Privacy notice

This privacy notice (referred to as the Notice) describes how the Palmer group of companies (Palmer, we, us, our) will make use of the personal data of our clients, including that sent via our website palmerfs.com (the Website). It is important that you read this notice together with any other privacy notices or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Privacy Pledge

As we build Palmer’s suite of services, we are committed to the principles of respecting your privacy, keeping your data safe and keeping the decision as to how your information is used and shared in your hands.

Our privacy pledge is as follows:

Palmer will only collect data that is of legitimate interest and which is useful and necessary for improving its products, services and your experience;
Palmer will maintain fairness and transparency at all times with regards to how we collect and process data at all times;
Palmer will never sell or otherwise seek commercialise your data and will only share your personal data when given your explicit consent to do so for a specific reason;
Palmer will never make decisions based solely on automated processing or profiling of data; and
Palmer will always take the security of your data seriously in line with our other legal and regulatory obligations.

Personal Data Collection

We process personal data about you when you use the website, this includes:

information you provide to us, for example, information you submit via forms on the Website and information you provide us if you contact us); and
Website usage information (such as information about the device you use to access the Website, connection information (such as IP addresses), and information about your use of the website (such as the links that you click, how long you remain on the website, and any errors that may occur on the website)). We collect this information using cookies and other technologies as described in our Cookie Notice.

Giving us this information is optional, but if you choose not to provide it, this might affect your ability to receive certain services or take part in certain activities where we need this information.

Where you are a prospective, current or former client of Palmer or, where you are an owner, controller or personnel of our prospective, current or former client, we process personal data about you. This includes:

identifying information (e.g., information used to identify a specific individual or confirm they are a person, such as: given name(s), preferred name(s), nickname(s), date of birth/age, place of birth, nationality and passport details);
contact information (e.g., postal address, telephone number and email address);
family information (e.g., family structure, siblings, offspring, marriages, divorces and relationships);
financial information (e.g., source of wealth, personal assets, bank account numbers and income details);
professional information (e.g., job titles, employment history); and
transactional information (e.g., details about payments to and from you and other details of products and services you have purchased from us).

Marketing and Communications data includes your preferences in receiving marketing from us and your communication preferences.

Where you are a client, in certain circumstances we will also collect, use, store and transfer certain special category personal data about you. As part of our due diligence processes, we collect information about:

your political opinions and affiliations, so that we can identify that you are, or are connected to, a politically exposed person; and
your criminal records or alleged criminal activity.

Where we need to collect your personal data to comply with our legal obligations, or to perform a contract we have with you, this is mandatory and we will not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services) if we do not have this information. We may have to terminate the provisions of services if this information is not provided. Otherwise, provision of the requested personal data is optional, but not providing it may affect your ability to receive certain services or take part in certain activities where the information is needed for those purposes.

If you do have any concerns about the information you’re being asked to provide, then please contact our Data Protection Officer.

Third Party Sources

Where you are a client, we may receive personal information about you in the followings forms and from the following sources:

identifying, contact and professional information from publicly available sources such as Companies House in the UK;
identifying, contact, professional and sensitive personal data from searches of electronic databases researched and maintained by professional service providers to help identify and manage financial, regulatory, and reputational risk, such as World-Check; and
identifying, contact, family, financial, professional, transaction and sensitive personal data from your other service providers and advisers including trust companies, fund administrators, accountants, tax advisers and lawyers.

Use of Personal Data

We have set out below the Reason we may use your personal data. We manage these processes carefully to ensure your information is only used where it is necessary, that it is only used in a secure and transparent way and that any inappropriate processing is identified quickly and ceased.

In connection with the provision of services.	Where Palmer intends or has entered into a contract with a client to enable it to supply the services. So that we can communicate with you in respect of our services. For Palmer’s client management purposes including but not limited to the management of queries, complaints, or claims.
Where required by law.	To verify your identity. In connection with any legal obligation on us to report any fraud or other criminal activity (including money laundering or tax avoidance schemes).
Where Palmer has a legitimate interest in using such information.	To meet all legal, regulatory and ethical obligations applicable to Palmer. To verify the accuracy of information / personal data that we hold about you and create a better understanding of you as a client. To gather views directly to maintain and enhance Palmer’s products and services. In connection with the support network and system security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access. To comply with a request from you in connection with the exercise of your rights (for example if you ask us not to contact you for marketing purposes, we will keep a record of this in order to be able to comply with your request). Where relevant to protect the legitimate interests of shareholders, directors, officers (or similar persons) of the client, and their respective beneficial owners or to establish or defend legal actions or claims brought by or against any such persons. For marketing activities (other than where we rely on your consent) to contact you by email or text with information about our products and services
Where you have consented to such use.	For example, if you have expressly requested / consented to marketing materials being provided to you; or you have provided us with sensitive personal information about you in connection with the provision of our services.

