Introduction

The purpose of this notice is to provide you with information on our use of your personal data in accordance with the Data Protection Law, 2017 of the Cayman Islands (the "DPL").

In this document, "we", "us" and "our" refers to Wheatstones, its subsidiaries and their affiliates and/or delegates.

 

Your Data 

By virtue of your associated interactions with us and the recording of electronic communications or phone calls where applicable or by virtue of you otherwise providing us with personal information of individuals connected with you (for example directors, trustees, employees, representatives, shareholders, beneficial owners or agents), you will provide us with certain personal information that constitutes personal data within the meaning of the DPL. Data includes, without limitation, the following information relating to you and/or any individuals connected with you: name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, credit history, correspondence records, and passport number. In our use of data, Wheatstones will be characterized as a "data controller" for the purposes of the DPL. Wheatstones’ and the partners'/directors' affiliates and delegates may act as "data processors" for the purposes of the DPL. 

 

Who this Affects 

If you are a natural person, this will affect you directly. If you are a corporate (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with data on individuals connected to you for any reason in relation to your interaction with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

 

How We May Use Your Personal Data 

Wheatstones, as the data controller, may collect, store and use data for lawful purposes, including, in particular: 

(i) Where this is necessary for the performance of our rights and obligations;

(ii) Where this is necessary for compliance with a legal and regulatory obligation to which Wheatstones or the partners/directors are subject; and/or 

(iii) Where this is necessary for the purposes of our legitimate interests and such interests are not overridden by your interests, fundamental rights or freedoms. 

Should we wish to use data for other specific purposes (including, if applicable, any purpose that requires your consent), we will contact you. 

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Why We May Transfer Your Personal Data 

In certain circumstances we and/or our authorized affiliates or delegates may be legally obliged to share data and other information with the relevant regulatory authorities such as the Cayman Islands Monetary Authority or the Tax Information Authority. They, in turn, may exchange this information with foreign authorities, including tax authorities.   

We anticipate disclosing data to parties who provide services to Wheatstones and their respective affiliates (which may include certain entities located outside the Cayman Islands or the European Economic Area), who will process your personal data on our behalf. Such parties may include, to the extent applicable: 

(i) Administrator and/or sub‐administrator; and

(ii) Wheatstones’ accountants, auditors, consultants, lawyers and other outside professional advisors. 

 

The Data Protection Measures We Take 

Any transfer of data by us or our duly authorized affiliates and/or delegates outside of the Cayman Islands shall be in accordance with the requirements of the DPL. 

We and our duly authorized affiliates and/or delegates shall apply appropriate technical and organizational information security measures designed to protect against unauthorized or unlawful processing of data, and against accidental loss or destruction of, or damage to, data. 

We shall notify you of any data breach that is reasonably likely to result in a risk to the interests, fundamental rights or freedoms of either you or those data subjects to whom the relevant data relates. 

 

Getting In Touch 

Should you have any queries or wish to discuss your data protection with us, please email at info@wheatstones.com