Privacy Policy
We provide independent directors with solid Web3 expertise and understanding to the boards of VASPs, DAOs, foundations, OpCos and associated entities.
IMS Group-Data Protection Privacy Notice
This Privacy Notice is provided on behalf of the IMS Group of companies, which includes IMS, as the Cayman Islands Administrator, IMS Data Privacy Policy (“we”, “us” or “IMS Group”) and explains to you how we will handle your personal data. We will collect, use, and process your personal data in accordance with this Privacy Notice and the Cayman Islands Data Protection Act (as amended, “DPA”) and/or other relevant legislation.
References to “personal data” or “Personal Data” means any information that identifies, or could reasonably be used to identify, an individual and where such term is defined and regulated by the DPA.
The Personal Data we Collect.
We primarily acquire personal data in relation to providing our services to our clients, including in relation to client onboarding and conducting anti-money laundering checks. We also collect and hold personal data in respect of:
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Persons engaged by us;
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Our professional advisors and service providers;
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Our partners, contacts, and visitors;
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Persons who apply for employment with us;
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Persons whose personal data we receive:
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When you use our organisation of offices or general services as our visitor;
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When you interact with our website or other digital services.
When provided as or on behalf of such data as in other circumstances, such as when you disclose details of persons or third parties to us in your capacity as our client’s officer, agent or service provider, for example.
If you are a director or similar position, we may receive personal data from, such as (1) from either or service providers or (2) from public records.
The personal data we collect will vary based on your relationship with us. Where we have personal data relating to you, we may, subject to and where permitted by section 18 of the DPA and/or other relevant legislation, use, store, transfer, and process personal data/information of (1) for internal operations, and (2) for business processes including, without limitation, record keeping, disaster recovery, regulatory and/or internal compliance, due diligence checks, accounting, auditing, and other legitimate business interests.
The personal data we collect and process may include:
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Identification data and background information provided by you or collected by us as part of our business acceptance process (which may include: name, address, nationality, tax identification number, date and place of birth, copies of identification documents such as passport and driving license, photographs, marital status, health information, political opinions, and/or other personal data/information relating to you or another individual;
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Financial information, such as your financial position, sources of wealth, and investment activity;
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Other personal information as beneficial owner/controller;
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Other personal information provided in correspondence and during meetings and/or events
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For us in the context of providing services and governance which may include special categories of data, such as health information, political opinions, and religious beliefs, if we are under a legal or regulatory obligation to do so.
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When you use our organisation of offices or general services as our visitor;
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When you interact with our website or other digital services.
This is not an exhaustive list of the personal data we may process on you
Why and on What Basis We Use Your Personal Data
We rely on several legal bases for processing your personal data, depending on the purpose of the processing, including where we have your consent or where we have a legal or regulatory obligation to do so. For example, we may process personal data to:
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Comply with legal and regulatory obligations, including any anti-money laundering, developments and obligations we may have; to comply with all sanctions lists; and to establish, exercise or defend legal or contractual rights in connection with compliance and adherence to legal obligations.
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To enable us to provide our services and/or carry out our business operations, including where we administer funds, foundations, companies, and other entities and where necessary for the purposes of processing payments, accounting, auditing, billing, and invoicing and related administrative functions.
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To enhance the security of our communications and systems (including where we manage access to our offices and systems).
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For monitoring and recording for business and legal purposes.
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For marketing and providing you with relevant information about our services and products.
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Where permitted by relevant law, we may process personal data for any purpose that is not incompatible with the purpose for which it was originally collected.
I have also given my consent to the foregoing or for any purpose for which we provided the personal data to IMS Group.
Retention of Personal Data.
We will keep your personal data for as long as we consider necessary, for the purpose of processing. When we determine the appropriate retention period, we take into account any legal or regulatory obligations we may have, the risk of harm from unauthorised use or disclosure, and the purposes for which we process the personal data. In any event, we will not keep your personal data for longer than is necessary.
Disclosing Personal Data to Third Parties.
Your personal data may be shared among all the entities within the IMS Group both inside and outside the Cayman Islands and with third-party service providers who help us provide our services and who are bound by contractual agreements with us.
We may also need to transfer personal data to third parties, including but not limited to lawyers or service providers in relation to the provision of the services and/or where we are legally or contractually obliged to do so. In particular, we may transfer personal data to:
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Service providers (including IT providers, mail houses, and payment processors)
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Service providers in relation to the provision of data protection, including (if you fill this out here), or where the personal data is required to comply with regulatory obligations
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Service providers, auditors, regulators, courts, government agencies, customs authorities, and other parties involved in your business.
We may also transfer your personal data to third parties in the context of any mergers, acquisitions, or restructurings, including all or part of our business, and where permitted by the DPA and relevant legislation (including the GDPR).
We will ensure that all third parties who process your personal data are contractually obliged to keep your personal data confidential and secure, in accordance with our instructions and regulatory requirements.
Transfer of Personal Data Outside the Cayman Islands.
Your personal data may be transferred to and stored in a country outside the Cayman Islands, including countries with different data protection laws to the Cayman Islands. We will take steps to ensure that your personal data is protected as required by relevant laws and regulations, including the DPA and the GDPR.
Your Rights Regarding your Personal Data.
You have the right to request access to the personal data we hold about you. You may also have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
You may also have the right to request that we erase your personal data, object to or restrict our processing of your personal data, or request that we transfer your personal data to another party.
If you have given your consent for us to process your personal data, you have the right to withdraw that consent at any time.
If you have any concerns about how we are processing your personal data, you have the right to lodge a complaint with the Cayman Islands Ombudsman or other relevant supervisory authority.
Data Protection Officer.
The IMS Group has appointed a Data Protection Officer. If you have any questions about this Privacy Policy, or how we handle your personal data, please contact the Data Protection Officer.
[Email address redacted from the original text for privacy].
Rights of Data Subjects.
The rights of data subjects are exercised in accordance with the DPA and other relevant legislation
Retention and Disposal.
Data records are retained and disposed of in accordance with the DPA and other relevant legislation.
Amendments to this Privacy Policy.
We reserve the right to amend this Privacy Notice from time to time and will post the updated version on our website. We encourage you to review this Privacy Notice periodically to stay informed of our data protection practices.
Governing Law.
This Privacy Notice is governed by the laws of the Cayman Islands.