Your Privacy Is Important To Jermyn

In the course of serving you as an individual client or as someone associated with a corporate or institutional client, Jermyn may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This Policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy. As used throughout this Policy, the term “Jermyn” refers to Jermyn Capital Partners Plc, and its affiliates worldwide.

The Sources of Information

The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Jermyn during the course of your relationship with us. We may also collect information about your transactions and experiences with Jermyn relating to the products and services Jermyn provides. In addition, depending on the products or services you require, Jermyn may obtain additional information about you, such as your credit history, from consumer reporting agencies.

Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g., recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis but it may be used for compliance or security purposes.

Information we will require About You

If you deal with Jermyn in your capacity as an Intermediate Customer,  a settler/trustee/beneficiary of a trust,  an owner or principal of a company, or other investment vehicle established to invest on your behalf , or on behalf of your Family Office,   information we will collect about you will include:-

• Full Name
• Address
• Contact Details

Proof of your address using any two of the following:-

• Utility Bills
• Bank Statements
• Lawyer's letter confirming your address
• Tax authority correspondence

A certified copy of your passport or driving licence which should include a photograph of you.

Any other relevant information necessary to meet anti-money laundering identification.


Our Use of Your Personal Information

We may use your personal information to:

• Administer, operate, facilitate and manage your relationship and/or account with Jermyn. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively
  
  
• Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account
  
  
• Provide you with information (such as investment research), recommendations or advice concerning products and services offered by Jermyn; and
  
  
• Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

If your relationship with Jermyn ends, Jermyn will continue to treat your personal information, to the extent we retain it, as described in this Policy.

Disclosures of Your Personal Information within Jermyn

In order to provide efficient and reliable services, and to improve product and service options available to you, more than one entity within Jermyn may be given, or given access to, your personal information. For example, one Jermyn entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts or as part of its arranging for the performance of specialised services such as U.S. and international brokerage, asset management, and advisory and trust services. When so sharing your personal information we adhere to applicable legal and industry standards regarding the protection of personal information.

Disclosures of Your Personal Information to Third Parties

Jermyn does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with Jermyn, including those that provide professional, legal, or accounting advice to Jermyn. Non-affiliated companies that assist Jermyn in providing services to you are required to maintain the confidentiality of such information to the extent they receive it, and to use your personal information only in the course of providing such services and only for the purposes that Jermyn dictates.

We may also disclose your personal information to fulfil your instructions, to protect our rights and interests and those of our business partners, or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to a subpoena or similar legal process, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities, or with organizations such as exchanges and clearinghouses.

You should know that Jermyn will not sell your personal information.

Privacy and the Internet

The following additional information will be of interest to you if you access Jermyn products or services through one or more Jermyn Web sites:

• Users of Private Jermyn Web sites are required to identify and authenticate themselves prior to accessing our services. Generally, identification and authentication take place through the use of your user name and a password.
  
  
• The private Jermyn web sites are built upon a secure infrastructure and use standard industry encryption technologies to protect your information from external compromise.
  
  
• Security is a cooperative effort between Jermyn and the users of the Jermyn Web sites. Please remember that your password is personal to you and should not be made available to any other person. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them. We cannot guarantee the confidentiality of information sent to us by email and therefore we would advise clients and users to carefully consider this before sending any confidential and sensitive information by such means.
  

• “Cookies” are small text files consisting of information stored by your Web browser, or operating system or any third-party tools or software. This information is used for administrative purposes and to improve your experience with our Web sites. For example, this information helps authenticate you (i.e., verify that you are who you say you are), an essential component of site security. Cookies also make it easier for you to navigate a Jermyn Web site by, among other things, “remembering” your identity so that you do not have to input your password multiple times as you move between pages or services. You can set your Web browser to inform you when cookies are set, or to prevent cookies from being set. However, if you decline to use cookies, you may experience reduced functionality, and declining to use authentication related cookies will prevent you from using the Web site altogether.
  
  
• If you are a client of Jermyn, your personal information is held on our secure databases outside the website. We shall not ask you to provide any additional personal information on our website.

• If you wish to become a client of Jermyn, you will be required to download our Account Application forms and send them to us in the post along with attested copies of identity documents. These details are not exposed on the website at any time.

Other Privacy Policies or Statements; Changes to Policy

This Policy provides a general statement of the ways in which Jermyn protects your personal information. You may, however, in connection with specific products or services offered by Jermyn, be provided with privacy policies or statements that supplement this Policy. This Policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised Policy will be effective immediately upon posting to our Web site. This version of the Policy is effective December 1, 2006.

Additional Information

You are entitled to access any personal data about you held by Jermyn by sending a written request to the applicable individual identified below. You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorized disclosure of your personal information. We will process your request within the time provided by applicable law. You are also entitled to have Jermyn modify or delete any information that you believe is incorrect or out of date.

Jermyn may occasionally contact you by post, telephone, electronic mail, facsimile, etc., with details of products and services that we believe may be of interest to you. If you do not wish to be contacted in this way, if you wish to exercise your rights of correction and access, or you have difficulties viewing this Web site please contact us.