General Data Protection Regulations:The Sovereign Group Ltd and its subsidiaries (“Sovereign”) are committed to comply with all data protection laws as applicable such as the General Data Protection Regulation (“GDPR”), the e-Privacy Directive and any implementing act as appropriate.

The scope of the data protection laws is to guarantee the rights and freedoms of data subjects in relation to their personal data that under the GDPR is defined as

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural personal is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

We are required to notify you with the following information regarding the processing of personal data relating to you.

Data Protection Officer:If you would like to contact us with any queries or comments, please contact our Group Data Protection Officer by using the below contact details:

Luca Esposito
Sovereign Pension Services Limited
Level 5, St. Julian’s Business Centre
Elia Zammit Street, St. Julians, STJ3153, Malta

Email address: dpo@SovereignGroup.com

Contact number: (+356)27888132

Who we are?The entities of Sovereign may be “data controller”, “data processor” or “joint controller”, as appropriate, regarding one or more specific processing of personal data. A full list of entities can be found at the following link.
Legal basis of processing:Sovereign will process your data for the following legal basis:

  • In the performance of the contract we have entered into with you or to enter into a contract with you;
  • Where we need to comply with a legal obligation; and
  • It is in our legitimate interest to process your personal data;
Purposes of processing your data:Sovereign will process your data according to the main purpose of the company that is to offer corporate, family office, residency, payroll, accountancy and retirement planning services and other services as agreed with you from time to time. Sovereign will process your data for security reasons, such as due diligence checks, know your client procedures, fraud prevention, anti-money laundering obligations.

Sovereign may process your data for direct marketing purpose.

Categories of personal data that we collect:Sovereign in the course of its relationship with you will collect the following data about you and, in some circumstances, your spouse, civil partner, partner, beneficiaries or dependants:

  • Client details (name, date of birth and so forth);
  • Contact details (address, telephone, email);
  • Identification documents (passport);
  • Marital status and other data, which is deemed special category of data regarding lifestyle, sexual orientation or religion (gender, marital or relationship certificate);
  • National insurance number;
  • Tax identification number;
  • Bank details;
  • Source of wealth
  • Recorded phone calls.

Sovereign may obtain some of this information from your advisors or agents, if we hold your permission to do so, and from sources available in the public domain.

Representative in the European Union: Sovereign elected as Representative of Controllers and Processors not established in European Union the following company:

Sovereign Pension Services Limited
Level 5, St. Julian’s Business Centre
Elia Zammit Street, St. Julians STJ3153, Malta

Telephone call recording:Sovereign may have the legal obligation to record telephone calls in certain circumstances, such as the security call to verify the identity of a member, and use a secure telephone call logging software to record, store and archive those telephone calls.

At certain conditions, recorded voice can be considered health data and as such appropriate safeguards are in place.

Consequences of non-provision of your personal data: In case personal data is necessary to enter into or perform the contract, Sovereign would not be able to enter into or continue with its contractual relationship with you.

In case personal data is processed according to the legitimate interest of Sovereign, you can oppose the legitimate interest at any time, without affecting the contract, especially for marketing purposes, unless exceptions provided by the law apply.

Recipients of your personal data: Sovereign shall keep your data confidential and, when disclosed, ensure that third parties shall treat your personal data accordingly.

However, from time to time, we may be requested to disclose personal data by law enforcement or to comply with legal obligations to governmental agencies or entities, regulatory authorities or other persons in line with any applicable law, regulations, court order or official request. For example, your data may be shared with these entities where Sovereign would be expected to cooperate in the event of a criminal investigation.

In any other case, Sovereign will share your personal data to execute the contract or related services to:

  • Other Sovereign offices across the world;
  • Professional advisors such as lawyers, accountants, financial advisors; and
  • Other financial institutions such as banks, insurance and investment companies;
Will your data be transferred inside/outside of the EU?Sovereign may transfer your data outside the European Economic Area and countries that the European Commission has deemed adequate. In such case, the legal tool for international transfer is the standard contractual clauses drafted by the European Commission, a copy of which may be found at the following link:
https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=en
How will it be protected whilst in transit and where can I obtain further details? Data will be encrypted and/or password protected.
How long will the data be retained? Sovereign shall retain your personal data for the entire duration of the contractual relationship.

After, Sovereign shall retain data according to the applicable law, but no longer than what is required by the applicable law or the statute of limitation for civil liability.

Beyond, the data shall be destroyed or anonymised.

Your rights: Unless legal exemptions apply, you shall have the right:

  • To be informed about how we use your personal data;
  • To access your data and obtain one copy free of charge in an electronic format;
  • To have your data rectified promptly if it is inaccurate or incomplete;
  • To have your data erased;
  • To restrict processing; and
  • To object to processing of your data;
Opt-Out from Legitimate Interest:You have the right to opt-out at any time from legitimate interest-based processing, unless we can demonstrate a compelling legitimate ground (e.g. fraud detection). In case of marketing you have always the right to opt-out.
Complaints: Sovereign is represented within the European Union by Sovereign Pension Services Limited in Malta, thus the relevant data protection authority is the Information and Data Protection Commissioner.

If you wish to lodge a complaint, please contact Sovereign’s DPO (dpo@SovereignGroup.com) or, if you prefer to complain to a higher authority, please contact the data protection authority of your habitual residence, place of work or place of the alleged infringement.

What about Cookies?

 

A HTTP cookie is a small text file that a website stores on your machine’s browser.

Sovereign’s website minimises the use of cookies to those strictly necessary, third-party performance cookies (google analytics) and functionality cookies, to personalise your experience offering tailored features.

Sovereign does not deploy flash cookies or cookies walls.

You can choose whether to accept cookies by changing the settings of your browser. Typically, by accessing the browser’s help feature you can obtain information on how to prevent your browser from accepting all cookies or to notify you when a cookie is being sent. If you choose not to accept these cookies, your experience at our website and other websites may be diminished and some features may not work as intended.

 

Definitions: Data Subject is a living individual to whom personal data relates.

Processing means any operation or set of operations which is performed on personal data or on sets of personal data.

Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others (“Joint controller”), determines the purposes and means of the processing of personal data.

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Special categories of personal data means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Hyperlinks from The Sovereign Group to websites outside The Sovereign Group: There may be cases on our website when Sovereign provide hyperlinks to other locations or websites on the Internet. These hyperlinks lead to websites published or operated by third parties who are not affiliated with or in any way related to Sovereign. They have been included in our website to enhance your user experience and are presented for information purposes only. We endeavour to select reputable websites and sources of information for your convenience.

However, by providing hyperlinks to an external website or webpage, Sovereign shall not be deemed to endorse, recommend, approve, guarantee or introduce any third parties or the services/ products they provide on their websites, or to have any form of co-operation with such third parties and websites unless otherwise stated by Sovereign.

We are not in any way responsible for the content of any externally linked website or webpage. You use or follow these links at your own risk and Sovereign is not responsible for any damages or losses incurred or suffered by you arising out of or in connection with your use of the link. Sovereign is not a party to any contractual arrangements entered into between you and the provider of the external website unless otherwise expressly specified or agreed to by Sovereign.

Any links to websites that contain downloadable software are provided for your convenience only. Sovereign are not responsible for any difficulties you may encounter in downloading the software or for any consequences from your doing so. Please remember that the use of any software downloaded from the Internet may be governed by a licence agreement and your failure to observe the terms of such licence agreement may result in an infringement of intellectual property rights of the relevant software provider which we are not in any way responsible.

Please be mindful that when you click on a link and leave our website you will be subject to the terms of use and privacy policies of the other website that you are going to visit.

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