We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

Personal data, or personal information, means any information relating to an identified or identifiable individual. It does not include data where no natural person can be identified from the data.

There are "special categories" of personal data which require a higher level of protection (Special Category Data).

We may collect, store, and use the following categories of personal information about you

• Personal Details:
  • Full name
  • Title
  • Resident address
  • Telephone, fax, email
  • Occupation and employer
  • Resume

We may also collect, store and use the following Special Category Data:

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
• Information about your health, including any medical condition, health and sickness records.
• Genetic information and biometric data.
• Information about criminal convictions and offences.

We collect your personal information when you contact us by telephone, in writing, by email or by entering your details in the fields requested on, or any documents linked to or downloaded from, our website, or any other forms provided to you. We will collect the data to enable us to deal with your enquiry or provide you with the relevant services. If you telephone us we may record the conversation for training, customer service and quality of service purposes. If we intend to record your call you will be informed before the call commences so you are able to hang up. When you write to or email us, we may store and use the information you provide within that letter or email together with your postal address and email address and any enclosures or attachments you may have included.

We also use cookies and collect IP addresses (an IP address is a number that can uniquely identify a specific computer or other network device on the internet). We use analysis software to look at IP addresses and cookies for the purpose of enhancing your user experience. This data is not used to develop a personal profile of you and the log files are regularly purged. Cookies may be used to customise your experience, record how many times our site is visited and the pages accessed. You can disallow cookies at any time by amending your web browser settings. If you decline them, some features of our site may not work as well or you may not be able to access or use some features or services. Please note, it is not our intention to use cookies to retrieve information that is unrelated to our site or your interaction with it.

We may sometimes collect additional information from third parties including clients, client advisers, credit reference agencies or public open sources.

We may collect additional personal information in the course of service-related activities throughout the period of dealing with you.

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else's interests).
2. Where it is needed in the public interest.

Normally the purposes for which we use your personal information will be made clear at the point we collect that information. We will not use your personal information for purposes that are not clear when it is collected. We may also use the personal information you provide for direct marketing purposes provided you consented for us to do so by opting-in at the point the information was collected. You are able to withdraw consent at any time.

We may also use the information we gather to:

• enhance or improve Blue Horizon Advisors Limited and our website
• for security purposes i.e. confirm your identity
• develop and provide products and services, either on our own or with third parties
• to provide anonymised statistical data on our overall performance

We need all the categories of information in the list above (see 'The kind of information we hold about you' on page 1, above) primarily to allow us to perform contracts with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below

• Where you are a party related to an entity with which we are contracting
• Business management and planning, including accounting and auditing
• Making arrangements for the termination of our commercial relationship
• Education, training and development requirements
• Dealing with legal disputes involving you
• To prevent fraud
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution
• To conduct data analytics studies to review

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

What was referred to as sensitive personal data under the previous data protection law is now referred to as Special Category Data. Special Category Data requires higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.
2. Where we need to carry out our legal obligations and in line with our data protection policy.
3. Where it is needed in the public interest, such as for equal opportunities monitoring, and in line with our data protection policy.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

Do we need your consent

In limited circumstances we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us, but declining consent may affect what services we can offer you.

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

Due to the nature of the work Blue Horizon Advisors Limited undertakes, we do not envisage that we will hold information about criminal convictions.

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any Special Category Data, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

We may have to share your data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information to an unauthorised jurisdiction which is a jurisdiction which is not (a) the Bailiwick, (b) a Member State of the European Union, (c) any country, any sector within a country, or any international organisation that the Commission has determined ensures an adequate level of protection within the meaning of Article 45(2) of the GDPR (or the equivalent article of the former Directive), and for which the determination is still in force, or (d) a designated jurisdiction which is (i) the United Kingdom, (ii) a country within the United Kingdom, (iii) any other country within the British Islands, or (iv) any sector within a country mentioned in (i), (ii) or (iii) (Unauthorised Jurisdictions).

If we do, you can expect a similar degree of protection in respect of your personal information

We will not share or sell your personal data with anyone outside of Blue Horizon Advisors Limited except as set out below:

• we made it clear to you we may do so when you provided the information
• to third parties we are have contracted or are contracted by to provide the products and services you have requested
• to credit reference and debt collection agencies
• to our auditors or legal advisors
• we are legally required to do so
• our regulatory obligations
• with relevant third parties in the event of Blue Horizon Advisors Limited's sale, merger, consolidation, change in control, reorganisation, liquidation or administration

"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. Certain activities are carried out by third-party service providers (for example, IT services).

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

We will transfer the personal information we collect about you to countries which are authorised jurisdictions other than Member States of the European Union in order to perform our contract with you. There an adequacy decision in force in respect of the country or the authorised jurisdiction is a designated jurisdiction which is (i) the United Kingdom, (ii) a country within the United Kingdom, (iii) any other country within the British Islands, or (iv) any sector within a country mentioned in (i), (ii) or (iii).

We may transfer the personal information we collect about you to countries which are Unauthorised Jurisdictions. If we do so, in order to ensure that your personal information does receive an adequate level of protection we will put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects Guernsey laws on data protection. If you require further information about you can request it from the data privacy representative.

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

How long will we use your information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available on request from the data privacy representative. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a Contact of the company we will retain and securely destroy your personal information in accordance with our data retention policy and/or applicable laws and regulations.

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Under certain circumstances, by law you have the:

• Right to data portability: right to request the transfer of your personal information to another party.
• Right of access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Right to object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes or if data were being processed on grounds of public interest or for historical or scientific purposes.
• Right to rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Right to erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Right to restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Right to be notified of rectification, erasure and restrictions; and
• Right not to be subject to decisions based on automated processing.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our data protection officer in writing.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our data protection officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you have any questions about this privacy notice or how we handle your personal information, please contact our data privacy representative. You have the right to make a complaint at any time to the Authority established pursuant to the Guernsey Data Protection Law and to appeal any decisions.

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. This privacy notice was last updated on 25 May 2018.

If you have any questions about this privacy notice, please contact our data privacy representative as follows: