At Aston & Williams we want you to be given the opportunity to understand how we use your personal information and to be confident that this information is safe and secure. This privacy policy explains why we collect your information, how we use it, your rights and choices together with the steps we take to keep it secure and confidential.

 

 

We keep our privacy policy under review and we recommend that you check it regularly. This privacy policy was last updated on 20 October 2020.

 

THIS PRIVACY POLICY COVERS:

 

• How we use your information to provide Aston & Williams's services

• Why we share your information within the Aston & Williams Group

• Why we share your information with other organisations

• How we transfer your information to other countries

• How we use your information to contact you

• What happens to your information when we don’t need to use it anymore

• How we keep your information secure

• Your rights in relation to your information

• How we use social media

• Your rights when you follow links to external websites

• The cookies we use and how you can control them

• How you can ask for more information, ask a question, or make a complaint

• How to contact the Aston & Williams Group Data Protection Officer

 

Where we refer to Aston & Williams, we mean Aston & Williams Group and its wholly owned subsidiary companies. 

 

USING YOUR INFORMATION TO PROVIDE ASTON & WILLIAMS SERVICES

 

Aston & Williams offers a wide range of services and we collect and hold personal information that identifies clients, intermediaries, suppliers and other third parties linked to our clients. The types and amount of information we collect differs depending on your relationship with us.  We only collect the data we need in order to provide the services you have asked for, or that we need in order to fulfil our legal or regulatory obligations in relation to those services.  If we need to collect additional information we will explain why we need it.

 

You are not obliged to provide any of the information we ask you for, but if you choose not to we may be unable to provide you with services or respond to your enquiries.

 

The examples in this section are only an overview of the types of processing we carry out. If you would like a more in-depth list of our processing activities and our legal basis for processing, please contact the Aston & Williams Group Data Protection team.

 

As an example, when you enquire about our services and when you have appointed Aston & Williams to provide services, your personal information may be used for:

 

• Responding to enquiries, offering services, and agreeing terms of business

• Communicating with you about the services you have asked us to provide and informing you of changes that affect those services

• Providing fiduciary services

• Setting up and administering trusts and companies via a Regulated & Licensed Partner 

• Translation services

 

There are times when we are under a legal obligation to collect your personal information, including for:

 

• Preventing financial crime and the funding of terrorism

• Identifying politically or commercially exposed persons, or those with a significant exposure to the media 

• FATCA/CRS reporting

• Obtaining certificates of competency, qualification certificates and health records for yacht and aircraft crew

 

 

SHARING YOUR INFORMATION WITHIN ASTON & WILLIAMS 

 

We share your information with other Aston & Williams companies where it is necessary in order for us to provide you with services or to allow our company boards to have full oversight of our operations. 

 

To enable Aston & Williams to operate on a global scale, some of our business functions have been amalgamated at group level to provide centres of excellence, allowing our expert staff to provide a high quality, streamlined service. These specialist functions are sometimes outsourced and can include Client Accounting, Group Risk Management, Data Protection, Finance and Corporate Communications. In addition, some specialist services that support our business are also centralised, such as IT, Project Management and Internal Audit.

 

Wherever possible, information provided for group functions is anonymised, for example, where statistical information is shared to meet group reporting and governance requirements. There are however, times where we cannot provide the relevant services without using some personal information. In these cases access is only granted to employees who need it in order to provide those services and the amount of information shared is limited to the minimum that will allow them to fulfil their functions.

 

SHARING YOUR INFORMATION WITH OTHER ORGANISATIONS

 

In the usual course of our business, we use third party organisations to support the essential delivery of our services. Under these circumstances Aston & Williams remains responsible for the security and privacy of your information and we regularly review all third parties' security measures to ensure they meet the same standards you expect from Aston & Williams. All third party organisations operate under contracts that restrict their use of your personal information to providing the services we have employed them for.

 

The services they provide include:

 

• providing and supporting the IT systems in which your information is stored

• transportation and storage of information and confidential destruction

• translation of documents

• managing events arranged by Aston & Williams

• administering bulk email campaigns for information or marketing purposes

 

We may also have an obligation to share some of your personal information with public authorities, such as:

 

• Tax and VAT authorities

• Regulatory authorities

• Law enforcement agencies

• Yacht and aircraft registries

 

In some cases, your personal information will be shared with organisations outside Aston & Williams in order to obtain specialist or professional services that are necessary for the services we provide.  These include:

 

• Your professional advisers, such as accountants, lawyers, agents and architects

• Banks or other financial institutions

• Credit reference agencies who assist us in meeting our customer due diligence obligations

• Services provided by our external cyber security partner company

 

These external organisations have a legal obligation to comply with privacy and data protection legislation and may also operate under a professional duty of confidentiality due to the type of service they provide. They have their own privacy policies that provide information about how they use your information.

