This Privacy Notice explains how Antelope Group collects, uses, shares or otherwise processes personal information that you provide to us, or that we may otherwise obtain or generate, which relates to you. Please take a moment to review this Privacy Notice and, if you have any questions, feel free to get in touch via one of the methods set out under the header “Contact Information” below.
If this Privacy Notice is updated or modified in any way you shall be duly notified and provided with the updated version.
1. What personal information do we collect, and where do we obtain it from?
The personal information that we collect about you may include:
- The personal data that We collect for the fulfilment of our client engagement procedure including all personal data in our Client Set-up Form, Engagement Letter and Due Diligence Questionnaire and any documents or information which you may be required to supply to Us for such purposes;
- Personal data that We may process as a result of legal obligations imposed on Us;
- Your identity details such as your name, surname, employer, title, position, and status;
- Your contact information such as your name, parentage, email address, physical address and telephone numbers;
- where applicable, a copy of a personal identification document, such as your ID card or passport, documents providing proof of residence, birth/marriage certificates;
- Your bank account details and other financial information;
- Personal data provided to us by, on behalf of or in relation to our clients, business partners, service providers and employees;
- Any personal data lawfully generated by us in the course of executing our client’s instructions;
- Outdoor CCTV footage, when you visit Our offices; and
- Any personal data which you may voluntarily provide to Us.
- Other documents as may be necessary for us to comply with our legal obligations, such as documents required for proof of identity and/or residence, source of wealth and source of funds.
We gather and generate information about you when you provide it to us or interact with us directly. We may also receive professional information about you from other sources, including but not limited to publicly available sources. We may combine information that we have about you from various sources, including the information that you have provided to us.
2. Use of your personal information
We may use your personal information:
- As part of Our client engagement procedures;
- When you or your company requests services from Antelope Group;
- Complying with Our legal obligations, in particular Our legal obligations with respect to anti-money laundering and combating the funding of terrorism;
- Conflict check purposes;
- Managing our relationship with you or your company, including for billing and debt collection purposes;
- When you or your company provides services to Antelope Group or refers clients to us;
- Provide you with professional services in terms of the letter of appointment through any of our three entities, Antelope Trustees Limited, Antelope Services Limited and Antelope Legal.
- Answer your questions and requests for services;
- Send important notices or communications, such as changes in laws and regulation that may affect you or changes to our terms, conditions and policies;
- For internal purposes such as billing, auditing and research, and to maintain our client database; and
- To ensure we have up‐to‐date contact information for you.
We may also be required to process your personal data for the purpose of:
- Compliance with applicable laws, rules, regulations, guidance and codes;
- Compliance with demands or requests made by local and foreign regulators, governments, courts and law enforcement authorities, and complying with a judicial process or arbitral procedure, or in connection with any dispute or litigation, subject to our obligations of professional secrecy as may be applicable in the particular circumstances where such data is requested;
3. On what basis do we use your personal information?
- With your consent: We will at times ask for your specific consent to process your personal information.
- For the performance of a contract: If you engage us to provide you with professional services, we will process your data insofar as it is necessary for the performance of our contracted services.
- For compliance with a legal obligation: We may at times be legally obliged to process your personal information in order to comply with demands or requests made by local and foreign regulators, governments, courts and law enforcement authorities, or with a court process, or in connection with any litigation, or in order to comply with our legal obligations.
- For legitimate business purposes: We may at times use your personal information for our legitimate business purposes. Where we use your personal information for this purpose, rest assured that we will take measures to protect your personal information.
In the interest of transparency, note that we use systems which could profile you. Such systems are used by us exclusively to help us comply with legal obligations imposed on us as a result of anti-money laundering and combating the funding of terrorism legislation. However, no automated-decision will result from said use of such systems.
4. Recipients and Sharing of your personal information
Your personal information will be received by Antelope Group partners, consultants and employees.
