Privacy Policy

Privacy Notice Last Updated 1 November 2023

1. Scope

1.1 AB Advisor ("AB Advisor", "Choose Your Company", "we" or "our") maintains a global presence with offices in various jurisdictions. This Privacy Notice pertains to individuals interacting with AB Advisor offices within the European Economic Area (EEA) or regions recognized by the European Commission as offering adequate protection (referred to as "Adequate Jurisdictions").

1.2 This Privacy Notice delineates the types of information we gather, the reasons for its collection, the parties with whom we may share it, and the measures taken to safeguard this information. Additionally, it outlines the rights and choices available to individuals regarding their information and provides contact details for inquiries related to our privacy practices.

2. Definitions and Interpretation

2.1 "Data Protection Legislation" encompasses all relevant legislation pertaining to privacy and data protection, including but not limited to the EU General Data Protection Regulation 2016/679 ("GDPR"), data protection laws in Adequate Jurisdictions, and the legislation in other regions where we conduct business.

2.2 In our usage, terms like "personal data", "subject", "controller", "processor" and

"process" (and their derivatives) shall adopt the definitions ascribed to them in Data

Protection Legislation.

2.3 The AB Advisor offices to which this Privacy Notice applies are herein referred to as "Relevant Offices," and, depending on context, as "we" or "our."

2.4 "You" may signify any person interacting with us or having associations with the entities receiving our services, which may encompass clients, intermediaries, associates, family members, guardians, representatives, advisors, directors, settlors, beneficiaries, trustees, other officers or appointees, attorneys, introducers, suppliers, service providers, lenders, borrowers, employees, or agents of any of these roles.

3. Our Privacy Principles

3.1 We may gather and process information concerning you, your employees, officers, directors, agents, contractors, or consultants ("Client Personnel") whose information you provide to us. Additionally, we may collect information about other individuals ("Other Relevant Individuals") whose information you supply to us to facilitate the provision of our services or conduct business.

3.2 The information we collect shall be processed in accordance with Data Protection Legislation and the terms outlined in this Privacy Notice.

3.3 You are responsible for ensuring that your Client Personnel and Other Relevant Individuals are made aware of this Privacy Notice, and that its provisions are communicated clearly and conspicuously to them before you provide us with any information.

3.4 The information we collect encompasses personal data, which pertains to information enabling the identification of a natural person and includes:

3.4.1 Contact details, such as an individual's residential or work address, and contact information (including mobile phone numbers).

3.4.2 Details such as date of birth, marital or civil partnership status, information about dependents, next of kin, family connections, lifestyle, and social circumstances.

3.4.3 Employment status.

3.4.4 Information regarding an individual's occupation, educational background, professional qualifications, and business activities.

3.4.5 Records of compensation, bank account particulars (including routing details), national insurance numbers, and tax-related information.

3.4.6 Information about the source of wealth and the ownership of assets.

3.4.7 Other details that you or they choose to disclose to us while engaging with us, including information about any complaints or concerns raised by you or them.

3.4.8 Data obtained from interactions with our services and our business operations, including when you or your Client Personnel or Other Relevant Individuals utilize our website.

3.4.9 Data collected during communications between you, your Client Personnel, or Other Relevant Individuals and us, or during the execution of transactions, applications for our products or services, or any other interactions with us.

3.4.10 Information acquired from third parties, such as when validating information provided by you, including data from other entities within the AB Advisor Group, your representatives or intermediaries, employers, clients, agencies involved in crime and fraud prevention, government and public bodies, or similar organizations.

3.4.11 Data obtained through screening processes, involving screening service providers and research conducted using publicly accessible sources.

3.5 Some of the information we collect about you, your Client Personnel, or Other Relevant Individuals may encompass special categories of personal data, as defined by the GDPR. This may include information about racial or ethnic origin, criminal or alleged criminal offenses, trade union membership, or details about health and lifestyle. In compliance with applicable law, we will seek separate written permission from you or them

to process such special categories of personal data.

3.6 Should you decline to provide us with information or if you, your Client Personnel, or Other Relevant Individuals object to our processing of such data (refer to section 9 for more information on your rights concerning your information), this may result in:

3.6.1 Impediments to conducting business with you and the inability to provide services to you or to entities connected to you for which we offer services.

3.6.2 Possible non-compliance with relevant laws or regulations and subsequent penalties or entities connected to you, for which we provide services.