 

You can find out more about the organisations your data has been shared with by contacting the Aston & Williams Group Data Protection team.

 

TRANSFERRING YOUR INFORMATION TO OTHER COUNTRIES

 

When we share your information with organisations that are located in different jurisdictions, including other Aston & Williams companies, we ensure they apply equivalent levels of protection.  

 

Countries in the European Economic Area and those that have been awarded an adequacy ruling by the EU are considered to be secure. Personal information can flow freely between those countries because they provide equivalent levels of protection and their laws give you the same rights and protections in relation to your personal data.

 

For other international transfers we put data sharing contracts in place to ensure you retain the same rights and protections in the recipient country as you have in the country where your information was originally collected. This ensures that such transfers are legal and gives you and Aston & Williams, the reassurance of knowing that your privacy rights remain the same wherever your information is being processed.

 

USING YOUR CONTACT DETAILS 

 

From time to time we will send you important notices about the products or services you have asked us to provide, changes to our policies or terms and conditions, or changes to laws or regulations that could affect the service we provide. This is important information that keeps you informed about the products or services you have asked us to provide.

 

We may also send you emails containing newsletters and articles, information about additional services provided by Aston & Williams, or invitations to events we are organising, attending or sponsoring.  You can opt-out of receiving these messages by contacting us here or by clicking on the unsubscribe link in those emails.

 

We never sell or lease your personal information or share it with other organisations outside Aston & Williams for marketing purposes.

 

STORING AND DELETING YOUR INFORMATION 

 

The amount of time we keep your personal information will vary depending on your relationship with Aston & Williams. In some circumstances there is a legal or regulatory requirement to keep information for a specific amount of time, although this will be extended if there is ongoing legal action that overrides the normal retention period. Where there is no regulatory or legal requirement, we assess how long we reasonably need to keep your information in order to deal with ongoing queries.

 

When our relationship with you ends, there will be information we cannot delete immediately. Such information will be stored in our physical and/or electronic archives until we no longer have an obligation to keep them. At that point the information will be permanently deleted.

 

KEEPING YOUR INFORMATION SECURE

 

We take the security of personal information and confidential documents extremely seriously. Aston & Williams complies with data protection legislation in the jurisdictions in which we operate and we have put in place appropriate safeguards to prevent unauthorised access or unlawful use of confidential information. 

 

We restrict access to personal information to Aston & Williams employees, contractors and agents who need to know that information in order to process it for us. They are subject to strict contractual confidentiality obligations and they may be disciplined or their contract terminated if they fail to meet these obligations.

 

We also employ a wide variety of technical and organisational security measures to safeguard the confidentiality, integrity and availability of your information.

 

YOUR RIGHTS

 

Subject to some exceptions, you have the right to:

 

• know whether Aston & Williams is processing your personal information

• request a copy of the personal information Aston & Williams holds about you

• have any inaccuracies corrected or/and have incomplete personal data completed

• have your personal data erased if it is no longer needed

• ask Aston & Williams to restrict the processing of your data

• object to Aston & Williams processing your data

• ask for your data to be transferred to a new service provider

• object to processing that is carried out in Aston & Williams's legitimate interests

• not be subject to a decision based solely on automated processing if it produces legal effects or similarly affects you

• make a complaint to a data protection supervisory authority or regulator

 

SOCIAL MEDIA

 

Aston & Williams uses a number of social media sites including Facebook, X, LinkedIn and YouTube. We receive some information about you from these sites when you interact with us or access our social media content. The amount of information we receive is governed by your social media account privacy settings and the policies and procedures of each social media platform.

 

LINKS TO EXTERNAL SITES

 

The Aston & Williams website contains links to other websites which are not controlled by Aston & Williams. We are not responsible for the privacy of those sites and we encourage you to review the privacy policies of each one when you visit external sites so that you understand how those other organisations are using your personal information.

 

COOKIES

 

A cookie is a file which is sent to your computer or other access device when you visit a website.  The Aston & Williams website uses cookies to analyse user activities which helps us to develop it and initiate improvements aimed at making your visits more simple and relevant. The cookies we use do not collect personal information and they are not used to identify individuals.

 

QUERIES AND COMPLAINTS 

 

This privacy policy aims to give you an overview of the ways in which we process your personal information. If you would like more detail or have any queries, please contact us so that we can assist you. We take any complaints we receive about the way we process your information very seriously and we would like to hear from you if you have any concerns. Please refer to the Aston & Williams contacts section at the bottom of this policy for information about our locations and contact details.

 

If you have any concerns about the way we process your personal information we would prefer that you contact us to discuss your concerns.  You also have the right to make a complaint to the data protection supervisory authority in the country where the Aston & Williams company who collected your information is located. Alternatively, if you are in the European Union you can contact the data protection supervisory authority in your location; their contact details can be found on their individual websites. 

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