PRIVACY POLICY

“Personal Data” refers to any data and/or information that can be used directly or indirectly to identify, locate or contact you. The Personal Data we collect about you when you use our Services include:

1. Contact details, e.g. name, address, telephone number, mailing address, email address, IP address and other contact information you provide to us;
2. Personal information, e.g. passport or other identification number, politically exposed person (PEP) status, profession, marital status, details of financial information, source of wealth and source of funds; and
3. Tax information, e.g. taxpayer identification number and tax residence.

Generally, we collect Personal Data through the following ways:

1. Directly from you; and
2. From third parties, e.g. your authorised representatives or advisors.

Generally, we collect, use and/or disclose Personal Data for the purposes below:

1. To fulfil your requests and provide Services to you;
2. To comply with our internal policies and procedures;
3. To provide you with marketing communications and offers for services from Claremont and, in some cases, our partners; and
4. To comply with any requirement of applicable laws and regulations.

We share your Personal Data for the purposes listed above to the following parties:

1. Our related companies, where they are directly or indirectly involved in the provision of our Services;
2. Third party service providers, agents, suppliers and contractors where the sharing of your Personal Data is to enable Claremont to perform the relevant Services;
3. Any person to the extent required or provided by law, regulation or court order, for example if Claremont is under a duty to disclose your Personal Data in order to comply with our AML/CFT obligations; and
4. Any other person to whom we have been authorised to disclose your Personal Data.

We keep all your Personal Data confidential. At any time, you shall have the rights to:

1. Access Personal Data;
2. Make corrections to Personal Data;
3. Restrict and/or object to the use of Personal Data;
4. Request the erasure of Personal Data; and
5. Withdraw consent to the collection, use and/or disclosure of Personal Data.

To exercise your rights listed above, please submit a written request to Claremont and we will make the necessary arrangements. The request may be sent to [email protected] or by post to our registered office address marked for the attention of the Data Protection Officer.

You can also limit the information that you receive from Claremont. To opt out of marketing, newsletter and promotional emails, you may click ‘unsubscribe’ at the bottom of the email we send you.

In the event you fail to provide sufficient data and/or information when requested, we may not be able to provide Services and may have to terminate any agreement we have with you.

We seek to ensure security of your Personal Data. As part of efforts to protect Personal Data in our possession, Claremont has implemented an information security program that contains administrative, technical and physical controls that are designed to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal and/or similar risks. Claremont also subjects its employees to confidentiality obligations under their terms of employment.

Claremont shall retain Personal Data only for as long as reasonably necessary to fulfil the purposes set out above, or as required to comply with any legal obligations to which we are subject.

After we cease to provide Services to you, we may still keep your information. Claremont will normally destroy or erase the data after the statutory and regulatory periods for which we are required to keep records.

We may update this Statement from time to time. If we do, we will post an updated version of this Statement on this website page.