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⦁ INTRODUCTION
⦁ PURPOSE OF DATA PROTECTION
⦁ DATA WE COLLECT ABOUT YOU
⦁ PURPOSES & LAWFUL BASIS FOR PROCESSING
⦁ SHARING YOUR PERSONAL DATA
⦁ TRANSFERRING YOUR DATA OVERSEAS
⦁ RETAINING YOUR DATA
⦁ PROTECTING YOUR DATA
⦁ YOUR RIGHTS & OPTIONS
⦁ COOKIE POLICY
⦁ CONTACT US
⦁ UPDATES
INTRODUCTION
Consilium Advisory is a global provider of financial crime consulting and professional development services to corporate, institutional and to private individuals. This global privacy notice (“notice”) explains how we collect, manage, and protect your personal data if we need to process it as a data controller for the purposes of providing services to our clients. References to “we”, “us” and “our” in this notice are to one or more members of Consilium Advisory.
Consilium Advisory LLC, a company incorporated in Sharjah, United Arab Emirates with registered license number 2220245.01, whose registered office is at SHAMS Business Center, Sharjah Media City FZ, Sharjah, UAE. You can contact Consilium Advisory using the details provided on our here. You can also contact our Managing Director using the details provided at the end of this notice.
We collect and process your personal data if you are:
⦁ a client that is an individual receiving services in your own capacity (an “individual client”), for instance, related to a trust or a foundation, from us; or
⦁ associated with a corporate client because you are (for instance) an owner, director, officer, employee or contractor of the corporate client, or an investor in it, or if you are the subject of, for example, share plan administration services that we provide to our client, your employer.
We also collect your personal data if you represent other entities or organizations that we deal with, such as advisers, governmental and judicial bodies, regulators, suppliers or anyone that makes any form of enquiry in relation to us or our services or if you personally make any enquiry in relation to (for instance) our services or employment with us.
If you are an individual client, the data controller of your personal data is the member of Consilium Advisory named in the engagement agreement you have agreed with us.
If you are not an individual client and a member of Consilium Advisory is a data controller in relation to personal data collected from you, the data controller is the member of Consilium Advisory which has collected that personal data.
This notice does not apply to the collection or use of personal data by any member of Consilium Advisory as a data processor acting on instructions from a client. Where this applies, the client will be the data controller and its privacy notice and/or the terms of an agreement as to processing agreed between us will apply.
PURPOSE OF DATA PROTECTION
The purpose of data protection law is to protect your rights and privacy when we process your personal data. Personal data is any information relating to an identified or identifiable natural person. A person is “identifiable” if he or she can be identified, directly or indirectly, not only by things such as a name or an identification number, but also by things such as location data or some factor specific to (for example) the physical, physiological or social identity of that person.
More common examples of personal data include names, identification numbers, contact information, identity documents, medical records and photographic images and it may be contained in written document or in a recording, voicemail, for example. “Processing” covers any activity involving personal data and includes such things as the collection, recording, storage, adaptation, use, disclosure and destruction of personal data.
Because of the broad definition of “processing”, we will in many cases need to start processing personal data about you before you or an entity with which you are associated or otherwise connected, actually become(s) a client or a supplier, as the case may be. Therefore, where the context allows, references in this notice to “clients”, “suppliers” and others are to be read as including references to potential clients, suppliers and so on, even if you or they never actually become(s) a “client” or a “supplier” and so on. The only exception to this is in relation to “potential employees”, who are dealt with separately below.
DATA WE COLLECT ABOUT YOU
Clients & Persons Connected to Clients
If you are an individual client, are associated with a corporate client or are otherwise connected with client (whether private or corporate) because (i) you are a legal or beneficial owner, investor, a settlor, protector or beneficiary or (ii) you are a director, officer, employee or contractor of a client or (iii) you are the subject of, for example, share plan administration services that we provide to our client, your employer, we collect and process your personal data for various purposes connected with our
services.
What personal data we collect and for what purpose will depend on our relationship with the client in question and/or you but will include:
⦁ Name and Contact Details: Information that we require for the purposes of managing our relationship, including your names and your postal addresses, email addresses and telephone numbers.
⦁ Due Diligence & Regulatory Details: Information that we require to meet our legal and regulatory obligations, particularly anti‐money laundering legislation, and to assess the risk associated with providing services to the client in question, including:
⦁ Identity information including your current and former names, aliases, date of birth, country of birth, place of birth, gender, nationality and a copy of your valid passport and/or birth certificate (including issue date and expiry date, where applicable).
