This Privacy Policy describes the ways in which Sanlam Trustees International Limited (“STIL”, “we”, “our” or “us”) collect, use, and disclose your personal information. By using our website and our services, you consent to the processing of your information as set forth in this Privacy Policy, now and as amended by us.
1. General
STIL is registered with the Data Protection Office of the Republic of Mauritius. We may collect information from you through your use of our website, when you request information from us or engage our services, or as a result of your relationship with one or more of our clients.
By using any of our services including our website and by providing us with any personal information, you are consenting to the use of your personal information as set out in this policy.
Please do not send us any personal information if you do not want your personal information to be used in this way.
2. Information collected through our website
Your personal data comprises of information related to identification (including name, signature, nationality, place and date of birth, passport number, residential address, email address and other contact details); bank account details; professional qualifications, employment history, references and other details regarding your career history; tax status and tax identification numbers; and where necessary, information regarding your investment activities.
STIL may share your personal data with group companies and third parties (including bank, financial institution or other third-party lenders, IT service providers, auditors and legal professionals) under the terms of any appropriate delegation or contractual arrangement. Those authorised third parties may, in turn, process your personal data abroad and may have to disclose it to foreign authorities with proper legal authority. We will only transfer this information in the limited circumstances of and for the purposes described in this policy. By using STIL, you authorize us to transfer this information.
Please do not send us any personal information if you do not want your personal information to be used in this way.
3. Principles relating to processing of personal data
STIL takes all reasonable steps to ensure that personal data are:
processed lawfully, fairly and in a transparent manner in relation to any data subject collected for explicit, specified and legitimate purposes and not further processed in a manner incompatible with those purposes adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed accurate and, where necessary, kept up to date, with every reasonable step being taken to ensure that any inaccurate personal data are erased or rectified without delay kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed processed in accordance with the rights of data subjects
4. Purpose to collect your personal information
To comply with our legal and regulatory obligations.
To provide and improve our services to you and to our clients including handling personal information of others on behalf of our clients.
To understand our clients’ preferences, expectations and financial history in order to improve the services we offer
To provide for and improve our website
For other legitimate business purposes
5. Protection of your information
We restrict access to personal information about you to those employees, agents or other parties who need to know that information to provide services to you or in connection with your business with or through us.
We apply high standard of security when it comes to hosting and protecting your personal data from unauthorized access, deletion or alteration. We do not make personal information commercially available to any third party, except as described in this policy or with your prior permission.
Whilst we have taken every reasonable care to ensure the implementation of appropriate technical and security measures, we cannot guarantee the security of your personal data over the internet, via email or via our websites nor do we accept, to the fullest extent permitted by law, any liability for any errors in data transmission, machine, software or operating error or any other cause.
6. Legal Requirements
While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.
7. Your Rights
Under the data protection law we must ensure that your personal information is accurate and up to date. Therefore, please advise us of any changes to your information so that these can be undertaken as soon as is practicable. You are also entitled to request the destruction of your personal data and STIL will consider your request in light of any other laws or regulations prohibiting STIL from destroying your personal data.
You are entitled to request details of the information we hold about you and to have it rectified or deleted as required by applicable data protection legislation. For more information please send us an email.
8. Data Retention
STIL will store your personal information for as long as is required by data protection laws and any applicable laws or regulatory requirement. Once the purpose for keeping your personal data has lapsed, we shall destroy such information as soon as reasonably practicable.
9. Withdrawing your Consent
You may withdraw your consent at any time and free of charge by sending us an e-mail.
10. Changes to this Policy
This Privacy Notice is dated 24 May 2018. We reserve the right to amend this Privacy Notice at any time without notice, in which case the date of the policy will be revised.
Your Queries and how to contact us
If you have any questions about our use of your personal data, our retention procedures or our security processes, please contact the Data Protection Officer:
Mr. Gael Duchenne
Sanlam Trustees International Limited
Labourdonnais Village
Mapou 31803, Mauritius
Tel: +230 266 5000
Email: mu@trustees.sanlam.com