PRIVACY NOTICE
In this Notice, “Leeward” means Leeward Management Limited, Leeward Trust Limited, Leeward (BVI) Limited, together with any affiliates, subsidiaries or entities which are authorised by Leeward Group Limited to operate under the Leeward brand.
Introduction
At Leeward, we understand the importance of maintaining the privacy and protection of personal data. As a fiduciary services provider operating within the regulatory environments of both the British Virgin Islands (BVI) and the Cayman Islands, we adhere strictly to the BVI Data Protection Act, 2021 and the Cayman Islands Data Protection Act (as revised). This Privacy Notice sets out how we collect, use, store, and protect your personal data, and the rights you have under applicable laws.
Key Definitions
- Data Controller: Leeward, responsible for determining the purposes and means of processing personal data.
- Data Subject: The individual whose personal data is being processed.
- Processing: Any operation or set of operations performed on personal data, including collection, storage, use, disclosure, and destruction.
What Information We Collect
We collect a variety of personal data, including but not limited to:
- Full name, nationality, date of birth, and gender
- Government-issued identification and verification documentation
- Contact details (email address, telephone number, mailing address)
- Employment history and professional details
- Financial information such as source of wealth and tax identification numbers
- Information relating to trust beneficiaries, settlors, directors, shareholders, agents and/or representatives
Collection Methods
Personal data is obtained through the following channels:
- Direct communication from clients, counterparties, their lawyers or representatives
- Submission of application forms or onboarding documents
- Third-party verification and due diligence services
- Regulatory filings, compliance reporting, and publicly available data
Lawful Bases for Processing
Our processing activities are grounded in one or more of the following legal bases:
- Consent: In cases where you voluntarily provide data and have given explicit permission
- Contractual necessity: To fulfill obligations under a service contract
- Legal obligations: To meet statutory requirements such as anti-money laundering processes, tax reporting, or regulatory compliance
- Legitimate interests: To ensure the efficient operation of our services, protect legal rights, and enhance client relationships
Use of Your Data
We use personal data for the following purposes:
- Anti-money laundering and know-your-client verification
- Sanctions screening
- Client onboarding and account administration
- FATCA/CRS compliance and regulatory disclosures
- Trust and entity management
- Internal risk assessments
- Communication, invoicing, and service updates
Sharing and Disclosure
Your personal data may be shared with:
- Internal staff and Leeward affiliates (where the nature of the services being provided requires)
- Regulatory bodies (e.g., Cayman Islands Monetary Authority and BVI Financial Services Commission)
- Law enforcement agencies as required by law
- Persons as directed by a court of competent jurisdiction or competent authority
- Banking institutions, custodians, legal advisors and other services providers such as auditors and compliance consultants
Data is shared only when necessary and under confidentiality obligations.
International Transfers
We may transfer your data to jurisdictions outside the BVI or Cayman Islands. When doing so, we ensure an adequate level of protection through:
- Standard Contractual Clauses (SCCs)
- Risk-based jurisdictional adequacy assessments
- Internal policy controls and encryption
Data Security and Retention
We implement physical, electronic, and administrative safeguards including:
- Standard encryption protocols
- Role-based access restrictions
- Regular system audits and penetration testing
- Secure document storage and shredding procedures
Data is retained only as long as necessary to fulfill legal, regulatory, or contractual obligations, after which it is securely destroyed.
Your Rights
Under the applicable BVI and Cayman data protection legislation, you are entitled to:
- Request access to personal data held about you
- Request rectification of inaccurate or incomplete data
- Request erasure where data is no longer required
- Object to processing based on legitimate interests
- Request restriction of processing
- Request portability of data in structured formats
- Lodge complaints with supervisory authorities
Supervisory Authorities
Cayman Islands Ombudsman: info@ombudsman.ky | www.ombudsman.ky
BVI Information Commissioner’s Office: | www.privacy.bm
Contact Us
For any privacy-related queries or to exercise your rights, contact our Data Protection Officer: Email: info@leeward.ky