Privacy Policy
This Privacy Notice is intended for individuals who receive services provided by RBC Offshore Fund Managers Limited.
We are firmly committed to protecting your personal, financial, and business information.
We want you to understand:
- what personal information we collect about you
- how we obtain your personal information
- how we use your personal information
- on what basis we use your personal information
- with whom we share your personal information
- the countries to which we transfer your personal information
- how long we keep your personal information
- your rights regarding your personal information
If you have any questions, or you would like any further detail about the contents of this Privacy Notice, feel free to get in touch via one of the methods set out in the “Contact Us” section below.
What personal information do we collect about you?
The information we may collect from you includes:
- This Privacy Notice is intended for individuals who receive services provided by RBC Fund Administration (CI) Limited
- information establishing your identity (for example, name, address, phone number, date of birth, etc.) and personal background (and may include personal information concerning your family members, if provided to us)
- information related to transactions or financial behaviour arising from your relationship with and through us
- information you provide on an application form for any products and services
- information you provide with respect to events in the lifecycle of the employee benefit plan that you participate in, for example withdrawals
- information regarding your wishes regarding application of death benefits
- in respect of corporate or institutional customers (including partnerships), details about persons with an interest in that customer, including but not limited to shareholders, partners, directors, trustees, settlors, protectors, beneficiaries, staff, and corporate contacts (including their individual customers and such customers’ family members), and authorised signatories.
How do we obtain your personal information?
We may collect and confirm your information during the course of our relationship with you and will only use personal information which constitutes personal data in accordance with applicable data protection laws.
We may obtain this information from a variety of sources including from you, from service arrangements you make with or through us, from your employer or former employer (or members/ affiliates of their group) and from other sources, as is necessary for the provision of our products and services.
We may make searches with people tracing agencies, which will keep a record of that search. Where our customer is a corporate or other institutional customer, we may also make enquiries with licensed credit reporting or fraud prevention agencies about your directors or partners (as the case may be).
If you communicate with us using email or by other electronic means, then we may monitor email or other electronic traffic to gather information for the purposes of security, statistical analysis, and systems development.
How do we use your personal information?
We may use or process your information for the following purposes:
- to verify your identity and investigate your personal background
- to facilitate or otherwise assist in the provision of your account with us or any service provided by us to you and / or the investment fund(s) and / or other holding entities that you invest in
- to service any of your other relationships with RBC
- to meet our or RBC’s regulatory and/or legal and/or financial and/or other reporting obligations in the UK or in any other jurisdiction (as applicable)
- to comply with laws, regulations, or court orders in any jurisdiction (whether or not the same is strictly binding or capable of being enforced against us)
- to prevent or detect fraud, money laundering, terrorist financing or other criminal conduct (including, without limitation, compliance with RBC’s internal know your client, anti- money laundering and anti-bribery and corruption policies)
- to recover a debt
- to assess and manage our operations and financial and insurance risks
- to develop new products and services
- to bring or defend any dispute or litigation concerning your account with us or the services provided by us to you
- to determine your suitability for products and/or services offered by us or RBC
- to satisfy any regulatory requirements, or for the sake of research or history or to prepare or contribute to high-level anonymised statistical reports
- as a record of any information obtained from or about you during our relationship and
- to allow for certain efficiencies including operating and managing systems, systems back-up and data recovery, risk evaluations, know your client procedures to verify client identity, and anti-money laundering screening.
We may wish to send to you information on services or other offerings which we believe will be of interest to you. Using your personal information helps us to make our communications with you more relevant, selective, and personalised to you, and to make your experience of our services efficient and effective. If you do not wish to receive this information you should notify us in writing as described in the “Your Rights” section.
On what basis do we use your personal information?
We use your personal information on the following basis:
- to comply with legal and regulatory obligations
- to perform our legal obligations to you for legitimate business purposes. Using your personal information helps us to operate and improve our business and minimise any disruption to the services that we may offer to you.
We also have a legitimate interest in sending you information on services and offerings which we believe will be of interest to you. See the “How do we use your personal information” section for further details about the legitimate business purposes for which we process personal information - because you have given your consent (if we expressly ask for consent to process your personal information, for a specific purpose) and
- to prevent and detect crime, or for reasons of substantial public interest, and for the establishment, exercise or defence of legal claims or proceedings.
- Notwithstanding that we may ask for your consent to share your confidential information, unless expressly stated otherwise we rely on another legal basis to process your personal information, as set out above.
