Privacy Notice

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Stonehage Fleming Services Limited

 

This Privacy Notice explains how Stonehage Fleming Services Limited (“us”,“we”) and other companies in the Stonehage Fleming Group collect, use and disclose your personal data, and your rights in relation to the personal data being held by us and other Group companies.

We may amend this Privacy Notice from time to time, to reflect any changes in the way that we process your personal data. This Privacy Notice supersedes any previous version of this notice with which you may have been provided or have had sight of before the stated date, as well as anything to the contrary contained in any agreement with us.

 

How we share your data

 

We may use other Group companies to provide services to you and we may share your personal data for the reasons set out elsewhere in this Privacy Notice. The companies in the Group (“other Group companies”) which may be involved in delivering services to you or processing your personal data in a related manner are:

 

 

ServiceCompany
Investment management and dealing services

Stonehage Fleming Investment Management Limited (United Kingdom)

Stonehage Fleming Dealing and Treasury Services (Jersey) Limited

Stonehage Fleming Dealing and Treasury Services (UK) Limited

Stonehage Fleming Investment Management (Suisse) AG

Stonehage Fleming Investment Management (South Africa) (Pty) Limited

Stonehage Fleming Investment Management (Liechtenstein) AG

Stonehage Fleming Asset Management (Pty) Ltd (South Africa)

Financial services, estate administration, trust and other services and art management

Stonehage Fleming Financial Services Limited (United Kingdom)

Stonehage Fleming (Israel) Financial Services Limited

Stonehage Fleming Financial Services (Pty) Limited (South Africa)

Stonehage Fleming Wealth Planning Limited (United Kingdom)

Primafides (Suisse) SA

Alto Trust Limited

Heritage Trustees SARL (Switzerland)

Stonehage Fleming Executors Limited (South Africa)

Stonehage Fleming Services (IOM) Limited (Isle of Man)

Stonehage Fleming Trustees (Pty) Ltd (South Africa)

Stonehage Fleming Trustees Limited (Isle of Man)

Stonehage Fleming (Mauritius) Limited

SF Trust (Liechtenstein) AG

Stonehage Fleming SA (Switzerland)

Stonehage Fleming (Canada) Incorporated

Stonehage Fleming Fiduciary Limited (South Africa)

United States tax, legal advice and related services

Stonehage Fleming US LLC

Stonehage Fleming Law US

Stonehage Fleming Advisory (Pty) Ltd (South Africa)

Stonehage Fleming Advisory (IOM) Limited (Isle of Man)

Insurance servicesStonehage Fleming Insurance Services Limited (Jersey)
Administration services

Stonehage Fleming Trust Holdings (Jersey) Limited

SF Trust Protectors (Switzerland) SARL

Chasseral (Directors) Limited

Stonehage Fleming Secretarial Limited (Mauritius)

Stonehage Fleming (Mauritius) Management Services Limited

Fund Administration, Corporate Trustee services

Stonehage Fleming Corporate Services Limited (Jersey)

Stonehage Fleming Corporate Services Luxembourg S.A. (Luxembourg)

Stonehage Fleming Corporate Services (Pty) Limited (South Africa)

Stonehage Fleming (Mauritius) Corporate Services Limited

Stonehage Fleming (Guernsey) Limited

Corporate Finance adviceStonehage Fleming Advisory Limited (United Kingdom)
United Kingdom tax and legal adviceStonehage Fleming Law Limited (United Kingdom)

 

Our Group companies in Switzerland, Israel, Jersey, Liechtenstein, Luxembourg, Guernsey, Malta, the Isle of Man, the United Kingdom and Canada provide an adequate level of protection for your personal data. Where we share your data with one or more of our offices in a third country (i.e. a country that does not provide an adequate level of protection for your personal data) we make use of standard contractual clauses, as a safeguard, to protect your data, or will share your data with your explicit consent. The Group has offices in the following third countries: United States of America, South Africa, Monaco and Mauritius.

 

We may also share your personal data with other companies or service providers we have engaged to assist us in providing services to you. These companies may be located in a third country which does not provide an adequate level of protection for your personal data. Where we share your personal data with a company or service provider in a non-adequate / third country we use standard contractual clauses or another available safeguard to protect your data, or will do so with your explicit consent.

 

If you wish to receive details regarding the companies within the Group or other service providers which we have engaged to assist in delivering services to you or entities in respect of which you are connected or have an interest and with whom we have shared your information please contact us at the following email address: groupdataprotectionofficer@stonehagefleming.com

 

How we collect your data

 

We and other Group companies may collect your personal data in a number of ways, for example:

  • From the information you provide to us when you meet with us;
  • From an employee or employees of one of our Stonehage Fleming Group (“Group”) companies or from a family member;
  • When you communicate with us or when we communicate with you by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
  • When you or your agent complete or we complete on your behalf client on-boarding or application or other forms;
  • From other companies in our Group;
  • From intermediaries, your agents, advisers and individuals in an organisation with which you are associated;
  • From the trustee(s) of any trust in respect of which you are a settlor or a beneficiary or with which you are otherwise connected;
  • From your agents and advisers, insurance companies, fund managers, investment managers and custodians of your assets;
  • From publicly available sources or from third parties where we need to conduct background checks about you.

