First National Trustee Company Limited

Legal & Compliance

Website Disclaimer

(1) Introduction
This disclaimer governs your use of our website; by using our website, you accept this disclaimer in full. If you disagree with any part of this disclaimer, you must not use our website.

(2) Intellectual property rights
Unless otherwise stated, we or our licensors own the intellectual property rights in the website and material on the website. Subject to the licence below, all these intellectual property rights are reserved.

(3) Licence to use website
You may view, download for caching purposes only, and print pages from the website for your own personal use, subject to the restrictions below.

You must not:


Whilst we endeavour to ensure that the information on this website is correct, we do not warrant its completeness or accuracy; nor do we commit to ensuring that the website remains available or that the material on the website is kept up-to-date.

To the maximum extent permitted by applicable law we exclude all representations, warranties and conditions relating to this website and the use of this website (including, without limitation, any warranties implied by law of satisfactory quality, fitness for purpose and/or the use of reasonable care and skill).

Nothing in this disclaimer (or elsewhere on our website) will exclude or limit our liability for fraud, for death or personal injury caused by our negligence, or for any other liability which cannot be excluded or limited under applicable law.

Subject to this, our liability to you in relation to the use of our website or under or in connection with this disclaimer, whether in contract, tort (including negligence) or otherwise, will be limited as follows:


(4) Variation
We may revise this disclaimer from time-to-time. The revised disclaimer will apply to the use of our website from the date of the publication of the revised disclaimer on our website. Please check this page regularly to ensure you are familiar with the current version.

(5) Entire agreement
This disclaimer, together with our Business Privacy Policy, constitutes the entire agreement between you and us in relation to your use of our website, and supersedes all previous agreements in respect of your use of this website.

(6) Law and jurisdiction
This disclaimer will be governed by and construed in accordance with the law of the Isle of Man, and any disputes relating to this disclaimer will be subject to the jurisdiction of the courts of the Isle of Man.

(7) Registrations and authorisations
Licensed by the Isle of Man Financial Services Authority
Company registration Number - 037018C
VAT number - GB 000 1962 34

Privacy Notice For Website Users

(1) Introduction
Welcome to FNTC’s privacy notice for website users.

FNTC is a company incorporated in the Isle of Man under registration number 37018C. FNTC respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

(2) Important information and who we are
Purpose of this privacy notice

This privacy notice aims to give you information on how FNTC collects and processes your personal data through your use of this website, including any data you may provide through this website when you complete the “Contact Us” form, sign up to our newsletter or if you request other marketing materials.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice is intended to deal with information you provide to us via our website and supplements the other notices and is not intended to override them.

Controller
This privacy notice is issued on behalf FNTC so when we mention “we”, “us” or “our” in this privacy notice, we are referring to FNTC which entity is the controller of personal data you may input to this website and is responsible for this website.

Philip Broomhead is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

If you are unhappy with our treatment of your personal data, you have the right to make a complaint at any time to the Data Protection or Information Commissioner’s Office in the jurisdiction in which you live or the data controller responsible for your personal data operates. We would, however, appreciate the chance to deal with your concerns before you approach such authorities so please contact us in the first instance.

Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

(2) The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

From this website we may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you via this website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

(3) How is your personal data collected through this website?
We use different methods to collect data from and about you including through:

(4) How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting info@fntc.com

Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a potential new customer or intermediary(a) Identity

(b) Contact
Necessary for our legitimate interests (to expand our customer and intermediary referrer base to grow our business)
To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey
(a) Identity

(b) Contact

(c) Marketing and Communications
(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity

(b) Contact

(c) Usage

(d) Marketing and Communications
(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Usage

(d) Marketing and Communications

(e) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage
Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or if you provided us with your details and expressly consented to receiving that marketing.

Third-party marketing
We will never share your personal data with any company outside FNTC for marketing purposes.

Opting out
You can ask us to stop sending you marketing messages at any time by email to info@fntc.com or by letter to the Digital Marketing Department, FNTC Limited, First Names House, Victoria Road, Douglas, Isle of Man IM2 4RB.

Cookies
You can set your browser to refuse all or some browser 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. Our cookie policy is available on our website www.fntc.com

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the Group Risk Director.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

(5) Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

(6) International Transfers
We may share your personal data within other companies within FNTC. This may involve transferring your data outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it than operates in the Isle of Man by ensuring at least one of the following safeguards is implemented:

If you want further information on the specific mechanism used by us when transferring your personal data out of the EEA, please contact the Group Risk Director.

(7) Data security
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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Sending information over the internet to us is generally not completely secure, and we can’t guarantee the security of your data whilst it is in transit. We have procedures and security features in place to keep your data secure once we receive it.

(8) Data retention
How long will you use my 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 legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

(9) Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary section entitled “Your Legal Rights” to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact the Director of Group Risk.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

(10) Glossary
Lawful basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties
Internal third parties
Other companies in FNTC acting as joint controllers or processors and provide services to FNTC such as risk management, HR, IT and system administration services and undertake leadership reporting.

External third parties

Your legal rights
Your legal rights will depend upon a number of factors including your country of residence and the location of company which operates this website and will generally include the right to:

Group Anti-Bribery and Corruption Policy

IQ-EQ, FNTC’s parent company, is committed to maintaining the highest levels of legal and ethical standards in the conduct of its business and to operating in an honest and transparent way, without bribery or corruption being used to obtain any unfair advantage. Please click to read IQ-EQ’s public statement detailing our Anti-bribery and Corruption policy..

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