Privacy Policy | ITL - Intercontinental Trust Limited
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Privacy Statement

1. Privacy Policy
This Policy is issued by Intercontinental Trust Ltd. References in this Policy to “ITL” are references to Intercontinental Trust Ltd, any affiliated entities and its subsidiaries. It concerns individuals outside our organisation, including visitors to our websites, customers and suppliers with whom ITL interacts in one way or the other.
This Policy is expected to be updated from time to time to reflect changes towards processing of personal data or any changes as applicable with regards to the Mauritius Data Protection Act 2017 (the “Act”). ITL highly encourages concerned users to read our Privacy Policy at regular intervals and to review any amendments ITL might make.
Reference in this Policy to “Personal Data” means any information that identifies, or could reasonably be used to identify, a living individual, either on its own or together with other information.

2. Processing your Personal Data
Collection of Personal Data: ITL may collect your Personal Data from different sources, namely:
- When you contact us via email or telephone or by any other means of communications;
- As part of our client on-boarding procedure;
- When managing transactions for or on behalf of customers; and
- When you visit our website.
Generally, you will have provided any such data to us. However, in some cases, we may collect data about you from a third-party source, such as government or other agencies, a service provider or from public records.

Creation of Personal Data: ITL creates personal data about you, such as records of your interactions with ITL, and details of your accounts, subject to applicable law.

Relevant Personal and Sensitive Personal Data: ITL may process the following categories of personal data, such as:
- Personal Details: first and last name, middle name, gender, date of birth or age, marital status, ID number, passport number, nationality, photographs
- Family Details: names and contact details of family members
- Contact Details: address, telephone and mobile numbers, email address
- Employment Details: names of current and former employers, work address, work telephone number, work email address and work related social media profile details
- Education History: details of your education and qualifications
- Financial Details: billing address, bank account numbers, credit card numbers, cardholder or accountholder name and details, instruction records, transaction details
- Electronic Identifying Data: IP addresses, cookies and geolocation data

Processing your Sensitive Personal Data: ITL does not seek to collect or otherwise process your personal data except when:
- required by law
- ITL has obtained, subject to applicable law, your explicit consent prior to processing your Personal Data.

Purposes for which we may process your Personal Data, and legal bases for Processing: Whether we receive your Personal Data directly from you or from a third-party source, ITL will only process your personal data for the purposes listed below, subject to applicable law:
- AML and KYC
- Client on-boarding
- Credit worthiness
- Providing Services to you
- Marketing and/or Prospecting
- IT and Information Security operations
- Financial Management
- Analytics
- Physical Security
- Legal matters (for e.g. investigations, legal compliance and legal proceedings)
- Fraud prevention
- For any purpose related to the foregoing or for any purpose for which you provided the personal data to ITL.

3. Disclosure of Personal Data to third parties
ITL may also need to transfer and disclose your personal data to other related companies affiliated to ITL and/or third parties (including Sub-Processors) involved in your matters, for legitimate business purposes, in accordance with applicable laws. Where ITL transfer or disclose your personal data, ITL will do this in accordance with applicable data protection laws and will take appropriate safeguards to ensure its integrity and protection.
ITL shall procure that each Sub-Processor enters into a written agreement subjecting such Sub-Processor to equivalent obligations with respect to Personal Data that are imposed on ITL under this Policy and under the Act.

4. International Transfer of Personal Data
ITL has international customers and business ventures and ITL may need to transfer your personal data and to other related companies within the group in connection with the purposes set out in this policy. All our data resides on private cloud in Microsoft data centres in the northern Europe.

5. Data Security
ITL has implemented the appropriate physical, technical and organisational security measures which ensures a level of internal security designed to protect your personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing of your Personal Data, in accordance with the applicable law.
You are responsible for ensuring secure sending of your personal data to ITL.

6. Data Accuracy
ITL takes reasonable steps designed to ensure that:
- your personal data that we process are accurate and where necessary, kept up to date, and
- any of your personal data that ITL processes and are considered inaccurate, are erased or rectified without further delay.
ITL may request you to confirm the accuracy of your personal data from time to time.

7. Data Minimisation
ITL takes reasonable steps designed to limit the collection of personal data to what is directly relevant and necessary to accomplish specific purposes set out in this policy.

8. Data Retention
ITL takes reasonable steps to ensure your personal data, subject to any applicable law, are retained for only as long as it is necessary to fulfill the purposes set out in this policy.

9. Your Legal Rights
Subject to applicable law, you may have a number of rights regarding the processing of your personal data, including:
- the right to request access to, or copies of, your personal data that ITL processes or control together with information regarding the nature, processing and disclosure of those personal data.
- the right to request rectification of any inaccuracies in your personal data that ITL processes or controls.
- the right to request, on legitimate grounds:
- - erasure of your personal data that ITL processes or controls
- - restriction of processing of your personal data that ITL processes or controls.
- the right to have your personal data that ITL processes or controls transferred to another controller; to the extent applicable.
- where ITL processes your personal data on the basis of your consent, the right to withdraw that consent anytime.
- the right to lodge complaints with a Data Protection Office of Mauritius regarding the processing of your personal data by ITL or on ITL’s behalf.

10. Direct Marketing
ITL may process your personal data to contact you, primarily by email and also by telephone, so that we can provide you with information concerning services that may be of interest, provided that we have first obtained your consent, to the extent required by, an in accordance with applicable law.
If you do not wish to receive marketing communications from ITL, you can opt out at any time by contacting your regular ITL’s contact or by electronically unsubscribing from emails ITL have sent you. After you have unsubscribed, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

11. Contact Details
If you have any comments, questions or concerns about any of the information in this policy, or any issues relating to the processing of personal data by ITL, please contact your regular ITL’s client service contact or:
Intercontinental Trust Ltd,
Level 3 Alexander House,
35, Cybercity, Ebene, 72201, Mauritius.


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