To the extent that any personal data processed contains special category data such as, for example: personal data relating to racial or ethnic origin, political opinion, religious or philosophical belief, trade union membership or criminal data then the processing of such data shall generally be for the purpose of complying with a right or duty imposed on us (or on any service provider appointed by us) by an enactment including, but not limited to, legislation and regulatory obligations relating to anti-money laundering and combatting the financing of terrorism and all other related legislation.

Disclosure of Personal Data

We will only disclose your personal information in accordance with applicable laws and regulations. We will disclose your information to the following third parties:

To a client entity in which you have a direct or indirect interest and / or such client’s subsidiaries, holding company and or other associated counterparties of such client entity where such disclosure is necessary for us to perform our services or we are otherwise required to share such information with such persons;
any person with legal or regulatory power over us (for example, in Jersey, the JFSC, the Jersey Office of the Information Commissioner, the Joint Financial Crimes Unit, or the Comptroller) who may require disclosure on legal grounds;
service providers engaged by us to help us run our business and perform the services. Such service providers may for include, for example, cloud storage providers (engaged by us to provide electronic board packs, or other storage facilities for our business data and your information); and
Any member of the Palmer group of companies.

International Transfers

Some of these third parties (including certain Palmer subsidiaries and service providers) may be outside of the European Economic Area (EEA), the Channel Islands or other territories determined by the EU to have adequate protection for the protection of personal data. If we transfer your information in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this privacy notice. Such steps include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Transfers within the Palmer group of companies will be covered by an intragroup agreement which contractually obliges each member to ensure that your personal data receives an appropriate level of protection wherever it is transferred within the group.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Recordings will be kept for as long as they are deemed up to date and useful to our services. Where you are a website user, or you contact us, we keep personal data obtained from cookies and similar technologies for the periods set out in the Cookies Notice.

Your legal rights

You have the following rights in relation to how we use your information. If you’d like to exercise these rights please contact us.

Right to lodge a complaint - You have a right to complain to the Commission at any time if you object to the way in which we use your personal information. More information can be found on its website.

Right of access – You have the right to know if we are using your information and, if so, the right to access it and information about how we are using it. There will not usually be a charge for dealing with these requests. Your personal information will usually be provided to you in writing, unless otherwise requested. Where you have made the request by electronic means the information will be provided to you by electronic means where possible.

Right of rectification – We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this is the case you have the right to require us to rectify any errors in the information we hold about you.

Right to erasure – you have the right to require us to delete your information if our continued use is not justified. However, this will need to be balanced against other factors, depending upon the type of personal information we hold about you and why we have collected it, there may be some legal and regulatory obligations which mean we cannot comply with your request.

Right to restrict processing - in some circumstances, although you may not be entitled to require us to erase your information, you may be entitled to limit the purposes for which we can use your information.

Right of data portability – you have the right to require us to provide you with a copy of the personal information that you have supplied to us in a commonly used machine-readable format or to transfer your information directly to another controller (e.g. a third party offering services competing with ours). Once transferred, the other party will be responsible for looking after your personal information.

Right to object to direct marketing - you can ask us to stop sending you marketing messages at any time.

Right not to be subject to automated-decision making – Palmer does not make decisions about you using automated decision making or profiling of your personal data.

Right to withdraw consent - For certain limited uses of your personal information, we may ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information. If you withdraw your consent, we may not be able to provide certain products and services to you. If this is the case, we’ll tell you at the time you ask to withdraw your consent.

In some circumstances exercising some of these rights will mean we are unable to continue maintaining a business relationship with you.

You can make any of the requests set out above using the contact details in this Privacy Notice. Please note that in some cases we may not be able to comply with your request for reasons such as our own obligations to comply with other legal or regulatory requirements. We will always respond to any request you make and if we can't comply with your request, we will tell you why.

Marketing

We respect your privacy and to the extent we carry out any direct marketing activities we will carry these out in accordance with applicable laws and guidance.

We may contact you with marketing information by post or by telephone or with targeted advertising delivered online through social media and platforms operated by other companies, unless and until you object.

If you are a corporate entity and have engaged us for services, we may also contact you with marketing information by email or other electronic means unless and until you object. If you are an individual or a member of an unincorporated entity (and except where the following paragraph applies) we will only contact you by email or electronic means with marketing information where you have given us your consent.

Where we have obtained your email address in connection with our contract with you for any services, or where you have made a positive enquiry about any of our services, we may also contact you with marketing information about similar services by email or other electronic means unless and until you object.

From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.

You have the right to opt-out of our use of your personal information to provide marketing to you by informing us (if we call you by telephone), or by clicking the “unsubscribe link” on any marketing email that we send to you, or by contacting us.

Contact Us

Should you have any queries or comments on this Notice or the processing of your personal data, please contact James Bermingham, our group data protection officer, at the address given in his bio.

Changes to this Privacy Notice

We will update this privacy notice when necessary to reflect changes in the law, our used practices and in our services, as well as to ensure it is accurate and up to date. When we make an update we will amend the date at the top of this notice, you are therefore advised to check this privacy notice periodically. We may also notify you in other ways from time to time about the processing of your personal information.