Privacy | abacus

Your privacy is important to us and we are committed to protecting and respecting it. This Privacy Policy provides an explanation as to what happens to any personal data that you provide to us or that we collect from you.
It is important that you read this Privacy Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, to ensure that you are fully aware of how and why we are using your personal data. This Privacy Policy supplements our other notices and does not override them.
We may update this Privacy Policy from time to time so please review it periodically.



Controller

We, Abacus Trust Company Limited, Abacus Financial Services Limited, Abacus Corporate Services Limited, Abacus Financial Services (Malta) Limited (collectively referred to as “Abacus”, “we”, “us” or “our” in this Privacy Policy) are the Controller of the personal data relating to our personnel and to personal data used in our business for our own commercial purposes.

We have appointed a Data Protection Officer (“DPO”) who is responsible for this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details below:

Email address: datacontroller@abacusiom.com

Postal address: Data Controller, Abacus, 1st Floor, Sixty Circular Road, Douglas, Isle of Man, IM1 1AE.

Telephone: +44 (0)1624 689600

You have the right to make a complaint at any time to the Information Commissioner, the Isle of Man supervisory authority for data protection issues (www.inforights.im) or the Office of the Information and Data Protection Commissioner, the Malta supervisory authority for data protection issues (www.idpc.org.mt) (collectively the “respective Commissioner”).

We would appreciate the chance to deal with your concerns before you approach the respective Commissioner so please contact us in the first instance.



Information We Collect

In operating our website, we may collect and process the following data about you:

  • Details of your visits to our website and the resources that you access, including, but not limited to, location data, traffic data, communication data and weblogs.
  • Information that you provide by filling in forms on our website, such as when you register to receive information from us.
  • Information provided to us when you communicate with us.



Use of Cookies

On occasion we may gather information about your computer to provide statistical information regarding the use of our website and for our services. Such information will not identify you personally, it is statistical data about our visitors and their use of our website. The statistical data does not identify any personal details.

Similarly, we may gather information about your general internet use by using a cookie file. Where used, these cookies are downloaded onto your computer automatically. The cookie file is stored on the hard drive of your computer as cookies contain information that is transferred to your computer’s hard drive. Cookies help us to improve our website and the services that we provide to you.

Computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may not be able to access some areas of our website.



How We Use Your Information

The information that we collect and store relating to you may be used for the following purposes:

  • To provide you with information requested from us, relating to our services.
  • To enable us to provide our services to you.
  • To provide information about other services which we feel may be of interest to you where you have consented to receive such information.
  • To notify you about any changes to our website, such as improvements to our services.

We do not reveal information about identifiable individuals to any other 3rd party service provider but we may, on occasion, provide them with aggregate statistical information about our visitors.

You can ask us to stop sending you marketing communications at any time by following the opt-out links on any marketing communication sent to you, or by contacting us at any time.

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us that may have resulted from an agreement or other transaction between us.



How We Store Your Personal Data

Data that is provided to us is stored on our secure servers. Transmission of information over the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically. Transmission of such data is therefore entirely at your own risk.



Third Party Links

Our website contains links to other websites. These websites should have their own privacy policies which you should familiarise yourself with. We do not accept any responsibility or liability whatsoever for their policies or website content as we have no control over them.



Your Rights Under Data Protection

Under certain circumstances you have rights under data protection laws in relation to your personal data:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of these rights, please contact the DPO in writing at the above contact details.

You will not 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 is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances and we will advise you accordingly.

We may need to request specific information from you to help us to confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to a person that has no right to receive it. We may also contact you to ask you for further information in relation to your request to help with our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. If this is the case, we will notify you and will keep you updated.



Your Legal Rights
Under the Data Protection Acts you have the right to:

Request access to your personal data –

Known as a “Data Subject Access Request”, this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction –

This enables you to have any incomplete or inaccurate personal data that we hold about you corrected, although we may need to verify the accuracy of the new personal data you provide to us.

Request erasure –

This enables you to ask us to delete or remove personal data where there is no valid reason for us continuing to process it.

You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to Object to processing (please see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons and we will notify you, if applicable, at the time of your request.

Object to processing –

You can object to us processing your personal data where we are relying on a legitimate interest (or those of a 3rd party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

You also have the right to object where we are processing your personal data for direct marketing purposes.

In some cases, we may demonstrate that we have legitimate grounds to process your personal data which overrides your rights and freedoms.

Request restriction of processing –
You can ask us to suspend the processing of your personal data in the following scenarios:

  • if you want us to establish the accuracy of the personal data;
  • where our use of the personal data is unlawful but you do not want us to erase it;
  • where you need us to hold the personal data, even if we no longer require it, as you need it to establish, exercise or defend legal claims;
  • you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.

Withdraw consent at any time –

Where we are relying on consent to process your personal data, you can withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you and we will advise you if this is the case at the time you withdraw your consent.




Contacting Us

We welcome any comments, requests or queries that you may have regarding this Privacy Policy, so please write to the DPO at the above contact details.

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Abacus Trust Company Limited is a member firm of the “Nexia International” network. Nexia International Limited does not deliver services in its own name or otherwise. Nexia International Limited and the member firms of the Nexia International network (including those members which trade under a name which includes the word NEXIA) are not part of a worldwide partnership. Nexia International Limited does not accept any responsibility for the commission of any act, or omission to act by, or the liabilities of, any of its members. Each member firm within the Nexia International network is a separate legal entity.
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