Your privacy and the safety of your personal information is very important to us. We want you to understand what data we collect, how we protect it, and how we may use it. This Privacy Policy provides examples of the types of personal information we may collect and with whom we may share it. Please note that these examples are not exhaustive of our collection or sharing practices.
Information We May Collect
We are required to collect personal information to determine if you qualify for our products and to service your account. All data is collected on a lawful basis and we only collect what is necessary for our business with you. Depending on the product(s) you apply for, the information we collect may include:
- Financial Information: To evaluate your eligibility (e.g., income, net worth, employment status).
- Identity Information: For compliance with regulatory requirements (e.g., identification documents, name, address, date of birth, country of residence).
- Consulting Information: Needed to provide our consulting services (e.g., tax identification numbers, tax forms).
- Service Information: To service your consulting arrangement (e.g., email, phone number, banking information).
Information We May Disclose and To Whom
We may share some or all of your personal information with:
- Your investment manager;
- Your asset custodian;
- Our banking institutions; and
- Other third-party firms that assist in providing the consulting services you acquire.
In certain circumstances, we may disclose some or all personal information (as permitted by law) to entities such as:
- Law enforcement agencies;
- Government regulators; or
- Auditors.
We do not sell any personal information to any third parties.
Procedures to Protect Your Personal Information
We have robust procedures and technology in place to safeguard your personal information. Only employees who require access to your data to provide consulting services have access. Our employees are regularly trained on the importance of data privacy and security.
Data Retention
All data is preserved in compliance with Bermuda regulatory requirements for client record retention. We delete your data as soon as it is no longer necessary, in accordance with our records retention policy.
Your Right to Access Your Data
You have the right to request access to your data and to understand its usage. To request access, please submit a written request to our Data Privacy Officer using the contact details below. In accordance with the Bermuda Personal Information Protection Act of 2016, your data will be made available for review within 45 days of your request.
Contact Information
For all data inquiries, please contact our Data Privacy Officer, Kimberly Gibson, at info@64northwest.com or call 441 707 0247.
