DATA PROTECTION POLICY

Trustmoore provides trust, funds, structured finance & capital markets, corporate and management services (hereinafter, “TM”). These services are provided by separate companies within the TM group in their respective geographic areas. A full list of the jurisdiction where the companies are located is available here.

TM respects the expectations of its Clients and Employees that the privacy, confidentiality and security of their personal data is warranted when residing within TM.

Therefore, TM has implemented the TM Personal Data Protection Policy which sets out TM’s privacy standards regarding the collection, processing, use and storage of personal data, explains why and how TM collects data and the corresponding legal basis as well as TMG’s rights and obligations (hereinafter referred as the “Policy"). This Policy is available through this website at the following link: (Link of the document)

This Policy provides for the minimum standard for protecting Personal Data of TM’s Clients and Employees globally. Furthermore, each TMG’s office is in charge of ensuring compliance with local regulations.

For the collection of Personal Data through TMG’s Website, we refer to our separate Website Privacy Statement for more information in this regard. Further, we refer to our Cookies Policy.

Website Privacy Statement

1. Introduction and Scope

This Privacy statement sets out how TM uses your Personal Data in connection with any services provided to you (‘Services’) as a user and visitor of TM website. For purpose of this Privacy Statement, “Personal Data” means any information relating to a Data Subject; a natural person 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, account number, information about payments made from the bank account, among others.

This Privacy statement only applies to the usage of Personal Data of users and visitors of TM website. This type of Personal Data is collected through various channels, such as e-mail, telephone calls, via forms you submit to us, and through cookies. Please refer to our Cookies Policy to more information in this regard.

2. Types of Personal Data:

The Personal Data that TM collects and processes may depend on the type and scope of the services provided:

Services Types of personal data
Corporate Services First name and family name, address, telephone, email, nationality, date of birth, place of birth, gender, Tax / Social / National identification number, compensation and benefits financials, user account details, job title, Client ID, signature, bank account details.
Human Resources and Payroll First name and family name, address, telephone, email, nationality, date of birth, place of birth, gender, marital status, Tax / Social / National identification number, compensation and benefits financials, user account details, job title, employee ID, Client ID, signature, bank account details, health status related data.

3. Use of personal data:

Further, TM may only process Personal Data when either of the following legitimate purposes apply:

  • Consent: The Data Subject has given consent to the Processing of his or her Personal Data for one or more specific purposes; e.g. sending information about our services, newsletters, promotions, news or services updates.
  • Performance of Contract: Processing of Personal Data is necessary for the performance of a contract to which the Data Subject is party, or in order to take steps at the request of the Data Subject prior to entering into a contract;
  • Legal Obligation: Processing of Personal Data is required for complying with a legal or regulatory obligation (including the laws of the financial sector, anti-money laundering and tax laws) to which TM is subject;
  • Vital interest of the Data Subject: Processing of Personal Data is necessary for protecting the vital interests of the data subject or of another natural person;
  • Task carried out in the public interest: Processing of Personal Data is necessary for the performance of a task carried out in the public interest or in the exercise of official authority.
  • Legitimate interests: Processing of Personal Data is necessary for the purposes of the legitimate interests pursued by TM, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject which require protection of Personal Data, in particular where the Data Subject is a child.

4. How we share your Personal Data:

We share your Personal Data with the following parties:

  • Data controllers within TM: Your Personal Data will be shared between the TM entities that may use your Personal Data as described in this Privacy Statement for internal administrative purposes, management purposes, analytical purposes and other business-related purposes. Your Personal Data will only be used by TM companies for marketing purposes if you have given your explicit consent thereto and/or where we have legitimate interest to do so. An overview of the locations TM entities operate in can be found here (link).
  • Service Providers and Processors: We engage third party processor to provide Services on our behalf, which may have access to your Personal Data, including: suppliers (such as IT service providers); marketing and advertising companies that carry out marketing activities on our behalf; analytics and search engine providers that assist us in the improvement and optimisation of our website, such as Google Analytics. In providing their services, they will access, receive, maintain or otherwise process Personal Data on our behalf. Our agreements with these service providers do not permit use of your Personal Data for their own (marketing) purposes. Consistent with applicable legal requirements, we take commercially reasonable steps to require third parties to adequately safeguard your Personal Data and only process it in accordance with our instructions.
  • Third parties in case of legal requirement: We will disclose your Personal Data if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process served on us, or to protect the rights or safety of the website, us or our affiliated companies.

5. Security:

TM keeps the Personal Data confidential and will ensure its staff and, processors and sub-processors are bound by the same confidentiality obligation. TM implements appropriate technical and organizational measures to protect Personal Data; preventing unauthorized or unlawful access to it.

6. Data retention

We retain your Personal Data as long as required to satisfy the purpose for which they were collected and used, unless a longer period is necessary for our legal obligation to defend.

7. Your rights

TM takes appropriate measures to comply with Data protection laws in order to ensure Data Subjects rights. In case Data Subjects have any questions, requests or complaints regarding their rights, they are encouraged to contact TM via privacy@trustmoore.com. A written question, request or complaint should have a clear subject related to the rights of the Data Subjects, that are the following:

  1. The right to be informed
  2. The right of access
  3. The right to rectification
  4. The right to erasure
  5. The right to restrict processing
  6. The right to data portability
  7. The right to object
  8. The rights in relation to automated decision making and profiling

For further information regarding the right, you can see Annex IV of our Data Protection Policy.

In the event your personal data is processed on the basis of your consent, you can withdraw your consent at any time by sending an email to the local TM entity which collected your data or privacy@trustmoore.com. specifying your request, without affecting the lawfulness of processing based on consent before its withdrawal.

You may lodge a complaint with a supervisory authority, in particular in your Member State of residence, if you consider that the collection and use of your Personal Data infringes this Privacy Statement or applicable law.

8. Changes to this Website Privacy Statement

This Website Privacy Statement may be revised from time to time. If a fundamental change to the nature of the use of your personal data is involved or if the change is in any other manner relevant to you, we will ensure that information is provided to you well in advance of the change actually taking effect.

9. Contact Us

If you have any questions, comments or complaints in relation to this Privacy Policy or the processing of your personal data, please feel free to contact your customary Trustmoore representative or our compliance team via privacy@trustmoore.com or +31204712707.

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