3.6.3 The failure to supply specific personal data in certain circumstances may necessitate that we or our employees or agents contemplate the need for disclosures under applicable legislation concerning anti-money laundering and counter-terrorism financing.

4. Our Use of Your Information

4.1 We may collect, record, and employ information about you, your Client Personnel, Other Relevant Individuals, and the business you conduct with us. This data will be held, processed, and used in accordance with Data Protection Legislation and in accordance with the terms detailed in this Privacy Notice. This may encompass sharing the information with third parties and transmitting it internationally.

4.2 The information we hold about you, your Client Personnel, and Other Relevant Individuals may be processed for various business purposes. It is your responsibility to ensure that your Client Personnel and Other Relevant Individuals are informed about such uses of their information. We collect and process personal data:

4.2.1 To manage and provide services to you and/or entities connected to you, or that receive services from us.

4.2.2 We monitor and analyze the conduct of goods and services received by or provided to you.

4.2.3 We conduct statistical and other analyses and fulfill legal, regulatory, or reporting obligations for entities to which we provide services.

4.2.4 We use information for our legitimate commercial purposes, including quality control, administration, and the development of new products and services.

4.2.5 We confirm your or an individual's identity, conduct background checks, including anti-money laundering and counter-terrorism checks, compliance screening, and fraud prevention.

4.2.6 We follow up with you or another individual to provide further assistance after initial contact.

4.2.7 We comply with applicable laws and regulations.

4.2.8 We fulfill reporting agreements with tax authorities or revenue services.

4.2.9 We verify your instructions.

4.2.10 We monitor, record, and analyze communications between you or another individual and us, including phone calls, for service analysis, improvement, training, and quality purposes. You have the right to opt out of receiving communications from us (explained below).

4.2.11 We prevent or detect abuse of our services, protect our rights, and enforce agreements.

4.2.12 We share information with relevant third parties in the context of a sale or potential sale of a relevant part of our business, subject to confidentiality obligations.

4.2.13 We use information if instructed by you or another individual or with your/their consent.

4.2.14 We may inform you or another individual about additional services offered by us, unless you or they indicate that you do not wish to receive such information.

4.2.15 We improve the relevance of marketing messages sent to you or another individual (which you can opt out of, as explained below).

5. Lawful Grounds for Using Your Information

5.1 We process information based on lawful grounds, including:

5.1.1 Necessity to perform agreements or take steps to enter into agreements with you, another individual, or entities connected to you.

5.1.2 Compliance with legal obligations we or entities connected to you have.

5.1.3 Pursuit of legitimate interests, such as managing our services, fulfilling fiduciary duties, preventing fraud, protecting business interests, complying with legal orders, defending against claims, investigating complaints, and informing clients about relevant products/services (unless opted out).

5.1.4 Explicit consent from you, your Client Personnel, or Other Relevant Individuals for specific processing purposes.

5.2 For special categories of personal data, we generally obtain specific consent, unless required for legal obligations. Withdrawal of consent is possible, although lawful processing may continue under other applicable bases.

6. Automated Processing

6.1 We do not engage in automated decision-making or profiling concerning you, your Client Personnel, or Other Relevant Individuals.

7. Sharing Your Information with Others

7.1 We maintain confidentiality, but may share information to fulfill client needs, comply with laws, and regulations. Sharing may occur with other AB Advisor members or third parties, ensuring compliance with Data Protection Legislation.

7.2 AB Advisor may share information about you, your Client Personnel, or Other Relevant Individuals with other members of AB Advisor or with third parties. In such instances, AB Advisor will ensure that any such disclosure, where relevant, remains in compliance with Data Protection Legislation at all times.

7.3 Information within AB Advisor's possession regarding you, your Client Personnel, or Other Relevant Individuals may be transferred across different jurisdictions. This may include Adequate Jurisdictions if you are located in the EEA, as well as other global jurisdictions, for the purposes outlined in this Privacy Notice.

7.4 If AB Advisor transfers information about you, your Client Personnel, or Other Relevant Individuals to third parties, AB Advisor will impose contractual obligations on these recipients, ensuring the protection of such information in accordance with the standards required by Data Protection Legislation. Alternatively, AB Advisor will ensure that such transfers adhere to safeguards provided under applicable Data Protection Legislation.

