This Privacy Statement describes how Opus Private Limited (Opus) collects, processes and shares the information you provide to us and any further information that we collect in the course of operating our business and in using our website.
In this Statement, where we refer to "Opus" (or "we"/"us"/"our)", we mean Opus Private Limited, its joint licensees and any other entities that are associated with us.
Opus Private Limited and its joint licensees are licensed and regulated for the provision of fiduciary services in Guernsey.
We may collect personal information from you when Opus is engaged to provide services or otherwise in the course of our business and through your use of this website.
Information may be collected directly or indirectly from you in correspondence, including by email, or through verbal communication, whether face to face, by telephone or by other means. Information may also be gathered independently through publicly available sources and trusted third parties.
Information that is collected and how it is processed
This may include:
- Your personal identification information (which may include your name and passport information, your IP address, information related to any criminal convictions or bankruptcy, your politically exposed person (PEP) status. We may also collect personal data that is available in the public domain through public search engines, public media and other commercially available subscriptions;
- Your contact information (which may include postal and e-mail addresses and home and mobile telephone numbers);
- Your family relationships (which may include your marital status, the identity of your spouse and the number of children that you have);
- Your professional and employment information (which may include your level of education and professional qualifications, employer’s name and details of directorships and other offices which you may hold);
- Financial information, sources of wealth and your assets (which may include details of your assets and their source, shareholdings and your beneficial interest in assets, your bank details and your credit history).
This information is collected and processed on the basis of legal and regulatory requirements, in the performance of contracts, or otherwise for reasons of legitimate interest.
Special Category Data
The information that we collect may contain special category data such as political opinions and affiliations, religious or philosophical beliefs, or to offences committed or alleged to have been committed. Opus does not require your consent for collecting and processing any special category data because it is necessary to do so in order for Opus to comply with the duties imposed on it by financial crime legislation and other reporting obligations.
We may also collect and process personal data regarding people connected to you, either by way of professional or other association or by way of family relationship.
Applications for Employment
If you apply for employment with Opus, either directly or through a recruitment agency, we may collect personal information relating to your past employment, professional qualifications and education, your nationality, your residential status, opinions from third parties about you (such as references) and other publicly available details about you which may be gathered during the recruitment process. This information is used for reasons of legitimate interest and will not be retained for longer than is necessary.
Information collected through our website
Opus maintains continuous logs of its web server activity. These log files include the details of website users’ IP address, browser type and page last visited etc. The log files are used to analyse how the website is being used by visitors and may be kept in an anonymised form for historical records as a legitimate interest.
Opus’s website uses hosted web analytics software. This hosted service is provided and managed by a third party company (Google, Inc.). The service ‘Google Analytics’ uses ‘cookies’ (a text file sent to users’ computers as they browse our website) to help analyse how users navigate our website. The information generated by the cookie regarding our website (including IP addresses) will be anonymised and transmitted to and stored by Google, Inc. on servers that may be hosted in the United States. Google, Inc. will use this information for the purposes of evaluating use of our website, compiling reports on website activity for website operators and providing other related services to Opus.
How and why we share your information
We may share your personal information outside Opus. This may include disclosures to:
- Third party agents/suppliers or contractors, in connection with the processing of your personal information for the purposes described, including, but not limited to, IT and communications service providers, Opus’s advisors such as auditors and accountants and any external legal advisors as may be instructed.
- Third parties relevant to the fiduciary and other services that we provide, including, but not limited to, banks, law firms and other professional service providers, regulators, law enforcement agencies, governmental institutions, tribunals and courts.
- To the extent required by law, regulation or court order.
- Should you apply for an employment position with us, your personal information may be disclosed for the purposes of seeking references and confirming details that you have provided.
Where there is a need or requirement to transfer your personal information outside the European Economic Area, Opus will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. For instance, the recipient country may have been assessed by the European Commission as providing an "adequate" level of protection for personal data (Guernsey has been assessed as being adequate).
In all cases, however, any transfer of your personal information will be carefully considered to ensure it is compliant with the Data Protection (Bailiwick of Guernsey) Law 2017.
We may contact you by email or other means to inform you about other services or events which may be of interest to you.
You have the right at any time to stop us from contacting you for marketing purposes. If you wish to do so, please contact: firstname.lastname@example.org
Personal information retention
Your personal information will be retained for as long as required:
- for the purposes for which the personal information was collected;
- in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations; and/or
- as required by data protection laws and any other applicable laws or regulatory requirements.
Opus will ensure that the personal information that we hold is subject to appropriate security measures.
Your access to and Control over Your Personal Information
You have rights in respect of the personal information about you that we process:
- the right to access and port personal information;
- the right to rectify personal information;
- the right to restrict the use of personal information;
- the right to request that personal information is erased; and
- the right to object to processing of personal information.
You also have the right to lodge a complaint about the processing of your personal information either with us, or with the Office of the Information Commissioner in Guernsey (https://dataci.gg), or the data protection authority in the EU member state of your usual residence or place of work.
Where we have relied on consent to process your personal information, you have the right to withdraw consent at any time.
If you wish to exercise any of the rights set out above, please contact our Group Data Protection Officer at email@example.com.
Inaccurate or amended information
Please let us know as soon as possible if any of your personal information changes (including your correspondence details). Failure to provide accurate information or to update information when it changes may have a detrimental impact upon our ability to provide services to you.
Questions and contact information
If you have any questions in relation to this statement please contact our Data Protection Officer at one of the addresses listed below or by emailing firstname.lastname@example.org
Changes to this notice
This notice may change periodically. You should check this page from time to time to ensure you are happy with any changes. This statement was last updated on 24th May 2018.