Privacy Policy
This privacy notice explains how Altrium Financial Services Limited, located at C/O XEINADIN SOUTH EAST LTD 8TH FLOOR BECKETT HOUSE, 36 OLD JEWRY LONDON, ENGLAND EC2R 8DD (referred to as “we,” “our,” or “us” in this notice), collects and uses your personal information. We are dedicated to transparency and safeguarding your data. Accordingly, this notice details how we store and protect your information, the parties we may share it with, and the duration for which we retain it. Additionally, it outlines your rights and the steps you can take if you have concerns about how Altrium manages your personal data. If we request information that identifies you while using this website, rest assured it will be handled in accordance with this privacy notice.
Altrium serves as the data controller responsible for processing client information. Our Data Protection Officer, who ensures Altrium and its employees comply with GDPR and acts as the primary point of contact for individuals regarding the processing of their data, can be reached at contact@altrium.co.uk.
In this notice, references to “your information” refer to the personal data you provide to us or that is provided on your behalf.
How we collect your personal data:
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Directly from you,
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From third parties (such as a solicitor, beneficiary, or others involved in delivering your services).
What type of personal data may be collected by Altrium?
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Full Name
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Photo Identification
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Personal & Business Email Addresses
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Phone Number
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Nationality
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Date of Birth
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Passport Number
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Address Proof
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Bank Account information, including Sort Code and Account Number
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Tax or National Insurance Number
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Name(s) of the Executor
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Name(s) of the Beneficiary
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Employment Contract (if we are acting as Facility Agent)
How we use your personal data and the legal grounds for processing it
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Personal business email address: We require this information to contact you regarding transactions or agreements. The lawful basis for processing this personal data is in our legitimate interests.
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Photo ID: We use photo identification to verify the identity of potential clients, in accordance with our ‘Know Your Customer’ (KYC) procedures and to comply with legal requirements for Anti-Money Laundering and Counter-Terrorist Financing obligations.
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Address Proof: We use address proof to confirm the identity of potential clients, in line with our KYC procedures and to meet legal obligations for Anti-Money Laundering and Counter-Terrorist Financing compliance.
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Name, Email Address and Phone Number: We use this information to contact you about our services and for operational or business purposes. The lawful basis for processing this information is in our legitimate interests.
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Bank Account Information: We require bank account details to process interest payments or distribute trust or escrow funds (if applicable). The lawful basis for processing this data is the contract with the individual and our legitimate interests.
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Tax number or National Insurance Number: We need a client’s tax or National Insurance number to verify their identity, in line with our KYC procedures and to comply with legal requirements.
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Original sealed Grant of Probate (which may include the names of the executor and/or beneficiary): This data is necessary to maintain the register, for example, to update it. It is also required to make payments if the beneficiary is deceased. The lawful basis for processing this data is in our legitimate interests.
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Employment Contract: This data may be provided under our agreement as a Facility Agent to verify the employment status of an individual. We are legally obligated to process this information.
Who we share your personal data with
If the personal data you provide to our transaction managers is for KYC purposes, it will be securely sent to our compliance team for processing. Additionally, this data will be shared with our third-party Customer Relationship Management (CRM) system.
Your information may be disclosed if we believe, in good faith, that such disclosure is:
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Required by law;
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Necessary to protect the safety of our employees, the public, or Altrium property;
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Needed to comply with a judicial proceeding, court order, or legal process; or
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For the prevention or detection of crime, including fraud.
Storage, Security and Transfers
Altrium is committed to ensuring the security and protection of your personal data. We have implemented both technical and organisational measures to safeguard your data from external and internal threats, ensuring that access to personal data is limited to those who need to process it. To prevent unauthorized access or disclosure, we have established appropriate physical, electronic, and managerial procedures to protect the information we collect online. Additionally, Altrium has put in place backup and recovery protocols to address the rare possibility of your personal data being lost or accidentally destroyed. After processing, your personal data will be securely stored in a private portal on Microsoft Office 365, with access restricted to authorized individuals.