⦁ Documents providing proof of your identity and address(es), such as copies of government issued documents, bank statements, utility bills and similar documents.
⦁ Detailed tax status information, including your tax domicile, and tax identification number.
⦁ Proof of the source of your wealth and funds, such as bank statements, pension plans, property sales agreements and loan documents, should a case for such proof arise.
⦁ Occupation and employment information, including details of legal entities you are employed by or associated or otherwise connected with.
⦁ Details of criminal convictions and disqualifications, history of bankruptcy and details of investigations by any official body and/or if you are named on a sanctions list.
⦁ Details of involvement in high‐risk or high‐profile activities and of any activities of a political nature.
⦁ Other due diligence information gathered from checking tools we use and from searching information in the public domain.
⦁ Records of Correspondence: personal data contained in communications that take place between you and us and/or the client in question and us, including emails, letters, meetings minutes and/or recordings and telephone call and voicemail recordings.
⦁ Other information: Additional information that (a) you provide to us or that the client in question (or someone else on its behalf) to provides us; (b) we collect; or (c) we create when providing services to the client in question. We collect personal data from information we learn about you through our relationship and from you from third parties, including the client’s professional advisers, due diligence and risk assessment screening service providers and from the public domain, including from internet searches.
The types of data we collect may include data relating to your race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health and your sex life or sexual orientation (‘special category personal data’) and data relating to criminal convictions or offences.
In this notice a “corporate client” includes any entity, organization or other body, whether incorporated or not, that is not an individual that is a client of Consilium Advisory in his or her own capacity.
Professional Advisor, Regulators & Suppliers
We work with entities or organizations that provide professional advice or services to us or to our clients, those that supervise and regulate us, and our clients and other suppliers of products and services to our business. We will collect personal data about you if you work for one of these organizations.
The personal data that we collect will include professional and/or personal contact details, including addresses, telephone numbers and email addresses, and records of communications that take place between you and/or others at the organization for which you work and us, including emails, letters, minutes and/or recordings of meetings and recordings of telephone calls (where made) and voicemails. In addition, we also, we collect personal data that you provide us with or that is created by us during our relationship with the entity or organization for which you work.
Potential Employees
If you are an applicant for a job with us (a potential employee), the personal data that we process about you will include:
⦁ your name, address and contact details, including telephone numbers and email address(es);
⦁ details of your qualifications, skills, experience and employment history;
⦁ information about your current level of remuneration, including entitlement to benefits;
⦁ whether or not you have a disability that we may need to make adjustments for during the recruitment process;
⦁ information about your entitlement to reside and/or work in the place where you have applied for a job; and
⦁ equal opportunity monitoring information, including information about your ethnic origin, sexual orientation, health and religion or beliefs.
If your application for a job with us is unsuccessful, we will retain your personal data for 6 months after the date on which we inform you (or any recruitment agency through which you have applied to us) that your application was unsuccessful, unless you ask us to retain your details on file for a longer period. We will delete any personal information no longer required and will do so in an appropriate and secure manner.
If your application for a job with us is successful, our retention of your personal data will be governed by our separate policy on staff personal data, which will be made available to you by our HR department as part of your becoming a member of staff.
Enquirers & Website Visitors
If you contact by us by telephone, email, using a contact form or via our social media channels we will collect the personal data that you provide to us and use it to respond to your enquiry. This personal data typically includes your name, your organization and your professional and/or personal contact details.
When you visit our website, we will automatically collect data about you, including:
⦁ technical information including the Internet Protocol (IP) address used to connect your computing device to the Internet, your browser type and version, time zone setting, operating system and platform;
⦁ information about your visit, which may include the pages viewed and page response times; and
⦁ your country of location by reference to a look‐up of your IP address against public sources.
Our website also uses cookies and/or similar technologies to collect and store certain information about your interaction with our website. For more information about how we use cookies see our Cookies Policy.
Marketing Communications
If you subscribe to our marketing communications or your details have been otherwise lawfully added to one of our contact lists, we will collect and process your name, job title and company name, location and contact details in order to provide you with promotional update communications about us or our services.
PURPOSES & LAWFUL BASIS FOR PROCESSING
Clients & Persons Connected to Clients
If you are a client that is an individual, are associated with corporate client or are otherwise connected with client (whether private or corporate), we will process the personal data that we collect from or about you for the following purposes and on the following lawful bases:
Purpose
Carrying out due diligence and performing risk assessments, including carrying out standard due diligence checks, enhanced due diligence checks, politically exposed person checks and performing risk assessments in relation to a client’s financial standing, credit worthiness and eligibility for our services.