 

The categories of the data we collect

 

We and other Group companies may collect the following categories of personal data about you:

 

 

All Group companies

 

  • Your name, date of birth, passport or national identity card details;
  • Country of birth, domicile and citizenship;
  • Contact information such as residential or business address, email address and telephone number;
  • Biometric data such as CCTV images when you visit our offices;
  • Gender, marital status;
  • Information about your employment, education, family, personal circumstances and interests;
  • Information relating to your tax affairs including your tax status and tax identification number;
  • Information, some of which is collected daily, to assess whether you may represent a money laundering, terrorist financing or reputational risk to the Group. This includes whether you are a Politically Exposed Person, are involved in a high risk business, have been arrested, charged or convicted of a crime, are on a sanctions list or expose us to tax, litigation, bribery or corruption risk.
  • Information relating to you and your financial situation such as your industry and marketing segment, the services we offer which may be of interest, your net worth, income, expenditure, assets and liabilities, sources of wealth and your bank account details;
  • Information about your knowledge and experience in the corporate or investment field;
  • Information regarding your goals and objectives in connection with your wealth;
  • With your explicit consent, information concerning your health where relevant to services provided.

 

Art Services

 

  • Details of your art collection

 

Insurance Services

 

  • Where you have provided your written consent, information concerning your health where you seek assistance in obtaining life insurance or medical cover;
  • Information relating to risks and exposures, which may include details of your assets and liabilities.

 

United States companies

We do not knowingly request or collect personal data from any person under 16 years of age without prior verifiable parental consent. If you believe that your child under the age of 16 has provided personal data to us without prior verifiable parental consent, please email usprivacyofficer@stonehagefleming.com so that we can take steps to delete the personal data that she or he has provided as required in accordance with applicable law.

 

 

The basis for processing your data other than with your consent, how we use that data and with whom we share it

 

We may process your personal data because it is necessary for the performance of a contract to deliver the services you have engaged us for or in order to take steps at your request prior to entering into a contract.

Our other Group companies may also process your personal data where it is necessary for the performance of a contract to deliver the services we have engaged them for or in order to take steps at your or our request prior to entering into a contract.

 

 We and other Group companies use your personal data for the following:We and other Group companies may share your personal data with the following:

This and other Group Companies

  • To prepare preliminary information or a proposal for you regarding the services we offer;

  • To provide you with the services as set out in our terms of engagement with you or as otherwise agreed with you from time to time;

  • To deal with any complaints or feedback you may have;

  • To book transport from and to our offices when you are visiting us;

  • For any other purpose for which you provide us with your personal data.

Your advisers or agents or employees of firms with which you are associated;

  • Companies, partnerships, other entities or the trustees of trusts, and the directors and/or employees of such companies, partnerships, other entities or trustees of trusts, in respect of which fiduciary and/or administrative services are provided, and in respect of which you are connected or have an interest;

  • Other third parties such as banks, intermediaries, insurance companies, fund managers, investment managers or administrators;

  • Registered agents;

  • Our advisers where it is necessary for us to obtain their advice or assistance;

  • Companies within our Group;

Payment processors where we are making payments on your behalf;

  • Transport companies and travel agents;

  • Our data storage providers.

 

Art Services

 

To arrange for the acquisition, insurance, transportation and exhibition of art.

  •  
  • Insurance brokers where we are instructed to arrange insurance;
  •  
  • Museums, galleries and auctioneers where you wish art to be exhibited;
  •  
  • Storage facilities where you wish art to be stored.

 

Corporate Finance

 

  • To provide you with corporate finance and/or direct investment opportunities or as otherwise
  • agreed with you from time to time.
Potential counterparties and their advisers in relation to our corporate finance or direct investment opportunity services.

 

Stonehage Fleming Law Limited

To provide you with legal services.

  • Third party service providers who we may engage on your behalf, for example, e-disclosure service providers and/or forensic data investigators;

Advisers or agents where it is necessary for us to obtain their advice or assistance, for example, foreign legal advisers and/or counsel or other specialists;

  • The Office of the Public Guardian;

  • Relevant tax authorities. 

 

 

If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your personal interests or fundamental rights and freedoms which require protection.

 

We and our other Group companies may also process your data for our compliance with a legal obligation which we and / or they are under.

 

 

We and other Group companies use your personal data for the following:We and other Group companies may share your personal data with the following:
  • To meet our compliance and regulatory obligations, such as compliance with anti‐ money laundering and countering terrorist financing regulations, tax reporting and beneficial ownership reporting requirements.
 
