Your Personal Information

Our legal and regulatory obligations require us to obtain information about clients as well as individuals associated with clients and client structures. This is both from the perspective of combating money laundering/terrorist financing (referred to below as "AML/CFT measures") and to comply with tax reporting requirements, including those concerned with FATCA and CRS (the US Foreign Account Tax Compliance Act and the Common Reporting Standard).

In holding and processing your personal information, we comply with legislation which regulates the processing of information relating to individuals and which provides certain protections and rights for data subjects; and we observe high standards of professionalism and client confidentiality. Disclosure of your personal information to third parties will only be made where there are overriding legal duties to do so or our interests reasonably require it as, for example, in the following circumstances:

• to comply with applicable AML/CFT measures;
• where disclosure is to our regulator, relevant tax authorities, our auditor and/or our reporting accountant, as necessary for them to perform their respective functions;
• where disclosure is necessary to protect our legitimate legal or business interests (for example, for the purposes of defending claims or proceedings involving third parties or otherwise, and in enforcing our legal rights); and
• to our agents, service providers and business partners with, where appropriate, appropriate confidentiality and non-disclosure provisions in place.

We may also disclose your personal information with your express agreement or at your direction.

Your personal information will be processed for the purposes of providing professional services in accordance with our client retainer, to comply with our legal and regulatory obligations and otherwise for the purposes and/or in the circumstances referred to above. We will not share your personal information with, or sell it to, to third parties, nor will we use it to send you marketing communications.

Your personal information will be held by Meridian Trust Company in the location of the Meridian Trust Company office to which you provided the data; and may be transferred to and/or processed in locations including countries outside the EEA, where comparable standards of data protection may not apply (but in which case we will take reasonable steps to protect your information by, e.g., obtaining contractual undertakings).

If you require any further information about how we handle and process your personal information, you can contact us by writing to datacontroller@meridiantrustnevis.com.