In this Policy, we use the terms “we”, “us”, and “our” (and other similar terms) to refer to Open Trustees (SRA reference: 80586) as owner of this website and who will be the data controller as prescribed in the entity’s local law (the “Data Controller”).
“OC Member Firm” to refer to any entity, including Osborne Clarke Verein, which is a member of international Osborne Clarke network (“Network Firm”) or which is a member firm of Osborne Clarke Verein, a Swiss Verein (“Osborne Clarke Verein Member Firm”).
“Network Firm” includes Osborne Clarke Services (company number: 3049484), Osborne Clarke Trustees Limited (SRA reference: 199769), Open Trustees Limited (SRA reference: 80586), Oval Nominees Limited (company number: 1865795), Ovalsec Limited (company number: 1379423) and Osborne Clarke International Services Ltd (company number: 8096377) – the registered office of each of the above companies is 2 Temple Back East, Temple Quay, Bristol, BS1 6EG.
“Osborne Clarke Verein Member Firm” includes (but is not limited to) those listed here. Each of the Osborne Clarke Verein Member Firm is a separately constituted and regulated legal entity or partnership which provides legal and other client services in accordance with the laws of the jurisdictions in which it operates. For the avoidance of doubt Osborne Clarke Verein is a Swiss verein which does not itself provide legal or other client services.
“Personal information” shall mean any information relating to an identified or identifiable natural person.
“Identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors.
“You” and “your” (and other similar terms) to refer website visitors.
You are entitled at any time to obtain confirmation of the existence of your Personal and Confidential Information and to be informed of the contents and origin, verify its accuracy, or else request that such data be supplemented, updated or rectified according to the provisions of local law.
You also have the right to request erasure, anonymisation or blocking of any data that is processed in breach of the law as well as to object in all cases, on legitimate grounds, to processing of the data.
You also have a right free of charge to object on legitimate ground to the processing of your Personal and Confidential Information and to object to the processing of your Personal and Confidential Information for marketing purpose.
To exercise such rights and if you have any questions about how we collect, store and use Personal and Confidential Information, then please contact us using the details provided below:
Write to us:
E-mail us at: firstname.lastname@example.org
We may collect, store and use the following Personal and Confidential Information in respect of website visitors:
We collect your Personal and Confidential Information through various means, including via our website, through e-mail correspondence, through direct contact (for example at marketing events and pension industry events).
The provision of your Personal and Confidential Information to us is optional – save for the case in which the law requires that this is provided (e.g. to enable us to comply with anti-money laundering regulation) in which case the provision of such data is mandatory and failure to provide the same may result in our inability to provide you with the services requested and subject you to administrative fines.
We use the Personal Information that we collect for the following purposes:
The processing operations connected with your Personal Information are only handled by authorised subjects or by persons appointed for the maintenance of the website.
We may pass your Personal and Confidential Information to third parties such as:
OC Member firms: Subject to compliance with local law, we also share your Personal and Confidential Information with OC Member Firms:
Disclosures required by law or regulation: In certain circumstances, please note that we may be required to disclose Personal and Confidential Information under applicable law or regulation, including to law enforcement agencies or in connection with proposed or actual legal proceedings.
As described above, from time to time, we may need to transfer your Personal Information to other OC Member Firms, who may have offices that are located in territories outside of the European Economic Area (“EEA”), including in the USA in order to provide you with the services required.
Please note that the legal regimes of some territories outside of the EEA do not always offer the same standard of data protection as those inside the EEA, although we will ensure that your Personal Information is only ever treated in accordance with this Policy and, if you are a client, our Engagement Letter.
Where necessary we have entered into standard European Commission approved form model data protection clauses with other OC Member Firms who have offices that are located in territories outside of the EEA, to provide you with the service required and with our external service providers and business partners in relation to services that they may provide that involve processing data from locations outside of the EEA for which we are Data Controller. If you would like to discuss any aspect of our arrangements with external service providers please contact the person responsible for your work.
If you or others on your behalf give us any Personal Information about another person, you take full responsibility for complying with any relevant data protection laws which apply to the provision of that information to us, and our use of it as explained in this Policy.
Personal Information may be processed by either automated or manual methods.
We have in place appropriate technical and organisational security measures to protect your Personal Information against unauthorised or unlawful use, and against accidental loss, damage or destruction.
We put in place strict confidentiality agreements (including data protection obligations) with our third party service providers.
In addition, the coding language the Open Trustees website is written in uses session cookies. These are deleted each time you close your browser. These cookies do not store any information about the visitor once the browser is closed. For more information about cookies, we recommend that you visit www.allaboutcookies.org
You were given the opportunity to consent to our using cookies as you entered our site (to get this far, you have already either consented or opted out of their use). If you have opted out, we only store one permanent ‘compliance’ cookie which tells us that you want to opt out of use of any other cookies.
The cookies that we use on the site are:
“_ga” is a Google Analytics cookie – It’s used to collect information about how visitors use the site. The information is collected anonymously, and used to report on the number of visitors to the site, where they have come from, and the pages they have visited. You can find out more info on Universal Analytics here.
“is_returning” – This cookie is used to anonymously visually interpret user behaviour on the site by building “Heat Maps”. This provides a graphical representation of where visitors click page links. You can find out more info on this cookie here.
“nmstat” is a siteimprove.com cookie – This cookie help record the visitor’s use of the website. This information is then used to improve the user experience on the website. This Siteimprove Analytics cookie contains a randomly generated ID used to recognise the browser when a visitor reads a page. The cookie contains no personal information and is used only for web analytics. You can find out more info on siteimprove.com cookies here.
ASPXAUTH – This cookie is used to make sure that your web experience, whilst on our site, is seamless as you move from page to page.
ASP.NET_SessionId – This cookie is installed automatically when a user connects to an ASP.NET application, and expires when the browser window closes. This provides a mechanism for persisting information between page requests in ASP.NET. You can find out more info on this cookie here and here.
“site-font-size” – This cookie remembers the font size selection for the session.
“site-css” – This cookie remembers the colour scheme for the session.
This Policy was last updated on 1 November 2015. Please note that for legal, business or operational reasons we may from time to time update this Policy. We will highlight any material changes that we make to this Policy on the Open Trustees website.
The Open Trustees website may link to other, unaffiliated third party websites. Please note that Open Trustees is not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third party websites. You must always carefully review the privacy and confidentiality policy of any third party website that you may visit in order to understand how the operators of that website may collect, store and use your personal and confidential information.
(Reviewed November 2015)