Last Updated: December 10, 2019 by Marc Godard, Data Controller, Strategic Wealth Preservation Ltd.
Strategic Wealth Preservation Ltd. (SWP) is a company headquartered in the Cayman Islands. Our services enable our clients to, among other things, buy, sell and store precious metals. We also provide other related services. We are committed to protecting your privacy. In this policy, we set out how SWP collects personal data, how it uses and shares it, and the rights and choices you have in relation to the personal data held and processed by SWP.
SWP will ensure that its practices remain compliant with all local laws and regulations on data protection and privacy. As of the date hereof there is no legal obligation on SWP to any foreign government, including any foreign tax authority, regulator and/or any foreign public authority to provide information on any customers and/or any transactions performed under this Agreement. To the extent that SWP is subject to any obligations under any law, SWP shall comply with those obligations and will notify you if possible.
SWP recognizes your right to confidentiality where your identity has been validated and, as physical bullion is not classified as a financial product, customer transactions do not fall under normal financial reporting rules. However, if SWP becomes suspicious of an attempt at money laundering, or if contacted by Cayman Islands authorities in a matter of money laundering, SWP is under an obligation to assist the authorities.
Information We Collect
The Personal Information that we may collect broadly falls into the following categories:
Information you provide to us: During engaging with our services, you may provide personal information about yourself or an entity you represent. Personal information is often, but not exclusively, provided to us when you sign up for and use the services, consult with our customer service team, send us an email, or communicate with us in any other way.
- Registration information: You need an SWP account to use our services as a client. When you register for an account, you will be asked to provide certain basic information, such as your name, email address, username, password, company name, occupation, location, and phone number.
- Billing and communications information: If you purchase our services, you may also need to provide us with payment and billing information, such as your credit card details, billing address or bank wire details. SWP will also maintain a record of your billing transactions and purchases, and any communications and responses.
- Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.
Use of Personal Information
We may use the personal information we collect through the services or other sources for a range of reasons, including:
- To bill and collect money owed to us by you
This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number.
- To send you system alert messages.
- To communicate with you about your account and provide customer support.
- To send you information for marketing purposes, in accordance with your marketing preferences.
- For recruitment purposes if you have applied for a role with SWP.
- To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.
- To manage our websites and system administration and security.
- To improve the navigation and content of our websites.
- To identify any server problems or other IT or network issues.
- To process transactions and to set up online accounts.
- To compile aggregated statistics about site usage and to better understand the preferences of our visitors.
- To carry out research and development to improve our products and services.
- To customize content and layout of the websites.
- To carry out other legitimate business purposes, as well as other lawful purposes.
Data Protection Rights
You may have the following data protection rights:
- To access, correct, update or request deletion of personal information. SWP takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. As a client, you can manage your individual account and profile settings within the dashboard provided through the SWP online platform, or you may contact us directly by emailing us at email@example.com.
- In addition, individuals who are residents of the EEA can object to processing of their personal information, ask to restrict processing of their personal information or request portability of their personal information. You can exercise these rights by contacting us at firstname.lastname@example.org.
- Similarly, if personal information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- The right to complain to a data protection authority about the collection and use of personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request.
Public Information and Third-Party Websites
- Blog. We have public blogs on our websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your personal information appears on our blogs and you want it removed, contact us at email@example.com. If we are unable to remove your information, we will tell you why.
- Social media platforms and widgets. Our websites include social media features. These features may collect information about your IP address and which page you are visiting on our website, and they may set a cookie to make sure the feature functions properly.
How We Share Information
- Our service providers:
Sometimes, we share your information with our third-party service providers, who help us provide and support our services and other business-related functions. Examples include analyzing data, hosting data, engaging technical support for our services, and processing payments.
Below is a list of third-party service providers that we may share your information with depending on the services you purchase from us or how you engage with us:
Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
Any other person with your consent.
Legal Basis for Processing Personal Information (EEA Persons Only)
If you are from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect and use personal information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the services and our websites; and for our marketing activities.
If you are a client, we may need the personal information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not, as well as of the possible consequences if you do not provide your personal information.
Where required by law, we will collect personal information only where we have your consent to do so.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at firstname.lastname@example.org.
Your Choices and Opt-Outs
Clients and visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us at email@example.com. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and clients cannot opt out of these messages unless you cancel your SWP account.
We take appropriate and reasonable technical and organizational measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information. For further information about our security practices, please see contact us firstname.lastname@example.org.
SWP accounts require a username and password to log in. Clients must keep their username and password secure, and never disclose it to a third party. Because the information in a client’s SWP account is so sensitive, account passwords are hashed, which means we cannot see a client’s password. We cannot resend forgotten passwords either. We will only provide clients with instructions on how to reset them.
We operate in the Cayman Islands
Our office is located in the Cayman Islands so your information may be transferred to, stored, or processed in the Cayman Islands.
Retention of Data
We retain personal information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:
- Whether we have a legal or contractual need to retain the data.
- Whether the data is necessary to provide our services.
- Whether our clients have the ability to access and delete the data within their SWP accounts.
- Whether our clients would reasonably expect that we would retain the data until they remove it or until their SWP accounts are closed or terminated.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Changes to this Policy
Questions & Concerns
If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please send us a message to email@example.com. You may also contact us by postal mail at:
Strategic Wealth Preservation Ltd.,
ATTN. General Manager
P.O. Box 10055, George Town, KY1-1001
Other Important Information
To learn more about the Cayman Islands’ Data Protection Laws (DPL), please visit: https://ombudsman.ky/data-protection
To learn more about the General Data Protection Regulation (GDPR), please visit: https://gdpr-info.eu/