7.5 You, your Client Personnel, or Other Relevant Individuals should acknowledge and accept that some countries may have varying laws, which may be less stringent, regarding the level of confidentiality applied to the information they hold. As a result, this information may become subject to the laws and disclosure requirements of these countries, including potential disclosure to governmental bodies, regulatory agencies, and private individuals through applicable governmental or regulatory inquiries, court orders, or similar processes.

7.6 Similarly, you, your Client Personnel, or Other Relevant Individuals should understand and accept that numerous jurisdictions have agreements with other countries facilitating the exchange of information for purposes related to law enforcement, tax, and various other purposes.

7.7 AB Advisor may also transfer your information in situations where you, your Client Personnel, or Other Relevant Individuals have consented to such transfers.

7.8 The recipients or categories of recipients of your information, or information relating to your Client Personnel or Other Relevant Individuals, may encompass:

7.8.1 Any revenue service or tax authority, if obligated to do so under applicable law and regulations, along with international reporting obligations.

7.8.2 AB Advisor's advisors, which may include accountants, lawyers, tax advisors, or other professional advisors, as well as financial services providers like banks and investment brokers.

7.8.3 Your advisors, such as accountants, lawyers, tax advisors, or other professional advisors, provided they are authorized by you.

7.8.4 Professional and financial advisors and service providers, including accountants, lawyers, tax advisors, or other professional advisors, banks, and investment brokers, who have been appointed by the entities to which AB Advisor provides services.

7.8.5 Governmental and quasi-governmental bodies, along with officially appointed individuals worldwide, to whom AB Advisor has a legal obligation to provide information regarding the entities to which AB Advisor provides services. This may encompass company registries, registered offices, registered agents, and other similar registries, appointed persons, or information repositories.

7.8.6 Courts, tribunals, and other judicial bodies worldwide.

7.8.7 Regulators and authorities worldwide, including law enforcement authorities in connection with their duties.

7.8.8 Organizations dedicated to preventing fraud, enforcing laws, and combatting terrorism by using this information to identify, examine, and thwart fraudulent activities, money laundering, terrorism, and other illicit behaviors.

7.8.9 Any parties to whom we may transfer our rights and/or obligations.

7.8.10 Any other individuals or entities in the event of a restructuring, sale, or acquisition involving any member of the AB Advisor Group, provided that said individuals or entities utilize your information for the same purposes for which it was originally provided to us or used by us (or both).

7.9 If AB Advisor, a fraud prevention agency, crime enforcement agency, or terrorism prevention agency determines that you, your Client Personnel, or Other Relevant Individuals pose a risk related to fraud, money laundering, and/or terrorist financing:

7.9.1 We maintain the right to decline services to you and/or any affiliated entities or cease providing existing services to you and/or affiliated entities.

7.9.2 Records pertaining to any instances of fraud, money laundering, and/or terrorist financing risk will be retained by relevant agencies, potentially resulting in other entities refusing to provide services, financing, or employment to you and/or entities to which AB Advisor provides services and with which you are connected.

8. Sharing Information about Another Individual with AB Advisor

8.1 If any information, including special categories of personal data, provided to AB Advisor pertains to another individual (such as your Client Personnel or Other Relevant Individuals), by supplying such information, you confirm that you have obtained the necessary permissions from these individuals regarding the appropriate use of their information in accordance with this Privacy Notice or that you are otherwise authorized to provide us with this information on their behalf.

9. Your General Rights Regarding Your Information

9.1 Depending on your country of residence, you, your Client Personnel, and Other Relevant Individuals may possess various rights concerning the handling of your information. It is your responsibility to ensure that your Client Personnel and Other Relevant Individuals are informed of these rights. At any time, you, your Client Personnel, and Other Relevant Individuals have the following rights:

9.1.1 To receive information about the processing of your or their personal data, including the purposes, types, recipients to whom it is disclosed, storage durations, and any third-party sources from which it was obtained.

9.1.2 To request access to, or a copy of, any personal data held by AB Advisor regarding you or them.

9.1.3 To request the correction of your or their personal data if it is deemed inaccurate and to be notified once it has been corrected or completed.

9.1.4 To request the erasure of your or their personal data if there is a belief that AB Advisor does not have the right to retain it, and to be notified once it has been erased.

9.1.5 To object to the processing or use of your or their personal data for any purpose, or to request the cessation of using your or their information.

9.1.6 To request not to be subject to decisions based on automated processing and to have safeguards in place if you or they are profiled based on personal data.

