The Horseshoe Group Privacy Notice

The Horseshoe Group is a leading financial services firm and includes Horseshoe Insurance Services Holdings Ltd and its subsidiaries. The Horseshoe Group is committed to protecting your privacy. This privacy notice explains how we collect, use, share and safeguard your information and how you can contact us.

 

Collection of Data

  1.  We may collect the personal data (“Data”) of clients and other individuals in connection with the purposes set out in this Notice.  These clients and other individuals may include the following or any of them (collectively “you” “your”): 
    1. clients of the Horseshoe Group;
    2. persons linked to a client or an applicant that is not an individual, including the beneficial owners and officers of that client, controllers, or in the case of a trust, including the trustees, settlors, protectors and beneficiaries of the trust; and
  2. If the Data requested by us is not provided in order to meet any regulatory requirements, we may be unable to provide (or to continue to provide) the services to you or to the relevant clients linked to you.
  3. Data may be:
    1. collected from you directly, from someone acting on your behalf or from another source;
    2. combined with other Data available to members of the Horseshoe Group and any member of the Horseshoe Group and its subsidiaries and affiliates;
    3. interpreted to mean any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location Data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person. In other words, information relating to an individual who can be identified directly or indirectly from that Data; an
    4. sourced from Customer Due Diligence (“CDD”) compliance forms; CDD supporting documentation and other related forms or agreements; investor Contribution/Partnership agreements, tax certificates and other related forms or agreements; and correspondence(written, telephonic or electronic). Data collected from these sources may include your first middle and last name, email and physical address, phone number and other contact information, job title, company affiliation(s),  tax identification number, ID documents that identify you (driver’s license/passport), bank details and information about your net worth and/or assets.

Use of Data

We will use your Data for the following purposes or any of them, which may vary depending on the nature of your relationship with us:

  1. to facilitate the opening of bank accounts in connection with the provision of our services;
  2. actions such as the processing of investments, transfers and withdrawals and the payment of distributions;
  3. to report tax related information to tax authorities in compliance with legal obligations;
  4. to monitor calls and electronic communications for (i) processing verification of instructions; (ii) investigation and fraud prevention purposes; (iii) for crime detection, prevention, investigation and prosecution; or (iv) to enforce or defend our and/or our affiliates’ rights, ourselves or through third parties to whom we delegate such responsibilities or rights in order to comply with any legal obligation imposed on us;
  5. to disclose information to other third parties such as service providers, auditors, regulatory authorities and technology providers;
  6. creating and maintaining our risk related models and governance processes;
  7. exercising our rights under contracts with you;
  8. ensuring your ongoing good standing;
  9. to update and maintain records;
  10. meeting our obligations, requirements or arrangements or those of any member of the Horseshoe Group, whether compulsory or voluntary, to comply with or in connection with:
    1. any law, regulation, judgment, court order, voluntary code, sanctions regime, existing currently and in the future (“Laws”); or
    2. any agreement or treaty with Bermuda.
  11. complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing Data and information within the Horseshoe Group and/or any other use of Data and information in accordance with any programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities ;
  12. conducting any action to meet our obligations or those of any member of the Horseshoe Group to comply with Laws or international guidance or regulatory requests relating to or in connection with the detection, investigation and prevention of money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions and/or any acts or attempts to circumvent or violate any Laws relating to these matters;

Disclosure of Data

Data held by us or a member of the Horseshoe Group will be kept confidential but we or a member of the Horseshoe Group may provide Data, subject to confidentiality requirements, to the following parties or any of them for the uses set out above:

  1. any persons under a duty of confidentiality to us or a member of the Horseshoe Group who have undertaken to keep such Data confidential.
  2. any competent authorities (including tax and regulatory authorities), courts and bodies required by law or on their request (with prior notice to you) or to affiliates for internal investigations and reporting.
  3. if you are an Investor of one of the funds we provide services to, we will also provide your personal Data to that Client as the Data Controller and for the purpose of administering the contract we have with them
  4. Data may be transferred to entities located in non-EEA countries or regions including: USA,  Cayman Islands, Bermuda, and any other countries as may be required dependent on client domicile.  Prior to undertaking any such transfers the Horseshoe Group ensures it has adequate safeguards in place such as Intra-Group agreements and standard contractual clauses.

Our Controls

The Horseshoe Group respects your privacy and is committed to protecting your Data.  Further, we have a robust disaster recovery plan in place in the unlikely event of a security breach. Staff are trained on Data protection, confidentiality and security.

To prevent unauthorised access to or disclosure of your Data, we have implemented appropriate controls.

We will retain your Data for as long as required to perform our services and/or to carry out the purposes for which the Data was collected.  Our security measures include a combination of some or all of the following:

  1. pseudonymisation and encryption of personal Data;
  2. the ability to ensure the ongoing confidentiality, integrity, availability and resilience of systems and services;
  3. the ability to restrict the availability and access to Data;
  4. a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational security measures; and
  5. identifying an appropriate level of security and privacy protection insurance to best protect the Horseshoe Group and potential liability for any potential Data security breaches.

Your Rights

You have the right:

  1. to check whether we hold Data  about you and to access such Data;
  2. to  require us to correct any Data relating to you which is inaccurate;
  3. to restrict or object to the processing of your Data in specific circumstances;
  4. to have the information anonymized or deleted in specific circumstances as appropriate;
  5. to request information about our policies and practices in relation to Data and to be informed about the kind of Data held by us;
  6. in relation to Know-Your-Client (“KYC”) information that is supplied about you , to be informed on request which items of Data are routinely disclosed to the relevant institutions, and to be provided with any further information that we may hold to allow you to make a request for correction to the relevant institutions;
  7. to exercise your right to Data portability – that is to have a copy of your Data transferred to you or a replacement service provider in machine-readable form (in specific circumstances);
  8. to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place if you consider that the processing of your Data is in breach of the law.; or
  9. to withdraw any prior consent at any time unless prohibited by regulatory requirements.

Contact Information

You should send requests for access to Data or correction of Data or for information regarding policies and practices and kinds of Data held to:

The Data Protection Officer
Horseshoe Group,
Wessex House,
3rd Floor 45 Reid Street,
Hamilton HM12,
Bermuda

E-mail: privacy@horseshoeglobal.com

Please contact The Data Protection Officer if you have any questions about this Notice. We may from time to time, revise this Privacy Notice.The most up to date version of the notice is always available on our website www.horseshoeglobal.com.