Your name and business email address will be stored in our third-party CRM system, which restricts access to individuals with a legitimate business need to view this information.
Altrium may transfer your personal data outside the European Economic Area (EEA), including to the UK from outside the EEA. In such cases, we will ensure that appropriate safeguards are in place to protect your personal data and maintain the same level of protection as it would receive in the UK.
Email Marketing
We rely on the following legal grounds to send email marketing:
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Where it is in our legitimate interest to do so
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With your consent
By “legitimate interests,” we mean that we have a valid business reason for using this data, and it does not unfairly conflict with your rights or interests.
If you have shared your business card with us, we will add you to our marketing list. We would like to keep you informed about Altrium, including updates on products and services you may find interesting, briefings, and invitations to our events. You can unsubscribe at any time.
If you have consented to receive our marketing emails through our website, we may use your personal business email address to send you the information mentioned above. You can unsubscribe at any time by clicking the ‘unsubscribe’ link at the bottom of any email we send or by clicking here.
How long does Altrium retain your data?
The personal data mentioned above will be retained for as long as we have a legitimate business need and will be kept in accordance with legal and regulatory requirements or guidance. Our Anti-Money Laundering (AML) Policy specifies that to comply with our Customer Due Diligence procedures, identification records will be retained for 5 years after the account is closed or a transaction is completed. During these 5 years, your personal data will be securely archived in Microsoft Office 365 SharePoint.
After this period, we will securely delete your personal data and take necessary measures to ensure it is permanently erased and cannot be recovered.
In certain cases, records may need to be stored for more than five years. If Altrium continues to have a relationship with an individual, either directly or through a corporate structure, we will retain the data and update it as needed.
How we use cookies
Cookies are text files stored on your computer to gather standard internet log data and information about visitor behaviour. This information helps track website usage and generate statistical reports on website activity.
For further information visit www.aboutcookies.org or www.allaboutcookies.org
You can configure your browser to refuse cookies, and the websites mentioned above provide instructions on how to remove cookies from your browser. However, please note that in some cases, certain features of our website may not work properly as a result.
Links to other websites
Our website may include links to other websites that may be of interest. This privacy notice applies solely to our website, so when you visit other websites, we recommend reviewing their respective privacy policies.
Controlling your personal information
We will not sell, distribute, or lease your personal information to third parties unless we have your consent or are legally required to do so.
Access to your information and correction
Under the new regulations, you have the right to request a copy of the personal data we hold about you. This is known as a Subject Access Request (SAR), and all requests must be made in writing to the Data Protection Officer. We will provide the requested information within one month of receiving your request. If the request is deemed manifestly unfounded or excessive, Altrium may extend this period by an additional two months. In such cases, you will be notified and explained the extension.
If you believe that any of the information, we hold about you is inaccurate or incomplete, please contact us in writing or by email as soon as possible. We will correct any inaccuracies promptly.
Your rights
The new regulations grant individuals additional rights concerning their personal data. There are specific circumstances in which these rights apply, and if you wish to exercise any of the following, we can inform you whether they are applicable to your situation.
Your rights include:
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The right to be informed about how your data is processed, collected, and used.
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The right to correct your data if it is inaccurate or incomplete.
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The right to request the deletion of your personal data (the ‘right to be forgotten’).
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The right to restrict the processing of your personal data
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The right to data portability, allowing you to move, copy, or transfer your personal information.
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The right to object to the processing of your personal data
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Rights related to automated decision-making and profiling that have legal consequences or could significantly affect you.
If the processing of your personal data is based on your consent, you have the right to withdraw it at any time. To do so, please contact the Data Protection Officer.
If you have concerns about how Altrium is handling your personal data, please reach out to our Data Protection Officer initially.
Altrium may update this Privacy Notice periodically. We recommend checking it regularly for any updates.