the personal information to other parties.
We will not share your personal information with any third parties for their own direct marketing use.
In general, you are not required to submit any personal information to us, but we may require you to provide certain personal information in order for you to receive certain services or for us to comply with certain legal and regulatory obligations. Accordingly, if certain personal information is not provided when requested, we may not be able to progress any transaction or potential transaction with you or on your behalf.
If you opt-in for particular services or communications, such as an e-newsletter or other market or performance commentary, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.
5. Your rights
If you have submitted personal information to us, you have the following rights:
The right to obtain information regarding the processing of your personal information and access to the personal information that we hold about you.
The right to request that we rectify your personal information if it is inaccurate or incomplete.
The right to object to, and the right to request that we restrict, our processing of your personal information in certain circumstances. There may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to continue processing your personal information or to refuse that request.
The right to ask us not to subject you to automated decision making that uses your personal information.
The right to object to us using your personal information for direct marketing purposes.
The right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that we have infringed any of your rights.
You can exercise your rights by contacting us using the details set out under "Contacting Us" below. We will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.
6. Data security and integrity
IS is committed to protecting the security of your personal information. IS has implemented generally accepted standards of technology and operational security in order to protect personal data and information from loss, misuse, alteration or destruction. IS ensures that all appropriate confidentiality obligations and technical and organizational security measure are in place to prevent any unauthorized or unlawful disclosure or processing of such information and data and the accidental loss or destruction of or damage to such information and data.
Only authorized IS employees and services providers are allowed to access the data and they are legally obliged to ensure confidentiality of this information. If IS receives a bona fide subpoena or document request from a relevant governmental or regulatory authority, we must provide the information that is being requested.
7. Transferring your personal information to other jurisdictions
IS may transfer or store your personal information to other jurisdictions.
Where this occurs, we will ensure that the transfer is subject to appropriate safeguards or is otherwise permitted under applicable law.
You can obtain more details of the protection given to your personal information when it is transferred to other jurisdictions, including a copy of any standard data protection clauses entered into with recipients of your personal information, by contacting us using the details set out under "Contacting Us" below.
8. Data retention
We make reasonable efforts to retain personal information only for as long as the information is necessary to comply with an individual's request, meet our legal obligations or until that person asks that the information be deleted, whichever is later.
We may modify this Privacy Statement from time to time to reflect current privacy practices. When we make changes to this Privacy Statement, we will revise the "updated" date at the top of this Privacy Statement. We encourage you to periodically review this Privacy Statement, which will be made available on our website, www.integrated.solutions, to be informed about how we are protecting your information.
10. Contacting Us
We are committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at email@example.com. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.
We will acknowledge your email within 14 days and seek to resolve your concern within 1 month of receipt. We may accept your concern (and in that case implement one of the measures set out in the 'Your Rights' section above), or we may reject your concern, the reasons for which will be fully outlined in our communication with you.