1.1 What personal information does Freeland collect?
We collect personal information that is required to enable us to provide a broad range of services for administration, corporate and trust, banking, financial products, reporting and tax services to our clients and related parties (“Clients”). The kinds of personal information and special information that we may collect includes:
We may also collect other information that is relevant to our functions or activities. We collect information in various ways, including from:
We may also collect other information that is relevant to our functions or activities.
1.2 How does Freeland collect information?
We collect information in various ways, including:
In some circumstances, we may collect personal information about you from a third party or from publicly available sources. The parties from whom we may acquire personal information may include Freeland affiliates, Clients in which you are or were an investor, other Client service providers including fund managers, your adviser’s or anyone you have authorized to deal with us on your behalf.
1.3 Why does Freeland collect information?
We only collect, hold, use and disclose personal information for purposes related to our functions or activities, including for the purposes of:
Furthermore any other uses identified at the time of collecting your personal information.
If we do not collect this personal information, we may not be able to provide Clients with the services or assistance requested.
We may periodically collect information from you through the use of “cookies” and similar online tracking tools across our websites. This is in order for us to provide better service, enhance the user experience, store online preferences, track usage of our websites and services, or generally improve/update data security.
3. How does Freeland disclose personal information?
We may disclose your personal information to the following parties:
This list of possible disclosures is not intended to be exhaustive and there may be other legitimate purposes for holding, disclosing or otherwise processing your personal information. Where the law so requires, you will be notified of any additional purposes and where required your consent will be sought.
To provide services to Clients, your personal information may be transferred and/or stored in other jurisdictions, including to jurisdictions that may not offer a level of personal data protection equivalent to your country of residence. We ensure that all data transfers comply with applicable legal requirements. Should you wish to know more about how your personal information is protected please contact the person stated below.
4. Legal bases for using your personal information
There are different legal bases that we rely on to use your personal information, namely:
We implement and maintain physical, electronic and procedural safeguards and security measures which are reasonably designed to protect your personal information. For example, we implement:
6. Accessing and correcting personal information held by Freeland
You may access the personal information we hold about you, and you may make or seek changes to that information, by contacting us using the contact details set out below. You may also ask us to erase, restrict or port your personal information and you may tell us if you object to our use of your personal information. To exercise these rights please contact us using the details below.
We will promptly investigate your privacy enquiry and provide you with answers or update our records, as appropriate.
7. Retention of your personal information
We will retain your personal information in accordance with our Data Retention Policy.
8. Questions or complaints
You may make a complaint about an alleged breach by us of applicable Privacy laws in relation to our handling of your personal information. Your complaint should be in writing and addressed to the undersigned. Alternatively, you have a right to complain to your local data protection authority (if one exists in your country).
T: +31 10 201 3626
Office Address: Coolsingel 61, NL-3012 AB Rotterdam, The Netherlands