Privacy policy
The following relates to the treatment of data submitted to us through this site. Please refer to our DISCLAIMER for clarification of our position on marketing and promotion.
This policy has been prepared to comply with The Data Protection (Jersey) Law 2018 (DPJL) for Alnitak Advisors (Jersey) Limited (“AAL”) (No 125290).
This policy applies to personal information held by AAL as data controller for Alnitak Advisors (Jersey) Limited and on behalf of fully owned subsidiary Amthe Capital Limited (“ACL”), having company number 144091, as described below.
It explains what information will be collected about you, how that information may be used, who it may be shared with, the circumstances when it may be shared, and what steps will be taken to make sure it stays private and secure.
It continues to apply even if your agreement for products and services with AAL or ACL, or any other fully-owned subsidiary ends.
It should also be read alongside any contract which you have entered into with AAL or ACL, as these will usually include sections relating to the use and disclosure of information.
This policy covers any products or services you have with us.
Wherever the words ‘you’ or ‘your’ have been used, this means you, any authorised person on your account, anyone who deals with us for you (e.g. trustees or executors, attorneys under a Power of Attorney) and other related people (including authorised signatories, partners, members and trustees).
When we have used the word ‘we’, this means Alnitak Advisors (Jersey) Limited acting as a data controller in respect of your personal data. Unless otherwise stated below, the data controller for the purposes of this notice will be Alnitak Advisors (Jersey) Limited, a company incorporated in Jersey Channel Islands having company number 125290.
The registered office of Alnitak Advisors (Jersey) Limited and of Amthe Capital Limited is:
Kestrel House
Trinity
Jersey
Channel Islands
JE3 5AQ
If you have provided AAL or ACL, or a member of our team with your details in the past, or if you have signed up for any regular automated correspondence administered by AAL or ACL, then we may hold limited personal information about you. We may also hold data collected from other sources, such as social media and other publicly accessible databases including Companies House, LinkedIn and Twitter.
If you have provided us with personal information for the purpose of communication or soliciting business, then you are responsible for making sure the information you give us is accurate and current, and you must tell us if anything changes as soon as possible. If you provide information for another person you will need to direct them to this notice. If we need that person’s consent, we will ask you to confirm that you have obtained such consent.
Why we hold your data:
Alnitak Advisors (Jersey) Limited retains data for purposes including, but not limited to:
Delivering our products and services, administering your account, or processing your transactions where approved by a separate agreement. We will do this in order to perform our contract with you where such provisions form part of our contract;
Preventing and detecting crime, including but not limited to fraud, terrorist financing and money laundering: this will include monitoring, mitigation and risk management, carrying out client due diligence, name screening, transaction screening and customer risk identification. We do this to comply with our legal obligations and because it is in our legitimate interest. We may share your information with relevant agencies, law enforcement and other third parties where the law allows us to for the purpose of preventing or detecting crime. Additionally, we and other financial institutions may take steps to help prevent financial crime and manage risk. We will do this because we have a legitimate interest, a legal obligation to prevent or detect crime or it’s in the public interest. We may be required to use your information to do this, even if you’ve asked us to stop using your information.
Updating or opting out:
Should you wish to update your details or unsubscribe from our newsletter or other email communication that you receive from us at any time, please send us an email at info@AlnitakAdvisors.com. You can also unsubscribe when receiving any of our generic communications and by using opt-out buttons on automated emails.
Legal basis for data retention:
When we use your personal information, we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal information we process and why.
The legal bases we may rely on for processing your personal information include:
- consent: where you have given us clear consent for us to process your personal information for a specific purpose.
- contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
- legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations).
- legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).
Data sharing:
Your data may be shared with third parties such as our website host, our email delivery system, or other parties who provide services to us, or, as above if we are required to do so by law. We never give your details to third parties for their own use or for reasons that do not fall within the scope of this policy.
The type of data we may hold:
Personal details, such as name, previous names, gender, date and place of birth;
contact details, address, email address, landline and mobile numbers;
information concerning your identity such as photo ID and passport information;
other information about you that you provide by completing forms or by communicating with us, whether face-to-face, by phone, email, online or otherwise;
We consider personal data to be information specific to an individual. Our system predominantly holds names, addresses and cities where you or your company are based, your email address for sending electronic correspondence and telephone numbers (landline or mobile) for calls.
Tracking or recording of conversations and actions:
We may record and keep track of conversations you have with us, including phone calls, face-to-face meetings, letters, emails, live chats, video chats and any other kinds of communication. We may use these recordings to check your instructions to us, assess, analyse and improve our service, train our team, manage risk or prevent and detect fraud and other crimes. We may also capture additional information about these interactions, e.g. telephone numbers that you call us from and information about the devices or software that you use. We may use closed-circuit television (CCTV) in and around our sites and these may collect photos or videos of you, or record your voice.
Security: How do we protect your information
We use a range of measures to keep your information safe and secure, which may include encryption, two-factor authentication and other forms of security. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards, including obligations to protect any information and apply appropriate measures for the use and transfer of information.
Retention Period: How long we’ll keep your information
We keep information in line with our data retention policy. We retain information to comply with legal or regulatory requirements or for our legitimate purposes, such as responding to enquiries, and may sometimes need to keep it for a longer period; if we don’t need to retain it for as long, we may delete, destroy or anonymise it sooner. This enables us to comply with legal and regulatory requirements or use it where we need to for our legitimate purposes such as dealing with any enquiries.
Alnitak Advisors (Jersey) Limited and Amthe Capital Limited do not use cookies on the website.
Your rights:
You have a number of rights in relation to the information that we hold about you. These rights include:
- the right to access the information we hold about you and to obtain information about how we process it;
- in some circumstances, the right to withdraw your consent to our processing of your information, which you can do at any time. We may continue to process your information if we have another legitimate reason for doing so;
- in some circumstances, the right to receive certain information you have provided to us in an electronic format and/or request that we transmit it to a third party;
- the right to request that we rectify your information if it’s inaccurate or incomplete;
- In some circumstances, the right to request that we erase your information. We may continue to retain your information if we’re entitled or required to retain it;
- the right to object to, and to request that we restrict, our processing of your information in some circumstances.
Again, there may be situations where you object to or ask us to restrict, our processing of your information, but we are entitled to continue processing your information and/or to refuse that request.
You can exercise your rights by contacting us using the details set out in the ‘More details about your information’ section below.
You also have a right to complain to the data protection regulator in the country where you live or work.
In Jersey this is the Office of the Information Commissioner whose website address is www.dataci.je.