ACSP Members

Veris Secretarial Limited

Services: TCSP Fiduciary, Accounting, Taxation, VAT

We are a long established family run CSP and TSP offering local and international services. We can also offer accounting services via our associated practice Edwards and Hartley, established in 1970. The principals of the business, Patrick Hartley (FCCA, LLB) and Andrew Hartley (ACIS) are proud to provide a highly personalised and bespoke package to our clients through many years of experience and expertise.

We are located in Douglas but also have a family office in London.

For additional information and assistance please contact Andrew Hartley on 671233 or at veris@manx.net.

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Privacy Notice

Your information
This notice applies to personal information held by Veris Secretarial Limited (Veris) as Data Controller.

"Information" refers to any personal data about you that you or third parties provide to us.

"You" refers to you in your capacity as a Customer, related party or controller of any relationship, entity or trust structure we operate.

Why we collect information
The type of information collected by Veris will differ depending on the services being provided. In general, the information will be used for the following purposes:
To enable Veris to enter into an agreement with you; fulfilling our legitimate interests, such as in the managing of risk; carrying out your instructions – e.g. trust and company administration services; creation and ongoing administration of a company or trust; the administration of investments; investigation and resolution of complaints; corresponding with solicitors, surveyors, valuers, conveyancers or other third parties for the provision of our services to you; recover debts owed to Veris; defence of our legal rights; complying with the regulatory requirements in relation to anti-money laundering, countering terrorist financing and anti-bribery & corruption in verifying you and your identity and assessing your suitability for our services and products; detecting and preventing crime, such as fraud; improving our services to you; the provision of information to relevant tax authorities as and when required; the provision of information to other external regulatory bodies to which we are legally required to provide information to, as and when the governing legislation or tax reporting requirements change, or any other legal requirement.

We will use your information where we have your consent or where another lawful reason exists such as the provision of a contract, in our legitimate interests, where we believe it is in the public interest, in defence of our legal rights or to comply with a legal requirement.

Where you determine not to provide the data or request us to cease processing your data we may need to cease provision of our services to you.

What we will collect about you
The type of information we will collect includes:
Personal details such as name, former names, date of birth, gender and place of birth; contact details such as address, previous addresses, email address and phone numbers; information about your marital status, dependents and social circumstances; tax reporting information including country of domicile, national insurance number or tax identification number; employment details, education, qualifications and positions held; confirmation of your right to act in relation to a company or structure or entity; information about your identity including passport copies, driving licence copies, other photographic identification documents, proof of address verification such as utility bills or bank statements or otherwise as provided; other information you provide relating to your financial standing, your personal wealth, assets and liabilities and the source of funds in order to verify the source of wealth for the arrangements you have with Veris; we may also require detail relating to your ability to cover a debt, repay a loan and your overall financial standing may also be applicable; where permitted by law, information about criminal convictions or offences or alleged offences or claims made against you or entities associated with you, for specific and limited activities such as completing our due diligence requirements; details of disqualifications or other relevant notices which are available in the public domain; details of any prominent or politically exposed position held.

The information you provide will only be used for the purposes of the provision of our services.

Some of the information we collect will come direct from you, other information will come from third parties or from publicly available sources. Veris will use third party sourced data to carry out due diligence checks, sanctions and anti-money laundering checks. This is information we need to support our regulatory obligations. The information listed above may relate to you as our Customer, but also to persons that are associated with any entity or structure with you, such as a trust or managed company.

If you fail to complete our full "Know Your Customer" due diligence requirements, we will not be able to facilitate or offer to provide any service to you.

We may also collect information on third parties or family members through the documentation you provide to us. We will only use the necessary information to meet our compliance obligations, to comply with laws and regulations that Veris is subject to.

Information we generate about you
We will generate information about you in the course of our relationship, including:
Your identification information and signature; where relevant the source of your wealth and the source of funds introduced to any client entity or structure; record of any meetings, advice or recommendations given to you; tracking information – see note below; records of correspondence received and processed by email, letter, voicemail etc.

Tracking
We may monitor or record any communication between you and Veris including face to face meetings, letters, emails and any other kind of communication. We may use these recordings to check your instructions to us, to assess and improve our service to you, train staff, manage risk and to prevent and detect crimes such as fraud.