Legal & regulatory compliance and compliance with law enforcement requests, including performing checks and monitoring transactions for the purpose of preventing and detecting crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. Also, sharing information on suspected financial crimes, fraud and threats with law enforcement and regulatory bodies.
Providing our fiduciary and administration services to our client.
Managing and developing our relationship with our client, including providing account management, contacting our client for feedback and inviting our client to participate in customer satisfaction surveys.
Internal management, administrative and organizational purposes, including maintaining internal records and carrying out other business administration tasks.
Statistics and other data analysis, including creating forecasts and business plans, improving our services and developing new services.
Sharing data with entities affiliated with Consilium Advisory, including sharing client records and results of due diligence exercises with our global entities.
We accept that sharing your personal data for such purposes may be barred by, or be subject to our compliance with, local laws protecting personal or professional secrecy in some jurisdictions.
Sharing data with other third parties, including third parties who process personal data on our behalf.
Lawful basis for processing
Necessary to comply with legal obligations to which we are subject.
Our legitimate interests to assess the risk associated with providing our client with our services.
When processing special category personal data, we do so only with your explicit consent.
Necessary to comply with legal obligations to which we are subject.
When processing special category personal data, we do so only with your explicit consent.
Necessary for the entry into and performance of the agreement to which our client is a party.
Our legitimate interests to provide our services to a client that you are associated with or connected to.
Our legitimate interests to develop our relationship with our client, by such things as responding to enquiries about our services and/or other requests, and collecting feedback, to assess levels of client satisfaction and to improve our services. In addition, with your consent where necessary, we may process your personal data, to inform you about our present and future services and to give you relevant news and service updates.
Our legitimate interests to manage our business.
Our legitimate interests to develop and improve our business through aggregated and anonymised reporting and analysis.
Our legitimate interests to identify and develop shared clients between Consilium Advisory and its affiliates or business partners or service providers and the jurisdiction(s) in which we operate and to utilize existing due diligence and risk assessment information when providing an existing client with services in a new jurisdiction.
Our legitimate interests to share your data with trusted third parties who provide us with services relevant to our provision of services to our clients, including professional advisers, screening service providers and IT service providers.
Professional Adviser, Regulators & Suppliers
If you work for or represent one of our professional advisers or suppliers or an organization that supervises or regulates us, we will process your personal data for the purpose of our legitimate interests in carrying out our business and in providing services to our clients.
Potential Employees
If you are an applicant for a job with us (a potential employee), we will process personal data about you in order, in our legitimate interests, to assess your application and to advance that application through our recruitment processes, including by making details of your application, including personal data, to relevant members of our management and of our HR Department, and to comply with policies and procedures under applicable professional regulations, guidelines or notices and/or that may have been put in place by us, relation to staff and recruitment.
Enquirers & Website Visitors
When you make contact with us, we will process your personal data for the purpose of our legitimate interests in responding to your enquiries and/or request for information. We will collect information about you, in our legitimate interest, when you visit our website in order to present content to you in the most effective manner for you and your computer and on order to keep our website safe and secure.
Marketing Communications
We may use your personal data to send you marketing about our fiduciary and administration services, our news and events if you have subscribed to our marketing communications and we have obtained your consent. If your details have been lawfully added to one of our contact lists by other means, we will send you marketing information based on our legitimate interests to send you promotional materials from time to time.
You can tell us to stop sending you marketing information at any time by objecting or withdrawing your consent. You can do so by contacting us at communications@consiliumadvisory.me or by using the “Unsubscribe” link in any marketing email you receive from us. Alternatively, you can change your preferences at any time, also by using the links in our marketing communications or by contacting us through our website.
Even if you tell us that you do not want to receive marketing information from us, we still may have the right to process your personal data for the purposes of providing services to you or a client with which you are associated or otherwise connected and, in such cases, we will continue to process your personal data for those purposes.
We do not sell or otherwise pass on your contact details to any third party outside Consilium Advisory for marketing purposes.
Other Situations
Where we do not base our use of personal data about you on one of the above legal bases or some other legal basis that we might explain to you in a supplemental privacy notice (see below), we will ask for your consent before we process the personal data (these cases will be clear from the context).
In some instances, we may use personal data about you in ways that are not described above. Where this is the case, we will provide a supplemental privacy notice that explains such use. You should read any supplemental notice in conjunction with this notice.
To the extent that we rely upon consent as the legal basis under which we use your data for any purpose, you are permitted to withdraw your consent at any time.