9.1.7 To ask AB Advisor to transfer a copy of your or their personal data to yourself or themselves or to another service provider or third party, where technically feasible and as otherwise required by applicable regulations.

9.1.8 To request that we refrain from processing your or their information while your or their objections or requests are under consideration, including retaining your information when you or they require it for legal claims.

9.1.9 The right to withdraw any prior consent that you or they have given us for the use of your or their personal data at any time.

9.1.10 To request that we stop or start sending you or them marketing messages at any time.

9.1.11 You may also possess the right to file a GDPR complaint with the relevant supervisory authority;

9.2 Please reach out to us to restrict the use or disclosure of your information using the contact details provided in section 13 ("Contacting Us").

9.3 These rights might be subject to limitations imposed by local law requirements or your place of  residence.

10. Access to Your Information

10.1 Depending on your country of residence, you, your Client Personnel, and Other Relevant Individuals may have the right to access some or all of the information we have about you or them. This includes the right to rectify any inaccurate information, as allowed by Data Protection Legislation. For instance, individuals whose data is collected in the European Union or Switzerland have the right to access the information we hold about them, subject to certain legal exceptions.

10.2 Any requests for access to or a copy of your personal data must be submitted in writing. We will make every effort to respond within a reasonable timeframe, in compliance with Data Protection Legislation, and in any case, within one month. We will adhere to our legal obligations regarding the rights of individuals as data subjects.

10.3 Our objective is to ensure the accuracy of the information we maintain about you, your Client Personnel, or Other Relevant Individuals at all times. To assist us in this endeavor, please inform us of any changes to the personal details for you, your Client Personnel, or Other Relevant Individuals by using the contact details provided in section 13. We will rectify any inaccuracies or omissions.

10.4 These rights may be subject to restrictions imposed by local legal requirements or the place of residence.

11. Retaining Your Information

11.1 We will process and retain the information we gather about you, your Client Personnel, and Other Relevant Individuals on our systems or with third parties only for as long as is necessary for the purposes outlined above, or as required to fulfill any legal obligations to which we are subject. In accordance with applicable Data Protection Legislation, we will regularly review our records to ensure that the information is accurate, up to date, and still necessary.

11.2 If you discontinue using our services, or if we discontinue providing services to an entity to which you are affiliated, or if you stop providing us with goods or services, or you decide not to proceed with your relationship with us, we may retain your information.

11.3 Typically, data will be destroyed or erased after the legally mandated and regulatory periods for record-keeping have elapsed, following the cessation of our services. However, we may retain information related to you, your Client Personnel, or Other Relevant Individuals for longer than the legally required retention period(s) after you cease to be a client or after we cease to provide services, provided it is necessary for legal, regulatory, or other legitimate business purposes, including potential disputes. In any case, we will not retain your personal data beyond the limits permitted by Data Protection Legislation.

12. Sending You Marketing Information

12.1 We may use your information from time to time to notify you, your Client Personnel, or Other Relevant Individuals through letters, phone calls, text messages (or similar means), emails, or other electronic methods about similar products and services (including those from third parties) that might be of interest to you or them. It is your responsibility to ensure that your Client Personnel and Other Relevant Individuals are aware that we may utilize their information for marketing purposes to keep them informed about services that might interest them.

12.2 You, your Client Personnel, or Other Relevant Individuals may, at any time, request that we discontinue or not send such information through one, some, or all communication channels by reaching out to us using the contact information provided in section 13.

13. Contacting Us/Concerns

13.1 If you or any of your Client Personnel or Other Relevant Individuals wish to exercise any of the rights related to your information as outlined above, or if you have questions or comments regarding data protection, or if you wish to file a complaint about how we are handling your information, you can get in touch with us using the following contact details:

13.1.1 Email: info@abadvisor.net

13.2 If you, your Client Personnel, or Other Relevant Individuals have concerns about our use of your information, you and they also have the right to file a complaint with the relevant information commissioner or equivalent authority in the applicable jurisdiction within the EEA or an Adequate Jurisdiction.

14. Changes to This Notice

14.1 We reserve the right to introduce alterations to this Privacy Notice and the manner in which we handle your information in the future. If any such modifications are made, we will publish an updated edition of this Privacy Notice on our website. To access the latest version of this Privacy Notice, which outlines how we will manage your information, please visit our website.