With whom do we share your personal information?
We will only disclose or transfer your information for the purposes set out in this document to:
- RBC’s employees, agents and service providers and other companies within RBC, who are required to maintain the confidentiality of this information
- your employer or former employer, at their request, or if it is required for us to provide you with our services
- companies and organisations that assist us to process transactions including, but not limited to, custodians
- regulatory, police authorities or law enforcement and fraud prevention agencies, where we or RBC are compelled or permitted or required to do so by order of a court or governmental or administrative tribunal or by law, regulation, or any other legal requirement
- credit reporting agencies, to whom we provide credit information, details of how your account is operated in instances such as where you have fallen behind with repayments on a debt or other liability owed to us, financial and other related information and who may share it with others
- anyone with whom you hold a joint account, and/or any person you nominate in the application form (or otherwise) as having authority on your account with us
- any person to whom we may assign or transfer our rights and/or obligations under our agreement with you or any third party because of a restructuring, sale or acquisition of Royal Bank of Canada or any of its direct or indirect subsidiaries, provided that the recipient uses the information for the same purpose as it was originally supplied to us and/or used by us
- such persons as we believe is necessary where a failure to make such disclosure would result in damage to our reputation or good standing, expose us to civil or criminal prosecution in any jurisdiction or where failure to make such disclosure would in our opinion be prejudicial to us, RBC, our nominees, advisors or agents or to such other person that we or RBC believe in good faith have a right to make a request for disclosure and
- any other person where disclosure is made at your request or with your consent (including your advisors or agents), or if otherwise permitted under our agreement with you.
Transfers of your personal information outside of your data controller’s jurisdiction
Delivering our services may result in certain of your personal information being transmitted through or stored or processed in jurisdictions other than the jurisdiction where your data controller is based (see the “Data Controller” section below).
TThese other jurisdictions may be outside the UK, the Channel Islands and/or the European Economic Area and may result in your information being subject to the laws of those other jurisdictions, whether or not those jurisdictions have equivalent or adequate data protection legislation.
Depending on the jurisdiction where your data controller is based, these other jurisdictions may include but are not limited to:
- United Kingdom
- Guernsey
- Canada
If we transfer your personal information outside of the jurisdiction where your data controller is based, we will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of your data controller’s jurisdiction, in accordance with applicable data protection laws.
These measures include entering into Standard Contractual Clauses. For further information, please contact dpo@rbc.com.
How long will we keep your personal information?
We will only retain the information we gather from you for as long as necessary and in accordance with our Document Retention and Destruction Policy. Following the termination of our relationship with you, this will be for such period as may be required from time to time under relevant laws and regulations, including those relating to record keeping and prescription periods, and for customer identification purposes.
Data security
Protecting your personal data and safeguarding you from fraud are one of our highest priorities. In addition to our strong privacy practices, we employ a diverse range of technologies, security tools and processes to ensure the safety, confidentiality and integrity of your information and transactions.
Your rights
If you believe that any of the centrally held information, including your personal information, is incorrect or inaccurate, you should notify us so that the information can be updated or corrected, as appropriate.
You have the right to:
- access your personal information
- correction, restriction, portability, or erasure of the information that we process about you
- to us using your personal information where we are doing so solely based on our legitimate business purposes or in relation to our use of your personal information for direct marketing purposes.
These rights are subject to any exemptions under applicable data protection laws.
You may seek to exercise these rights at any time by sending a request by email to dpo@rbc.com or writing to us as applicable at: RBC Offshore Fund Managers Limited, PO Box 246, Dorey Court, Admiral Park, St Peter Port, Guernsey, Channel Islands, GY1 3QE and providing further information (including appropriate proof of identity) as requested by us.
You can withdraw your consent to the processing of your personal information (where we are processing your personal information based on your consent). If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. However, this may limit or prevent us from providing the products or services you have asked for. It may also make it more difficult for us to advise you or suggest appropriate alternatives.
If you feel that we do not comply with applicable privacy rules you have the right to lodge a complaint with a competent data protection authority and to lodge an appeal following the determination of that complaint.
Data Controller
The data controller of your personal information is the entity identified in your contractual arrangement or subscription document and the counterparty headlined above who has been contracted to provide services in connection with that arrangement.
Contact us
Our Data Protection Officer can be contacted by email at dpo@rbc.com or in writing to Data Protection Officer, 100 Bishopsgate, London EC2N 4AA.