SHARING YOUR PERSONAL DATA
We may share your data with:
⦁ Other entities affiliated with Consilium Advisory, subject to any applicable confidentiality laws. We do this because we are a global organization and work with clients across multiple jurisdictions. Sharing records and the results of due diligence and risk assessments enables us to provide our services more efficiently and develop our relationship with you. Access to shared data is limited only to personnel who need access to carry out their assigned duties and, where relevant, to those who are entitled to receive it under applicable confidentiality laws.
⦁ Third parties who process data on our behalf to provide us or our clients with products or services for the purposes outlined in the table above in the row entitled “Sharing data with other third parties”. These third parties include:
⦁ Professional advisers, including lawyers and tax advisers.
⦁ Screening service providers, including due diligence and financial crime screening database providers, such as Thompson Reuters World‐Check.
⦁ IT service providers, including hosting and cloud service providers, such as Microsoft.
⦁ external networking sites, as a result of you visiting our website (which contains plugins to social media sites) while logged in to a relevant social network provider.
⦁ Other suppliers and providers of services to us, including banks, our sub‐contractors and agents.
⦁ Other third parties, where required or permitted by law, for example:
⦁ Regulatory authorities.
⦁ Government departments.
⦁ In response to a request from law or revenue enforcement authorities or other government bodies.
⦁ In compliance with an order of a competent court or other authority, with which we are obliged to comply.
TRANSFERRING YOUR DATA OVERSEAS
When sharing data about you with other entities affiliated with Consilium Advisory, or if it is necessary to provide you with our services, your data may be transferred outside the country in which it was collected. If your data is collected within the European Economic Area (EEA), this means that your data may be transferred outside of it, including to a country or organization that may not have data protection standards equivalent to those in the EEA. If your data is collected outside of the EEA, this means that your data may be transferred into the EEA.
Where we transfer personal data to a country or organization outside the EEA, we will only do so where:
⦁ The country or organization we are transferring your data to is recognised by the European Commission as providing ⦁ adequate data protection standards; or
⦁ We have implemented appropriate safeguards to ensure the protection of your personal data, such as ⦁ standard data protection clauses adopted by the European Commission.
If you would like to receive a copy of the information relating to the safeguards we put in place when we transfer your personal data outside the EEA, then you can contact our Managing Director using the details provided at the end of this notice.
RETAINING YOUR DATA
We have retention policies in place to meet regulatory requirements and client obligations. We retain personal data for the duration of the services that we provide as necessary to meet our obligations under our contractual obligations to you, to identify issues or to issue and resolve legal proceedings. We also retain personal data beyond the duration of the services that we provide as necessary to meet our legal and regulatory obligations to retain such information under applicable law. We may also retain aggregate information beyond this time for statistical analysis and research purposes and to help us improve our services. Old media (PC and server disks, tapes, etc.) are stored and then destroyed using a reputable specialist organization.
Retention periods are kept under review. There may be some cases in which we are obliged to delete personal data that we process, such as data that has been processed in breach of applicable law or to comply with a legal obligation to delete it. In other cases, there may be no specific time limit applicable to the retention of particular personal data and, in determining how long particular personal data will be retained for, we will use criteria including whether (a) the data is no longer necessary for the purpose for which it was collected and (b) the data can, if required, be collected again without undue delay or difficulty.
PROTECTING YOUR DATA
We implement appropriate technical and organizational measures to protect the personal data that we process from unauthorised disclosure, use, alteration or destruction. For more information about the steps we are taking to protect your data, please contact our Managing Director using the details provided at the end of this notice.
YOUR RIGHTS & OPTIONS
Depending on where you are resident, you may have some or all of the following rights under applicable data protection laws in respect of your data that we hold:
⦁ You have the right of access to your personal data and can request copies of it and information about our processing of it.
⦁ If the personal data we hold about you is incorrect or incomplete, you can ask us to rectify or add to it.
⦁ Where we are using your personal data with your consent, you can withdraw your consent at any time.
⦁ Where we are using your personal data because it is in our legitimate interests to do so, you can object to us using it this way.
⦁ Where we are using your personal data for direct marketing, including profiling for direct marketing purposes, you can object to us doing so and opt out of all future marketing.
⦁ You can ask us to restrict the use of your personal data if:
⦁ It is not accurate.
⦁ It has been used unlawfully but you do not want us to delete it.
⦁ We do not need it anymore, but you want us to keep it for use in legal claims; or
⦁ If you have already asked us to stop using your data but you are waiting to receive confirmation from us as to whether we can comply with your request.
⦁ In some circumstances you can compel us to erase your personal data and request a machine readable copy of your personal data to transfer to another service provider.
