Data Privacy Notice
This Privacy Notice explains how we (Horsepool Group) collect, use, disclose, and protect your personal data in compliance with the Data Protection (Bailiwick of Guernsey) Law, 2017 (the Data Protection Law).
Who We Are
Horsepool Group is a compliance consultancy and corporate services provider based in Guernsey. We act as a Data Controller for personal data we process directly and as a Data Processor when handling data on behalf of our clients.
For any queries about this Privacy Notice or your personal data, please contact us at:
c/o James Rouse
Horsepool Group
First Floor, Warwick House
La Grange
St Peter Port
Guernsey
GY1 2PX
Email: jim@horsepool.gg
Phone: +44 (0) 1481 740 458
What Personal Data We Collect
We may collect the following types of personal data:
- Identification Data, such as name, date of birth, national identification numbers, and passport details.
- Contact details, such as address, email address, and phone number.
- Financial information, such as bank account details, payment information, source of wealth and funds.
- Professional data, such as job title, employer details, and professional affiliations.
- Compliance data, being information required for the purposes of the prevention of financial crime and as provided for under relevant laws and regulations.
How We Collect Your Data
We collect personal data through:
- Direct interactions, such as when you contact us, provide documentation, or use our services.
- Third-party sources, such as regulators, public registers, or your authorised representatives.
How We Use Your Data
We process your personal data for the following purposes:
- To deliver our consultancy and corporate services.
- To meet legal and regulatory requirements, including financial crime prevention obligations.
- To manage client relationships and respond to enquiries.
- To ensure the integrity and security of our systems and operations.
The legal basis for processing your data may include, but is not necssarily limited to:
- Performance of a contract.
- Compliance with legal obligations.
- Legitimate interests, where these are not overridden by your rights.
- Your consent, where applicable.
Data Sharing
We may share your personal data with:
- Regulators and law enforcement agencies, as required by law.
- Professional advisors, such as auditors, lawyers, or insurers.
- Third-party service providers, who assist in delivering our services under strict confidentiality agreements.
- Other parties, where necessary for the performance of our services or with your explicit consent.
International Data Transfers
We may transfer your personal data outside of Guernsey, the UK, or the EEA. Such transfers will only occur:
- To jurisdictions with an adequacy decision from the European Commission.
- With appropriate safeguards in place, such as standard contractual clauses.
How We Protect Your Data
We implement technical and organisational measures to safeguard your personal data, including encryption, access controls, and periodic security assessments. Retention of Data
We retain personal data only as long as necessary for the purposes outlined in this notice or as required by law. For example, data may be retained for at least five years after the end of a business relationship, as mandated by financial crime prevention regulations. Your Data Protection Rights
You have the following rights under the Data Protection Law:
- Right to Access - Request a copy of your personal data.
- Right to Rectification - Correct inaccurate or incomplete data.
- Right of Erasure - Request deletion of your data, where applicable.
- Right of Restriction - Limit how your data is processed.
- Right of Data Portability - Receive your data in a structured, machine-readable format.
- Right of Objection - Object to processing based on legitimate interests.
- Right of Withdrawal of Consent - Withdraw consent where processing is based on it.
- Right to make a Complaint - Lodge a complaint the Office of the Data Protection Authority in Guernsey (ODPA) if you believe your rights have been violated.
Before making a complaint, you should first discuss your concern with Horsepool Group, or thereafter if you still wish to make a complaint, you can do so by visiting the ODPA website and submitting a complaint - https://www.odpa.gg/for-individuals/make-a-complaint