Privacy policy

Callin Wild LLC and CW Corporate Services Limited (“CW”, “we”, “us”, or “our”), are strongly committed to protecting personal data. This privacy statement describes why and how we collect and use personal data and provides information about individual's right. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for the purposes described in this privacy statement or as otherwise stated at the point of collection.

Personal data is any information relating to an identified or identifiable living person. CW processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ. Personal data may include sensitive personal data consisting of information as to racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health or conditions, sexual life, the commission or alleged commission of any offence, proceedings or the disposal of proceedings for any such offence or any sentence of a court for such proceedings.

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.

Security

We take the security of all of the data that we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data that we hold safe.

Personal Data

CW is the data controller of the information that you provide, or which we obtain, through our relationship with you. Your personal data will only be used as follows:-

1. where it is necessary to provide the services which you have engaged CW to provide; or
2. as authorised by you;
3. as required by law; or
4. as detailed in these Terms of Engagement.

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put in place contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

To enable us to fulfil our engagement with our clients we may need to transfer personal data outside the jurisdictions where we and our clients are located. This may include countries outside of the European Union (“EU”) and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that any transfers outside of the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, any transfer of data will be pursuant to an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as European Commission approved standard contractual clauses.

We may provide your personal data to third party organisations, our service providers and agents for the following purposes:-

1. providing and improving our services;
2. client identification and vetting;
3. anti-money laundering and countering the financing of terrorism;
4. to enable the Firm to comply with the terms of business with those banking institutions providing the Firm with the facility of a pooled client account;
5. billing and administration;
6. financial management;
7. statistical analysis;
8. training;
9. research and development;
10. application/functionality, data processing, IT Services and disaster recovery arrangement. We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud-based software, identity management, website hosting and management, security and storage services, our servers are located in the Isle of Man; and
11. security and marketing.

Occasionally we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Data Controller and contact information

The data controller is Callin Wild LLC (the limited liability company registered in the Isle of Man with company number 000927L and its registered office is at Bank Chambers 15 - 19 Athol Street, Douglas, Isle of Man IM1 1LB).

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Lesley Webb
Data Protection Officer
Callin Wild LLC
Bank Chambers
15 - 19 Athol Street
Douglas
IM1 1LB
Email: lwebb@callinwild.com
Telephone: 01624 623195

Individuals' right and how to exercise them

At any point whilst CW is in possession of or processing your personal data, all data subjects have the following rights:

• Right of access - you have the right to request a copy of the information that we hold about you.
• Right of rectification - you have a right to correct data that we hold about you that is inaccurate or incomplete
• Right to be forgotten - in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing - where certain conditions apply you have a right to restrict the processing.
• Right of portability - you have the right to have the data we hold about you transferred to another organisation.
• Right to object - you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling - you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that CW refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

CW at your request can confirm what information it holds about you and how it is processed

You can request the following information:

• Identity and the contact details of the person within CW that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of CW or a third party such as one of its clients, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (Data Protection Regulator).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn't collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

To access what personal data is held, identification will be required

CW will accept the following forms of ID when information on your personal data is requested: a copy of your driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If CW is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to lwebb@calliwild.com or by phoning 01624 623195 or writing to us at the address further below.

Complaints

In the event that you wish to make a compliant about how your personal data is being processed by CW or its partners, you have the right to complain to Kathryn Clough. If you do not get a response within 30 days you can complain to the Isle of Man Information Commissioner.

The details for each of these contacts are:

Kathryn Clough
Bank Chambers
15 - 19 Athol Street
Douglas
Isle of Man
IM1 1LB
Telephone 01624 623195 or email kclough@callinwild.com

Isle of Man Information Commissioner
P.O. Box 69
Douglas
Isle of Man
IM99 1EQ T
Telephone: +44 1624 693260 or email ask@inforights.im