⦁ The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
Your rights to object to our processing of your personal data are not absolute and it may be that in some circumstances we can continue to process your personal data if we can demonstrate compelling legitimate grounds, which override your interests, rights and freedoms or if the processing is for the establishment, exercise or defence of legal claims.
Further, if you object to our processing of your personal data and, as a result, we stop processing it, we may not be able to continue to provide services to you or to the client with which you are associated or otherwise connected in a particular manner or at all and we may, as a result, need to terminate the provision of our services.
We will delete any personal data no longer required and will do so in an appropriate and secure manner.
You will not generally have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
If you wish to exercise your rights, please contact our Managing Director using the details provided at the end of this notice.
You can also lodge a complaint with the national data protection authority of your habitual residence, place of work or place of an alleged infringement.
COOKIE POLICY
Fineksus will receive certain information about you when you visit our website; depending on your actions and requests when visiting our site.
If you visit our website to read or to download some information on our pages, we collect and store only the following information:
– The name of the domain from which you access the Internet.
– The date and time you access our site
– The Internet address of the website you used to link directly to our site. If you choose to register on our site to use the services we provide, we collect and store only the following information about you:
a. Name, Surname
b. Email
c. Phone Number
d. Company Name
e. Company Website
f. Position at the Company
g. Country Name
If you identify yourself by sending us an e-mail containing your personal information, then that information will be only used to respond to your message.
Fineksus may use software programs to create statistics which are used for statistical purposes such as identifying the number of visitors, what information is receiving most and least interest, technical design specifications, and identifying system performance. For site security purposes and to ensure that this service remains available to all users, Fineksus also uses software programs to monitor network traffic to determine unauthorized attempts to upload or change information.
Fineksus will not obtain personally-identifying information when you visit our site, unless you choose to provide such information to us by registering to our site, nor will such information be shared or sold to third parties.
COOKIE POLICY
By using our website you agree that Fineksus can use cookies in accordance with this policy.
What are Cookies?
Cookies are messages or small text files stored on hard drive of your device or computer, on the browser or network server; when you visit internet sites.
Fineksus uses cookies in order to;
– Identify you and distinguish you from other users to provide a personalised browsing experience
– Improve the services offered to you by enhancing the design, functionality and performance
– Provide commercial and legal security for you and our company
What type of cookies do we use?
Targeting Cookies: They are used to provide personalised content. They can be used for measuring a campaign as well as targeted advertising. This information is used to make our website and the ads displayed on it more relevant to your preferences. We may use these cookies to remember the sites you visit, in order to identify which channels are more efficient.
Functionality Cookies: They improve the functionality of the site by keeping your preferences. These cookies store information about your previous preferences (language, location etc.) and allow us to provide a more personal user experience.
Session (Transient) Cookies: They allow users to be remembered within a website so any page changes users make is recognized. Session cookies do not collect any data from the user’s devices and they re stored in temporary memory and are not retained after the browser is closed.
Authentication Cookies: They store session ID information in the user’s browser after a successful login.
Disabling Cookies
You can disable cookies by activating the setting on your browser that allows you to not permit the setting of all (or some) cookies. If you disable our use of cookies, you may not access certain features/pages of our site and you will not be able to receive a personalised browsing experience.
This policy might be updated due to the changes in legislation and technology from time to time; therefore you should visit this page periodically to ensure you are updated with any possible change.
CONTACT US
If you have any questions, or wish to exercise any of your rights, then you can contact our Managing Director by email at privacy@consiliumadvisory.me or by post to Consilium Advisory LLC, PO Box 9846, Dubai, UAE, marked for the attention of the Managing Director.
Data protection regulator contact details
If your request or concern is not satisfactorily resolved by us you may approach your local data protection data protection authority in the jurisdiction in which we provide services to you.
The contact details for the data protection regulators in the jurisdiction in which we are legally registered are as follows:
UAE: At the date of writing this update the Data Office responsible for administering and enforcing the PDPL has not yet been established.
The UAE Central Bank is responsible for its Consumer Protection Regulation and Standards, the SVF Regulation and the Retail Services Regulation.
The Ministry of Health and Prevention is responsible for the ICT in Health Fields Law.
The Telecommunications and Digital Government Regulatory Authority (“TDRA”) is responsible for the regulation of its Consumer Protection Regulations.
Last modified 18 Jan 2024
UPDATES
We review our policies and procedures regularly and we reserve the right to amend the terms of this notice from time to time at our absolute discretion. Any amended privacy notice will be posted on our website and you are encouraged to visit our website from time to time to ensure that you are aware of our latest policies in relation to the protection of personal data.
Last Updated: April 8, 2024