Website Privacy Policy

Introduction 

Freeport Trust Company Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits the website https://freeport.im (“Our Site”) and only collect and use your personal data in ways that are detailed in this policy, and in a way that is consistent with our obligations and your rights under the law.

What is personal data?

Personal data is defined as any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.  

What are your rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the contact details provided at the bottom of this page.
2. The right to access the personal data we hold about you. Details on how do access your personal data can be found below. 
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details provided at the bottom of this page. 
4. The right to be forgotten, i.e., the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the contact details provided at the bottom of this page.
5. The right to restrict (i.e. prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us the contact details provided  below. It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

What personal data do we collect and how? 

Our Site collects certain non personal data through the use of cookies which can include your IP address, device types, operating systems, browser types and browser versions known as aggregated data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 

If you send us an email, complete the Contact Us section on the website, we will collect your name, your email address, your phone number, and any other information which you choose to give us. 

If you sign up to be kept up to date with our latest news and insights, we will collect your name and your email address. 

Cookies 

We collect data about how you interact with our digital application through the use of cookies and other similar technology.

What is a cookie?  

Cookies are small text files containing small amounts of information which are downloaded to your computer or mobile device when you access our website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. 

You can set your browser to refuse all or come cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 

Why do we use cookies?

Cookies are useful because they allow our website to recognise your device. We use them to make our website work, or work more efficiently, as well as store information about your preferences or past actions. 

We also use cookies to enhance and improve your online experience (for example, by remembering your language and/or preferences) and to better understand how our website is used. Cookies may tell us, for example, whether you have visited our website before or whether you are a new visitor. They can also help to ensure that adverts seen online are more relevant to you and your interests. They cannot be used to identify you personally. 

What types of cookies do we use and how?

We use the following types of cookies:

Session Cookies – These are allocated to your device only for the duration of your visit to our website. These cookies are deleted automatically when you close your browser. 

Permanent Cookies – These survive after your browser is closed and can remain on your device for a period of time. They can be used by our website to recognise your computer or mobile device when you open your browser and browse the internet again. 

These cookies may be served directly by us to your computer or mobile device (so called ‘first party cookies’) or by one of our service providers (so called ‘third party cookies’). A first party cookie is only used by us to recognise your computer or mobile device when you revisit, or access content via, our website. Third party cookies can be used to recognise your computer or mobile device across different websites (and are most often used for analytical and advertising purposes). 

What purposes do we use cookies for? 

We use cookies for the following purposes; 

Essential Cookies – These are essential to provide you with services available through our website and to enable use of some of the features.  

Analytic Cookies – These are used to collect information about how you and others use our website. The information gathered does not identify you and is aggregated. This includes the number of visitors to our website. We use this information to help operate our website more efficiently, to gather broad demographic information and to monitor the level of activity on our website. 

Functionality Cookies – These allow our website to remember choices you make and provide enhanced, more personal features. They can also be used to provide services you have asked for, such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. 

Performance Cookies – These collect information about how you and others use our website, for example, which pages are most visited or if error messages come up. They are only used to help us improve how our website works and to ensure ease and speed of use. 

Marketing Cookies – These facilitate online advertising. Our website uses remarketing with google. Third party vendors, including Google, use these cookies to tailor adverts based on someone’s past visits to our website and serve these across the web. You can set preference for how Google advertises to you using the Google ad settings. 

How to manage cookies? 

You have the right to choose whether or not to accept cookies. However, if you do not accept our cookies, you may not be able to use the full functionality of our website. You can find out more about how to manage and remove cookies at allaboutcookies.org/manage-cookies. 

We use the following cookies:

• Google Analytics
• Google Tag Manager

How do we use your personal data? 

Where we collect any personal data, it will be processed and stored securely, for no longer that is necessary in light of the reason(s) for which it was first collected. 

We do not generally collect any personal data directly from you, but if you have contacted us via the website, we will use the information provided by you to make contact with you in response to your request. 

If you have subscribed to our publications, we will use the information provided by you to contact you with communications that Freeport Trust Company Limited has a legitimate interest to send to you. 

How and where do we store your data?  

All the data that we process about you is held in within our office located at 4 Athol Street, Douglas, Isle of Man, IM1 1LD in paper form and/or electronically. 

Do we share your personal data? 

Freeport Trust Company Limited will not share your personal data with any third parties. 

How do we secure your personal data?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These include firewalls and software to protect against malware and unauthorised access to the information systems. 

How long we will retain personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any statutory, legal and regulatory requirements as well as what we deem to be reasonable practice where there is no record keeping period set down in law or other rules. We will destroy business contact data when our business relationship with you comes to an end. If you have engaged with us via the web site and this does not proceed to a business relationship, we will destroy the data provided six months after the date of your enquiry.

How your personal data can be accessed?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it. This is known as a “subject access request”.

Subject access requests can be made verbally or in writing. If you do make a request verbally, we recommend you follow up in writing in prodder to provide a clear trail of correspondence. Written requests should be sent to the email or postal addresses detailed in the ‘How to contact us’ section. 

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within one month of receipt of the request. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, the time period may be extended by a maximum of a further two months. You will be kept fully informed of our progress and the reasons for any delay before the end of the first month.

How to contact us

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

The Directors
Freeport Trust Company Limited
Address: 4 Athol Street, Douglas, Isle of Man, IM1 1LD
Telephone: 01624 625538
Email: consult@freeport.im

Complaints

Should you feel it necessary to make a complaint about how we have processed your data, please contact the Directors on 01624 625538 or by emailing consult@freeport.im. You can also contact the Information Commissioner on 01624 693260 or by emailing ask@inforights.im