Privacy

The basics

You may visit this site without revealing any personal information. However, if you request specific information, provide feedback, participate in a marketing initiative or apply for a job online you will be disclosing personal data to us. We will take all reasonable steps to ensure your personal data is protected against unauthorized access and it will not be disclosed or sold to another company or organization. The only time we may disclose your personal data is when we are legally bound to do so or as required by our regulators.

These policies are subject to periodic review and any changes will be included in this section of the site.

The detail

Hamilton Trust Company Limited is a member firm of Moore Stephens International Limited (“MSIL”), a worldwide network of independent accounting and consulting firms. MSIL and its member firms are legally distinct and separate entities. They are not and nothing shall be construed to place these entities in the relationship of parents, subsidiaries, partners, joint ventures, or agents. No member firm of MSIL has any authority (actual, apparent, implied or otherwise) to oblige or bind MSIL or any other MSIL member firm in any manner whatsoever.

For the purposes of this Privacy Statement, member firms and correspondent firms of Moore Stephens International Limited are together described as Participant Firms.

This page contains the information gathering and use policies adopted by Hamilton Trust Company Limited in connection with this website (“the Site”). These policies are subject to review and any changes will be included within this section of this Site.

Hamilton Trust Company Limited is not responsible for the privacy policies of third party sites to which links are provided (including sites of Participant Firms). The privacy policies on such sites should be checked before providing any personal information.

Hamilton Trust Company Limited is committed to the protection of personal information supplied by users of this Site.

Collection of information

Hamilton Trust Company Limited will only collect and use personal data voluntarily and openly provided to this website. A user may choose to provide Hamilton Trust Company Limited with limited personal data as required in order to register for certain services; once registered the information will only be used for the specified purpose(s).

At the present time IP addresses of authorized users are not logged for either administrative or other purposes. It will normally be clear when personal information is being collected. The information required is the minimum necessary to enable Hamilton Trust Company Limited to deal with the services requested, but additional information may be requested in order for Hamilton Trust Company Limited to provide the most appropriate response. If such additional information is requested it is highlighted and its provision is voluntary.

Sensitive personal data includes gender, race or ethnic origin, political opinions, religious or other beliefs, trade union membership, physical or mental health, sexual life or criminal records. We do not solicit sensitive personal data through the Site except where legally required to do so.

Use of information

Information is used only for the specific purpose for which it was provided except where there has been an explicit selection to receive other information from Hamilton Trust Company Limited. Personal data provided through the Site will be made available to the provider of the information on request. Personal information may be deleted at any time. Requests for copies or deletion of information may be made by e-mailing htclinfo@htcl.bm.

Provision of information to third parties

Hamilton Trust Company Limited will only provide personal information to third parties in the following circumstances:

  • where the transfer is necessary to fulfill the requirements of the operation for which the information was provided, and the third party is a Participant Firm;
  • in order to fulfill a request which involves other Participant Firms;
  • so as to assist Hamilton Trust Company Limited’s professional advisors regarding matters referred to them concerning the operation of the Site:
  • where requested explicitly by an authorized user of the Site; or
  • as required by a court order or any other legal or regulatory requirement.

Hamilton Trust Company Limited does not collect or compile personal data or information obtained through the Site for dissemination or sale to outside parties. Hamilton Trust Company Limited does not undertake marketing activities for third parties.

Accuracy of information

Hamilton Trust Company Limited assumes responsibility for keeping an accurate record of personal data once it has been submitted, but not for confirming the ongoing accuracy of the personal information. If Hamilton Trust Company Limited is advised that the personal data is no longer accurate, it will be amended (where practical).

Retention of information

Information collected from users of the Site will only be kept in order to provide the required services. From time to time, we may wish to contact you about seminars, workshops, other events, publications or services, which we think will be of benefit to you. You may at any time request us to stop using your personal data for direct marketing purposes. If you wish to do this, please contact us.

Where the information has been collected in connection with an expression of interest in working for Hamilton Trust Company Limited or a Participant Firm, Hamilton Trust Company Limited or a Participant Firm may use, hold and destroy personal data supplied in connection with the initial expression of interest in accordance with the firm’s standard recruitment procedures:
# details may be retained for up to the next twelve months for the purpose of notification of suitable vacancies that might arise;
# details may be used for the purpose of research and analysis designed to improve recruitment and human resources’ policies and practices.

Where the authorized user of the Site has provided additional information, personal details will be retained for a period of time reasonable in the context of the nature of the request.

If these conditions are not acceptable the site should not be further used.

Security of information

Hamilton Trust Company Limited has implemented accepted standards of technical measures and security policies that are aimed at protecting the personal data it has under its control from:

  • unauthorized access;
  • improper use or disclosure;
  • unauthorized modification;
  • unlawful destruction or accidental loss.

All Hamilton Trust Company Limited and Participating Firm’s personnel are required to keep personal information confidential and only authorized persons have access to such information.

Children

We understand the importance of protecting children’s privacy especially in an online environment. This Site is not intentionally designed or directed at children 13 years of age or younger and it is our policy never to knowingly collect or maintain information about anyone under the age of 13 years.

Cookies

“Cookies” are not used on this Site.

Inaccuracies and corrections

We would like to keep your personal data accurate and up to date. If you become aware of any errors or inaccuracies please let us know by contacting us.

Other matters

Please note that the Site contains links to other sites (including sites maintained by Participant Firms) which are not governed by this privacy statement.

If you have any questions about this privacy statement please email htclinfo@htcl.bm.