  • Our advisers where it is necessary for us to obtain their advice or assistance;
  • Our auditors where it is necessary as part of their auditing functions;
  • With third parties who assist us in conducting background checks about you, such as whether you are on sanctions lists;
  • With relevant regulators, tax authorities and law enforcement agencies where we are required to do so.

 

Retention of your data

 

We retain your personal data in accordance with our Records Retention Policy and applicable laws, after which it will be destroyed or deleted. We may keep your information longer where:

  • There is pending litigation or an investigation.
  • It may be required to assist with the mitigation of any future tax or regulatory query into the transactions or other affairs undertaken by an entity or trust to which we provide regulated services. This ensures that the rights and freedoms of our clients, our staff as well as the Group and its Members are safeguarded.

 

Version: June 2026

The Stonehage Fleming group is now part of Corient Global HoldCo Limited.

 

Contact details and appointed representatives

 

GROUP DATA PROTECTION OFFICER 
By post: 6 St James's Square, London SW1Y 4JU, United Kingdom 
By email: groupdataprotectionofficer@stonehagefleming.com 
By telephone: +44 (0) 207 036 5000 

 
JERSEY 
Privacy Officer 
By post: Floor 4, Liberation House, Castle Street, St Helier Jersey, JE1 4HH Channel Islands 
By email: jerseyprivacyofficer@stonehagefleming.com 
By telephone: +44 1534 823 109 

 
LIECHTENSTEIN 
Privacy Officer 
By post: Landstrasse 123, 9495 Triesen, Liechtenstein 
By email: liechtensteinprivacyofficer@stonehagefleming.com 
By telephone: +423 399 02 53  


LUXEMBOURG  
Privacy and Data Protection Officer  
By post: 58 Rue Charles Martel, L-2134, Luxembourg City, Luxembourg 
By email: luxprivacyofficer@stonehagefleming.com 
By telephone: +352 2744 7300 
 

GUERNSEY 
Privacy Officer 
By post: La Vieille Cour, La Plaiderie, St Peter Port Guernsey, GY1 1WG 
By email: guernseyprivacyofficer@stonehagefleming.com 
By telephone: +44 1534 740 040 
 

ISLE OF MAN 
Data Protection Officer 
By post: Falcon Cliff, Palace Road, Douglas, Isle of Man, IM2 4LB 
By email: isleofmandataprotectionofficer@stonehagefleming.com 
By telephone: +44 207 087 0136

 

ISRAEL 
Privacy Officer 
By post: 2 Zarhin Street, 5th Floor, PO Box 4214, Raanana, 4366507, Israel 
By email: israelprivacyofficer@stonehagefleming.com 
By telephone: +972 9 970 1000

 

MALTA 
Privacy Officer 
By post: 4th Floor, Avantech Building, St Julian’s Road, San Gwann, SGN 2805, Malta 
By email: maltaprivacyofficer@stonehagefleming.com 
By telephone: +356 22486207 
 

MONACO 
Privacy Officer 
By post: Palais Saint James, 5 avenue Princesse Alice -3rd Floor, 98000, Monaco 
By email: monacoprivacyofficer@stonehagefleming.com 
By telephone: +377 97 97 31 80 
 

MAURITIUS 
Privacy Officer 
By post: 1st Floor, Les Fascines Building – Block B, Vivéa Business Park, Rue des Fascines, Moka, Mauritius 
By email: DPOMauritius@stonehagefleming.com 
By telephone: +230 490 1100

 

SOUTH AFRICA 
Information Officer 
By email: sainformationofficer@stonehagefleming.com 
By telephone: +27 21 301 0800 / +27 11 544 2900 
 

SWITZERLAND  
Privacy Officer 
By post: Rue Du Puits-Godet 6, PO Box 763, 2002 Neuchatel, Switzerland 
By email: swissprivacyofficer@stonehagefleming.com  
By telephone: +41 32 723 1038 
 

UNITED KINGDOM  
Data Protection Officer 
By post: 6 St James's Square, London SW1Y 4JU, United Kingdom 
By email: ukdataprotectionofficer@stonehagefleming.com 
By telephone: +44 (0) 207 036 5000 
 

UNITED STATES  
Privacy Officer 
By post: 1700 Market Street, Suite 3010, Philadelphia PA19103, United States of America 
By email: usprivacyofficer@stonehagefleming.com  
By telephone: +1 215 665 7270

 

Appointed representatives

 

The appointed representative in the European Union for non-EU based Group Companies is Sturdon Holdings Luxembourg SARL. The Data Protection Officer in Luxembourg may be contacted using the following email address or telephone number:

 

Email: luxprivacyofficer@stonehagefleming.com

Tel: +352 2744 7300.

The appointed representative in the United Kingdom for non-UK based Group Companies is Stonehage Fleming Services Limited. The Data Protection Officer in the United Kingdom may be contacted using the following email address or telephone number:

Email: ukdataprotectionofficer@stonehagefleming.com

Tel: +44 207 036 5000.

 

Version: June 2026

The Stonehage Fleming group is now part of Corient Global HoldCo Limited.