Where we may transfer your information
Your information may be shared or transferred where it is lawful to do so, depending on the type of service we are providing, with the following:
Other trustees, beneficiaries, controllers, administrators or executors; other parties involved in a dispute including disputed transactions; other financial services providers, lenders and credit reference agencies in relation to credit arrangements; other financial services providers for the provision of transactions; beneficiaries of payments or remitters of transactions; fund managers, brokers, asset managers or agents who deal on your behalf; intermediaries or introducers who have an interest in the business introduced to Veris; anyone who is instructed to act on your behalf, power of attorney, solicitors, accountants, etc.; entities or individuals in connection with a potential or actual corporate restructure, merger, acquisition or sale, including the transfer or potential transfer of any of our rights or duties under our agreement with you; internal and external auditors operating within the Veris group of companies; auditors or parties appointed to carry out investigations or audits of our activities; law enforcement, courts, dispute resolution and regulators as required by law; Government agencies and third party data processors in regard to the provision of tax reporting, as required by law; any other individual or entity that we have been instructed to share your information with by you, either jointly, solely or as a controller.

Overseas transfer of your information
Veris may occasionally transfer data outside of the Isle of Man under the following specific circumstances:

• For the performance of a contract between the client and Veris, or the implementation of pre-contractual measures taken at your request;
• For the conclusion or performance of a contract concluded in your interest between Veris and another person.

In practical terms this will involve the requirement to provide due diligence to third party financial institutions and service providers etc. outside of the Isle of Man in order to allow for a banking facility or for other services to be provided. It may also involve the requirement to provide personal data to FlyingBoat for CRS reporting XML conversion purposes, and as consented to via our individual tax self-certification forms.

In all cases, we will only share your information with those that have a right to see it, where there is an obligation to remit the information, where it is in our legitimate interest or where it is a requirement in order to facilitate a contract with you.

Your rights
You have a number of rights in relation to the information we obtain and hold about you, such as:
The right to access the information we hold about you and how it is processed; the right to receive the information you provided to us in a portable format, including the right to have the information provided to a third party; the right to have inaccurate information rectified; the right to erase information in certain circumstances. Where we are legally obliged to, we will continue to hold your information; the right to object to processing of your information or restrict the manner in which it is processed in certain circumstances. Where we are legally obliged to, we will continue to process your information and can refuse your request; the right to complain about our processing or handling of your information.

Where you complain about our processing of your information we will investigate on your behalf. You also have the right to lodge your complaint with the Isle of Man's Information Commissioner, whose contact information can be found at: www.inforights.im.

Retention of information
Your information will be retained in line with the requirements of relevant legislation that govern Veris, including those relating to trust and company administration, anti-money laundering and countering terrorist financing. The retention period is determined based on the type of record, the nature of the activity and the product and service offered. Detail of our retention timeframes is contained within our retention policy which may be updated from time to time as overriding legislation changes.

Once your information is no longer required we will destroy, delete or anonymise the data and can confirm that no further decisions will be made about you based on this deleted information.

We may need to retain your information outside of the prescribed timeframes, where an ongoing investigation is being undertaken by a Police force, other investigative agency or regulatory body, or where a dispute has arisen and is being investigated or whereby legal proceedings are taking place.

In these instances, your information will be retained for as long as deemed necessary. Destruction of such data will be completed as soon as practicable thereafter.

Security of Information
The information we collect about you is stored under our control.

We have put in place security procedures plus technical and organisational measures that we consider appropriate to safeguard your personal information and which are intended to guard against unauthorised or unlawful access to, alteration, disclosure or destruction of personal data and against accidental loss or destruction of or damage to personal data. Access to internal data servers is limited to specialist personnel and is controlled using defined policies.

Your obligations
We request that you ensure the information we hold about you is accurate and up to date. Please notify us as soon as possible if your circumstances change. We are obliged to send certain mandatory communications to you and therefore need to have accurate contact information for you.

Contact:
If you have any queries regarding this Privacy Notice or how we process your information, please contact us using the details noted below:

Veris Secretarial Limited
1st Floor, Peregrine House
Peel Road
Douglas
Isle of Man
IM1 5EH

Email: veris@manx.net

Phone: (0044) 1624 671233

Updated 29.11.2020

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