L&S Trust Services values your privacy. We are committed to ensuring the privacy and confidentiality of your personal data and personal data that you may provide to us about other persons, such as family members or advisors ("Personal Data") when you conduct business with us, use our website or communicate with us.
In this policy, "L&S Trust Services", "we", "us" and "our" includes L&S Trust Services SA in Switzerland and L&S Services LP in Guernsey.
The data controller of your Personal Data for the purposes of the Swiss Federal Act on Data Protection ("FADP"), the EU General Data Protection Regulation 2016/679 ("GDPR") and any other locally applicable data protection laws and regulations is L&S Trust Services SA. If Personal Data was provided only in relation to conducting business with L&S Services LP, then L&S Services LP is the data controller.
2. Personal Data we process
We hold the Personal Data of natural persons as follows:
- Personal Data of clients of L&S Trust Services and other parties (directly or indirectly) to contracts with L&S Trust Services, including (but not limited to) settlors, trustees, protectors, beneficiaries, directors, officers, shareholders, controllers and beneficial owners of entities to which we provide services;
- Personal data of persons inquiring about our services, whether or not we are or will be engaged to act; and
- Personal Data of suppliers of goods and services to us or to our clients.
We process the Personal Data you provide to us when communicating with us. Depending on the specific relationship with you, we will hold additional information, in some cases together with any documentation confirming such information, such as:
- Information relating to your financial circumstances including banking, investments, assets, source of funds and source of wealth;
- Information relating to your profession, curriculum vitae, business activities, business relations, tax status as well as identification numbers relating to tax, national insurance and similar; and
- Personal information about you such as your nationality, your personal circumstances, your family and close relations.
3. Collection and retention of Personal Data
You will voluntarily provide most of your Personal Data directly to us. We may also obtain Personal Data from third parties. The main sources and occurrences are as follows:
- Information and documentation you or persons related to you, your professional advisers or introducers provide at the point of initial inquiry, subsequent follow-up or when we complete client acceptance procedures;
- Information and documentation you or persons related to you, your professional advisers or introducers provide in the context of our client-due diligence procedures including updates and renewals of such information;
- When you, persons related to you, your professional advisers, intermediaries or other suppliers or service providers communicate with us by whatever means;
- From publicly available sources such as the internet as well as online information and checking services.
Sometimes the provision of your Personal Data to us by third parties will be unsolicited and/or provided in confidence (for example, reports made to us by regulators and other persons) and we may be unable to notify you of this. In all cases, we do our best to take such necessary steps to ensure that Personal Data is obtained and used in a fair and lawful way.
After the expiry of the retention period, L&S Trust Services may dispose of, delete and destroy any Personal Data without further reference to you.
4. Purposes for processing your Personal Data
Data processing is aimed at:
- the correct and complete execution of the professional assignment received;
- complying with legal and regulatory requirements, including compliance with applicable anti-money laundering regulations and regulations regarding automatic exchange of information in tax matters.
- managing our relationship with you and communicating with you
- the proper governance, management and administration of L&S Trust Services.
The processing of Personal Data will include obtaining and recording of Personal Data as well as the management of such Personal Data including organizing, copying, analysing, amending, storing, transmitting, disclosing, archiving, anonymising, deleting and destroying data. We do not monitor your behaviour, track your physical location or subject you to profiling or automated decision-making.
6. Disclosure of Personal Data
- Your agents, advisers, auditors, counterparties, family members, close relations, banks, investment managers;
- Our agents, advisors, auditors and other professionals; or
- Persons providing services in the context of the performance of our obligations, such as banks, investment managers, fund managers, brokers, tax and legal advisers, accountants.
We will also disclose Personal Data where disclosure is required by applicable laws and regulations (including laws about automatic exchange of information in tax matters) or orders of any court, tribunal, law enforcement, regulatory, public or quasi-governmental authority or department.
7. Our basis for processing your Personal Data
Our processing of your Personal Data is based on your consent to do so. We also process data where it is necessary:
- to perform our contracts to which you are a party (directly or indirectly including as a settlor, protector or potential beneficiary or similar position);
- to take steps at your request to entering into a contract with you;
- for compliance with legal and regulatory obligations; and
- for the purposes of our or another party's legitimate interests.
8. Protecting your Personal Data
We restrict the use and access to your Personal Data to those who have an absolute need-to-know to provide you with access to our website and/or communicate with you. We maintain appropriate technical and organizational measures to preserve the confidentiality and integrity of your Personal Data. We regularly review our security policies and procedures to ensure our systems are secure and protected, and we ensure compliance with all applicable data protection and security laws.
9. Your choices and rights
We welcome your inquiries and comments. Your rights include:
- the right to be informed by us on any processing of your Personal Data to verify the lawfulness of processing;
- the right to request rectification or completion of any relevant data in the event you are affected by incorrect or incomplete Personal Data;
- to the extent allowed by applicable law, you may request the deletion of your Personal Data or a temporary restriction of processing in certain instances; and
- the right to object to the processing of your Personal Data, in which case we may however not be in a position to provide any related services or perform our obligations under the relevant contracts.