Privacy and Client Service Policy
LEEWARD MANAGEMENT LIMITED
Leeward gives you the opportunity to understand how we use your personal information and to be confident that this information is safe and secure. This privacy policy explains why we collect your information, how we use it, your rights and choices, and the steps we take to keep it secure and confidential.
We review our privacy policy periodically and seek to update it where important developments require. This privacy policy was last updated on 31 October 2023.
This privacy policy covers:
· How we use your information to provide our services
· Why we share your information with other organisations
· How we transfer your information to other countries
· What happens to your information when we don’t need to use it anymore
· How we keep your information secure
· Your rights in relation to your information
· Your rights when you follow links to external websites
· How you can ask for more information, make an enquiry, or make a complaint
· How to contact Leeward’s Data Protection Officer
USING YOUR INFORMATION TO PROVIDE OUR SERVICES
Leeward collects and holds personal information that identifies its clients, client control persons and beneficial owners, intermediaries, suppliers and other third parties linked to our clients. The types and amount of information we collect differs depending on your relationship with us. We only collect the data we need in order to provide the services you have asked for, or that we need in order to fulfil our legal or regulatory obligations in relation to those services. If we need to collect additional information we will explain why we need it.
You are not obliged to provide any of the information we ask you for, but if you choose not to we may be unable to provide you with services or respond to your enquiries.
The examples in this section are only an overview of the types of processing we carry out. If you would like a more in-depth list of our processing activities and our legal basis for processing, please contact us using the below contact details.
When you enquire about our services and when you have appointed or engaged us to provide services, your personal information may be used for:
· Responding to enquiries, offering services, and agreeing terms of business
· Communicating with you about the services you have asked us to provide and informing you of changes that affect those services
There are times when we are under a legal obligation to collect your personal information, including for preventing financial crime, tax evasion, and the funding of terrorism.
There are occasions where it is in our legitimate interests to collect and process your information, for example:
- When you ask us to provide new services we need to assess the risks associated with providing that service. This will involve us using information we already hold and information from background checks and research information to evaluate the risks to you, to us, and to our clients and stakeholders.
- In the course of conducting a licensed business, we may be required in the course of financial, internal or IT security audits, or for regulatory reporting, to process and share your information with service providers and regulators.
In some circumstances we cannot process your data without your explicit consent, such as when your capacity for decision is in question. If we ask you to provide sensitive information we will explain your options before we ask you to provide it.
SHARING YOUR INFORMATION WITH OTHER ORGANISATIONS
In the usual course of our business, we use third party organisations to support the essential delivery of our services. Under these circumstances Leeward remains responsible for the security and privacy of your information and we regularly review third parties’ security measures to ensure they meet the same standards you expect from us. Third party organisations operate under contracts that restrict their use of your personal information to providing the services we have engaged them for.
We may also have an obligation to share some of your personal information with public authorities, such as:
· Tax authorities
· Regulatory authorities
· Law enforcement agencies
In some cases, your personal information will be shared with organisations outside Leeward in order to obtain specialist or professional services that are necessary for the services we provide.
These external organisations have a legal obligation to comply with privacy and data protection legislation and may also operate under a professional duty of confidentiality due to the type of service they provide. They have their own privacy policies that provide information about how they use your information. You can find out more about the organisations your data has been shared with by contacting us.
TRANSFERRING YOUR INFORMATION TO OTHER COUNTRIES
When we share your information with organisations that are located in different jurisdictions, we ensure they apply equivalent levels of protection.
STORING AND DELETING YOUR INFORMATION
The amount of time we keep your personal information will vary. In some circumstances, there is a legal or regulatory requirement to keep information for a specific amount of time, although this will be extended if there is ongoing legal action that overrides the normal retention period. Where there is no regulatory or legal requirement, we assess how long we reasonably need to keep your information in order to deal with ongoing queries.
When our relationship with you ends, there will be information we cannot delete immediately. Such information will be stored in our physical and/or electronic archives until we no longer have an obligation to keep it. At that point the information will be permanently deleted.
KEEPING YOUR INFORMATION SECURE
We take the security of personal information and confidential documents very seriously. Leeward complies with the Cayman Data Protection Act, 2017 and we have put in place appropriate safeguards to prevent unauthorised access or unlawful use of confidential information.
We restrict access to personal information to Leeward employees, contractors and agents who need to know that information in order to process it for us. They are subject to strict contractual confidentiality obligations and they may be disciplined or their contract terminated if they fail to meet these obligations.
YOUR RIGHTS
Subject to some exceptions, you have the right to:
· know whether Leeward is processing your personal information
· request a copy of the personal information Leeward holds about you
· have any inaccuracies corrected or and have incomplete personal data completed
· have your personal data erased if it is no longer needed
· stop Leeward form handling your data, not begin the handling of your personal information or to cease processing your personal data for a specified purpose or in a specified way
· object to Leeward using your data for direct marketing purposes
· not be subject to a decision based solely on automated processing if it produces adverse legal effects
· make a complaint to the Ombudsman of the Cayman Islands
If you would like to exercise any of your rights please contact our Data Protection Officer.
LINKS TO EXTERNAL SITES
Leeward’s website may from time to time contain links to other websites which are not controlled by Leeward. We are not responsible for the privacy of those sites, and we encourage you to review the privacy policies of each one when you visit external sites so that you understand how those other organisations are using your personal information.
QUERIES AND COMPLAINTS
This privacy policy aims to give you an overview of the ways in which we process your personal information. If you would like more detail or have any queries, please contact us so that we can assist you. We take any complaints we receive about the provision of our services to you and the way we process your information very seriously and we would like to hear from you if you have any concerns. Please refer to the contact section at the bottom of this policy for information about our location and contact details.
If you have any concerns about the way we process your personal information we would prefer that you contact us to discuss your concerns. You also have the right to make a complaint to the Ombudsman of the Cayman Islands.
LEEWARD DATA PROTECTION OFFICER
If you have any questions about this privacy policy or any other data protection issues please contact:
Leeward Data Protection Officer
Camana Bay
Suite 3119, 9 Forum Lane
George Town, Grand Cayman, Cayman Islands
Phone: +1 345 746 6410
Email: dpo@leewardmanagement.ky
Ombudsman
PO Box 2252
5th Floor Anderson Square
George Town
Grand Cayman KY1-1107
CAYMAN ISLANDS
Client Services Complaints
Should you have any concerns or complaints please complete this form. You will receive an acknowledgement within 48 hours of our receipt of a complaint and confirmation of any actions taken within 7 business days.
You may also contact CIMA directly as follows:
The Cayman Islands Monetary Authority
SIX, Cricket Square
PO Box 10052
Grand Cayman KY1-1001
Cayman Islands
Tel: +1 (345) 949-7089