Privacy Policy

1. INTRODUCTION

The Schindlers Group provides trustee and fiduciary management services, including trust, foundation and company formation, trusteeship and directorship services, administration, secretarial, accounting and professional services, escrow services and advisory services (the “Services”).

We are committed to protecting your personal information and the purpose of this Privacy Policy is to give you a clear explanation about how we collect, use, disclose, transfer, store, retain or otherwise process any personal information and data when you access our website, apply to use our Services, communicate with us or when you use our Services.

The Data Protection Officer can be contacted directly at:

Data Protection Officer
Baarerstrasse 125
Zug
6300
Switzerland

OR at: [email protected]

2. WHAT IS PERSONAL DATA?

Personal Data is any data or information that could reasonably be used to identify an individual, such as a name, identification or passport number, address etc. In this Privacy Policy, we call Personal Data, “Data”.

3. WHEN DO WE COLLECT DATA FROM YOU?

We collect Data from you so that we can provide you with our Services. You provide some of the Data directly to us, for example when you complete our application forms to use our Services, when you ask us to provide a specific service or when you communicate with us. We also get Data by recording how you interact with our Services, for example by using technologies such as cookies and we also get Data from third parties.

We are committed to ensuring that the Data we collect and use is appropriate for the purposes set out in this Privacy Policy, and does not constitute an invasion of your privacy. In terms of being contacted for marketing purposes we will contact you for additional consent.

4. WHAT DATA DO WE COLLECT FROM YOU?

We need the Data (i) to provide the Services; (ii) to keep the Services safe; (iii) to comply and show compliance with applicable laws, regulations and requests from governmental or regulatory organisations; (iv) for credit control and collection of fees; and (v) to enforce our rights, policies and agreements. Without the Data we will not be able to provide you with the Services.

4.1 The Data that we may collect from you includes:

• Identification Data: such as names, email addresses, postal addresses, phone numbers, photographs, date of births, passports, driver’s licences, government issued identification documents, taxpayer identification numbers and signatures.
• Financial Data: such as bank information, credit and debit card numbers, expiry date and other information to allow us to collect payments.
• Tax Data: such as tax filing status, tax identification numbers and tax filing reports.
• Transaction Data: such as information about when and where transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, bank account details, billing and shipping information, and the payment methods used to complete the transactions.
• Entity data: such as a company’s legal structure, product and service offerings, jurisdiction, company records, trust and foundation records, information on shareholders, directors, beneficial owners, settlors, protectors and beneficiaries.
• Business Data: such as information about products and services you sell (including inventory, pricing and other data) and other information you provide about you or your business (including appointment, staffing availability, employee and contact data).
• Customer and Transaction Data: such as information you collect from your customers, including email address, phone number, payment information, credit or debit card or other information.
• Browser and device information: such as IP address, device type, operating system and internet browser type.

4.2 Data We Collect From Third Parties

We may also collect information from third parties to perform identity verification checks and obtain background information for anti-money laundering, identity verification, and fraud detection and prevention purposes.

• Identity Verification: such as information from third-party verification services (e.g. credit reference agencies, identity verification agencies, social media agencies (if you authorise us to do so), credit bureaus, financial institutions, mailing list providers, and other publicly available sources.
• Background Data: such background check reports from public records of criminal convictions and arrest records.
• Credit, Compliance and Fraud: such as information about you credit reporting agencies or credit bureaus, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment, financial institutions, and personal reporting agencies.

We do not control or supervise how third parties providing your information to us, process your personal data, and any information request regarding the disclosure of your personal information to us by these third parties should be directed to such third parties.

4.3 Children’s Data

So that we can provide our Services, we may need information on children. Children are considered persons under the age of 16 years. Data on children will be collected and processed only with the consent of the child’s parent, guardian or holder of parental responsibility over that child.

5. HOW DO WE USE YOUR DATA?

We will process (collect, store and use) the Data you provide in a manner compatible with the EU General Data Protection Regulation (“GDPR”). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.

We collect and use your Data with your consent or as necessary to comply with and show compliance with our legal, compliance and regulatory obligations (such as anti-money laundering laws) and for the purposes of our legitimate interests.

Examples of how we may use or process your Data are as follows:

• to assess and process an application for our Services;
• to verify an identity for compliance and anti-money laundering purposes;
• to comply with any applicable laws or regulations, or in response to lawful requests for information from government or regulatory bodies or through legal process;
• to investigate, detect and prevent or report fraud, money-laundering, misrepresentations, security breaches or incidents, other potentially prohibited or illegal activities;
• to provide, operate and maintain the Services;
• for efficient management of our relationship with you;
• to process and complete transactions and send related information to you, such as the payment confirmations and bank statements;
• to communicate with you and deliver the information and support you request, in relation to our Services, including to resolve disputes, collect fees, and provide assistance for problems with our Services;
• to improve, personalise and facilitate your use of the Services;
• to fulfil any other purpose disclosed to you in connection with our Services;
• to enforce our rights, agreements or policies;
• to develop new products and services;
• to send you information we think you may find useful or which you have requested from us about Services;