In this Policy, where we refer to “Stonegate Trinity” (or “we”/”us”/”our”), we mean Stonegate Trinity LLP, and any other entities that are associated with us.
Stonegate Trinity LLP is a Limited Liability Partnership registered in England and Wales with Registration Number OC355118. The Registered Office Address is 137 Newhall Street, Birmingham, B3 1SF. Stonegate Trinity is registered as a firm of Tax Advisers with The Chartered Institute of Taxation.
We may collect information from you through your use of this website, when you request information from us or engage with our taxation or other services, or as a result of your relationship with one or more of our Tax Advisers or otherwise in the course of our business.
References in this notice to “your information” are also to personal information that you provide to us or which we otherwise gather in the course of operating our business.
THE INFORMATION WE COLLECT
We may collect various types of personal data about you, including:
- Your personal identification information (which may include your name and passport information, your IP address and personal data relating to politically exposed persons (PEP) status, personal data available in the public domain and such other information as may be necessary for Stonegate Trinity to provide its services and to complete its Client Due Diligence (CDD) process and discharge its Anti-Money Laundering (AML) obligations);
- Your contact information (which may include postal address and email address and your home and mobile telephone numbers);
- Your family relationships (which may include your marital status, the identity of your spouse and the number of children that you have);
- Your professional and employment information (which may include your level of education and professional qualifications, your employment, employer’s name and details of directorships and other offices which you may hold);
- Financial information, sources of wealth and your assets (which may include details of your assets, sources of wealth, shareholdings and your beneficial interest in assets, your bank details and your credit history);
- Information about client matters which may include a wide range of personal information which may include (but may not be limited to) information about employment, health, family issues and relationships, regulatory status.
We may also collect and process personal data regarding people connected to you, either by way of professional (or other) association or by way of family relationship.
If you apply for a position with us we may collect personal information relating to your past employment, professional qualifications and education, your nationality and immigration/residential status, opinions from third parties about you (such as references) and other details about you which may be gathered during the recruitment process. We may also review publically available information about you on your social media accounts.
WHERE WE OBTAIN YOUR PERSONAL INFORMATION
Along with any information that you give to us, we collect your personal information from the following sources, including but not limited to:
- Such other forms and documents as we may request that are completed in relation to the administration/management of any of our services;
- Information gathered through CDD carried out as part of our compliance with regulatory requirements; or
- Any personal information provided by way of correspondence with us by phone, email or otherwise;
- Personal information we receive from third party sources, such as:
- our clients in connection with matters upon which we are or may be instructed (for example where you are a counterparty to a transaction or an employee of one of our clients);
- entities in which you or someone connected to you has an interest;
- your accountants, legal, and financial advisors;
- financial institutions who hold and process your personal information;
- credit reference agencies for the purposes of complying with our regulatory requirements;
- personal information received in the course of dealing with advisors, regulators, official authorities and service providers by whom you are employed or engaged or for whom you act; and
- in the process of our recruitment processes, we may obtain information from recruitment agencies, past or current employers and/or educational institutions and/professional bodies.
INFORMATION THAT WE COLLECT THROUGH OUR WEBSITE
You are not required to provide any personal information on the public areas of our website.
Stonegate Trinity may collect the domain names and IP addresses of its visitors, along with usage statistics, analytics and browsing history. This data may be used to promote our services. Please see our Cookies Policy below for more details about this.
HOW WE USE YOUR INFORMATION
At Stonegate Trinity we are committed to protecting and respecting your privacy. We provide tax and other associated services to our clients and we use your personal data for those purposes. Normally the purposes for which we use your personal data will be clear when we collect the data. We will not use your personal data for purposes that are not clear when we collect that data and will only use your personal information to:
- conduct administrative or operational processes within our business;
- conduct administrative or operational processes within our business;
- perform a contract which we may have with you;
- comply with our legal and regulatory obligations;
- to establish, exercise or defend the legal rights of Stonegate Trinity LLP or for the purpose of legal proceedings;
- process and respond to requests, enquiries or complaints received from you or someone connected to you;
- send you marketing material (e.g., client briefings and legal updates);
- provide you with personalised content;
- for other legitimate business purposes; and
- should you apply for a position with us, to review and process your application.
TRANSFERRING YOUR INFORMATION OUTSIDE OF EUROPE
As part of the services offered to you through this website, the information which you give to us may be transferred to countries outside the European Union (“EU”). For example, some of our third party providers may be located outside of the EU. Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy. By submitting your personal data, you are agreeing to this transfer, storing or processing. Where our third party supplies are in the US we have ensured that their services fall under the “Privacy Shield” whereby participating companies are deemed to have adequate protection and therefore facilitate the transfer of information from the EU to the US.
If you use our services while you are outside the EU, your information may be transferred outside the EU to give you those services.
We may ask whether you wish to receive marketing from us and this will be presented to you as an option on the relevant application form or page on our website where necessary. We may also contact you by email or other means to inform you about other services or events which may be of interest to you.
You have the right at any time to stop us from contacting you for marketing purposes. If you wish to do so, please either unsubscribe or contact: email@example.com.
RETENTION OF PERSONAL INFORMATION AND SECURITY
Your personal information will be retained for as long as required:
- For the purposes for which the personal information was collected;
- as required by data protection laws and any other applicable laws or regulatory requirements.
We will ensure that the personal information that we hold is subject to appropriate security measures.
ACCESS TO AND CONTROL OF YOUR PERSONAL INFORMATION
You have the following rights in respect of the personal information about you that we process:
- the right to access personal information;
- the right to rectify personal information;
- the right to restrict the use of personal information;
- the right to request that personal information is erased; and
- the right to object to processing of personal information.
You also have the right to lodge a complaint about the processing of your personal information either with us, the Information Commissioner’s Office in the UK (https://ico.org.uk) or the data protection authority in the EU member state of your usual residence or place of work.
Where we have relied on consent to process your personal information, you have the right to withdraw consent at any time.
If you wish to exercise any of the rights set out above please contact Suzanne Wallace at firstname.lastname@example.org.
INACCURATE OR AMENDED INFORMATION
Please let us know as soon as possible if any of your personal information changes (including your correspondence details). Failure to provide accurate information or to update information when it changes may have a detrimental impact upon our ability to provide services to you.
QUESTIONS AND CONTACT INFORMATION
If you have any questions in relation to this notice please contact our Data Protection Officer at the office address or by emailing email@example.com.
CHANGES TO THIS POLICY
We may change this policy from time to time by updating this page. You should check this page from time to time to ensure you are happy with any changes. We last updated this policy on 21 May 2018.