This policy will explain areas of this website that may affect your privacy and personal details, how we process, collect, manage and store those details and how your rights under the GDPR (General Data Protection Regulation), Cayman Island Data Protection Law, are adhered to.
We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.
This policy describes how Coastroad collects, uses and shares the information you provide to us and the information we collect in the course of operating our business and in using our websites.
In this Policy, where we refer to "Coastroad" (or "we"/"us"/"our)", we mean each of the Coastroad Group Entities set out at the end of this policy and each of our international affiliates and the companies and other entities which are associated with us.
We may collect information from you through your use of this website, when you request information from us or engage with our financial or corporate services, or as a result of your relationship with one or more of our staff 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 claims, court cases and convictions, politically exposed person (PEP) status, personal data available in the public domain and such other information as may be necessary for Coastroad to provide its services and to complete its CDD process and discharge its AML/CFT obligations).
- Your contact information (which may include postal address and e-mail 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).
- 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
We collect your personal information from the following sources:
Personal information which you give to us, such as:
- 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 client due diligence carried out as part of our compliance with regulatory requirements.
- Any personal information provided by way of correspondence with us by phone, e-mail 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 or where you are a witness in a dispute resolution matter).
- Entities in which you or someone connected to you has an interest.
- Your legal and/or financial advisors.
- Financial institutions who hold and process your personal information.
- Credit reference agencies and financial crime databases 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.
INFORMATION THAT WE COLLECT THROUGH OUR WEBSITE
You are not required to provide any personal information on the public areas of our website; however, you may choose to do so by completing any of the forms which may from time to time be including on our website.
In addition to the information you knowingly provide, Coastroad collects the domain names and IP addresses of its visitors, along with usage statistics, analytics and browsing history. This data is used to promote our services. Please see our cookies policy for more details about this. You may also provide us with personal information if you contact us by email, telephone or letter.
HOW WE USE YOUR INFORMATION
At Coastroad we are committed to protecting and respecting your privacy. We provide corporate and other professional 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 that 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.
- Provide and improve our corporate and other services.
- Compile anonymous statistics, for example website usage statistics.
- Perform a contract which we may have with you.
- Comply with our professional and regulatory obligations.
- To establish, exercise or defend the legal rights of Coastroad 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 financial updates).
- Provide you with personalised content.
- Invite you to events.
- For other legitimate business purposes.
- To review and process your application should you apply for a position with us.
HOW AND WHY WE SHARE YOUR INFORMATION
We share personal information within Coastroad’s international network.
As a result, your personal information may be transferred to locations outside Cayman as well as within it for the purposes described above.
Outside of Coastroad.
We may also share your personal information outside Coastroad. This may include disclosures to:
Third party agents, suppliers or contractors, in connection with the processing of your personal information for the purposes described in this policy, which may include, but is not limited to:
- IT and communications service providers.
- Our own advisers such as auditors and accountants and any external legal advisors which we may instruct from time to time.
Third parties relevant to the professional and other services that we provide, which may include, but is not limited to:
- Counterparties to transactions (including professional service firms acting for other parties).
- Other professional service providers.
- Law enforcement agencies.
- Governmental institutions.
- Tribunals and courts.
To the extent required by law, regulation or court order, for example if we are under a duty to disclose your personal information in order to comply with any legal obligation such as our AML/CFT obligations.
We may disclose your personal information for the purposes of seeking references and confirmation of the details which you have provided should you apply for a position with us.
THE EU AND THE US PRVACY SHIELD FRAMEWORK
We comply with the EU and the US privacy shield principles and take full responsibility for the processing of personal data that we receive from our users, subjected to Privacy Shield Framework. The user has full right to access, delete or update his or her information shared with us and can simply do so, by writing an email for the same to our support team. In an unavoidable situation, we may be compelled to disclose personal data to comply lawful requests by public authorities.
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 firstname.lastname@example.org.
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.
- In order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations.
- 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 and port 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.
- 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 or with a competent supervisory authority in a Coastroad jurisdiction (including for example, the Office of the Ombudsman of the Cayman Islands (https://ombudsman.ky) or in your usual place of residence, your place of work or in the place of the alleged infringement.
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 or for further information, please contact our group information security and data protection officer at email@example.com.
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 group information security and data protection officer at one of the addresses listed below or by emailing firstname.lastname@example.org.
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 December 1, 2019.
COASTROAD GROUP ENTITIES
- Coastroad Financial Limited;
- Coastroad Services Limited;
- Coastroad Capital Limited;
- Coastroad Manager Platform SPC;
- Coastroad Holdings Limited; and
- Coastroad Group Holdings Limited.