We may also share your personal information with any of the following:
- Our professional advisors, accountants, IT service providers, and auditors strictly as required for consultation purposes or for compliance with our legal obligations or in the course of the provision of our services;
- Regulators, governments and law enforcement authorities as and when this is required under applicable laws and regulations; and
- Courts, tribunals, arbitrators or other competent bodies who may have authority to request such personal information or to whom disclosure is necessary for the purpose of providing our professional services.
- Other parties involved in any matter or dispute in which you are a party and for which we have been engaged to advise or assist, strictly as is necessary to provide the services required.
- Services providers who may have access to our data for IT purposes.
5. Transfers outside the European Union
We may transfer your personal information outside of Malta. The countries to which your personal information is transferred may not offer an equivalent level of protection for personal information to the laws of Malta. Where appropriate, we will take steps to ensure your information is transferred subject to appropriate safeguards, such as by entering into data transfer agreements. Where we have put data transfer agreements or similar safeguards in place, we may be able to make a copy of this available to you if you contact us via one of the methods set out under the header “Contact Information” below.
6. How long will we keep your personal information?
We have a data retention policy that sets out how long we keep your information. This policy is based on the type of information, the purpose of collection, and the system within our digital platforms in which the information is held.
As a result of legal obligations imposed on Antelope Group, we typically retain your personal data for up to ten (10) years from the closure of your file and you cease to be our client, unless we have a statutory obligation imposed on us to retain your data for a further period or a business need or require your personal data to exercise or defend legal claims.
Thereafter all data and files are destroyed.
7. Security of Data
We use a variety of security technologies and procedures to help protect your personal information from unauthorised access, use or disclosure. Our suppliers are carefully selected and required to use appropriate measures to protect the confidentiality and security of your information.
8. Keeping your Data secure
We shall keep your personal data secure and shall commit to take appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, including against accidental loss, destruction, storage or access. Your personal data may be stored in paper files or electronically on our technology systems or on technology systems of our IT service providers.
9. Your Rights
You have the right to:
- Withdraw your consent when your personal data is processed on the basis of your consent. The withdrawal of your consent shall not affect the lawfulness of processing before the withdrawal of your consent. Where the processing of data is necessary to provide you with contracted services, withdrawal of consent would render Antelope Group unable to provide the contracted services, provided that Antelope Group may have the right to process your personal information if it has another lawful basis for doing so, as outlined in this policy.
- Ask Antelope Group about the processing of your personal information, including to be provided with a copy of your personal information held by Antelope group;
- To request the correction and/or deletion of your personal information, or restrict or object to the processing of your personal information;
- To request to obtain and reuse your personal information for your own purposes across different services; and
- To complain to a competent supervisory authority, or to a court of law, if your data protection rights are violated or if you have suffered as a result of unlawful processing of your personal information.
If you would like access to the information that we hold about you, if any of the information that we hold about you is inaccurate or out of date, or if you wish to withdraw your consent or restrict or object to us processing it, please let us know by getting in touch via one of the methods set out under the header “Contact Information“ below.
If you object to our processing of your personal information, we will respect such requests in accordance with our legal obligations. Your objection may mean that we may not be able to perform the actions necessary to achieve the purposes set out above.
Antelope Group may be required or entitled to retain your information to comply with legal and regulatory obligations and to protect and exercise our legal rights and legitimate interests.
In addition to those rights outlined above you also have an unconditional right to object at any time to the processing of your personal information for direct marketing purposes by contacting us via one of the methods set out under the header “Contact Information” below.
11. Contact Us
Antelope is the controller of your personal information. The contact person for data protection related matters is Dr. Diane Vella Bianco Bonaci.
Should you have any questions, comments and requests regarding this Privacy Notice you may contact us through any of the following methods:
By phone: +356 21 335357
By e‐mail: firstname.lastname@example.org
By mail: Antelope Group, 37, Sir Michelangelo Refalo Avenue, Balzan BZN 1601, Malta