Terms & Conditions
This Privacy Notice sets out how Saltgate deals with your personal data which we collect in the course of you, and people and entities connected with you, interacting with Saltgate entities. We take privacy and security of your information seriously and will only use such personal information as set out in this Privacy Notice and in ways which are reasonably ancillary to what is set out below.
References to Saltgate, "We", "us" are to any or all of Saltgate Limited, Saltgate Services Limited, SJT Limited, Saltgate S.A. and Saltgate (UK) Limited together with their affiliates that process your personal data.
References to "you" include all individuals whose personal data we collect, hold and process in the course of carrying out the business of a specialist alternative investment service provider, including as a potential employer.
2. Contact Details
You can contact Saltgate in relation to data protection and your rights by email: firstname.lastname@example.org
Each of Saltgate Limited, Saltgate Services Limited, Saltgate Property Trustees Limited and SJT Limited has appointed Saltgate (UK) Limited as its representative within the European Economic Area (EEA). You can contact Saltgate (UK) Limited by email: email@example.com
4. The personal information we process
4.1 We may collect various types of personal data about you, including:
4.1.1 Your identification information (which may include your name, ID card and passport numbers, nationality, place and date of birth, gender, photograph and/or IP address and personal data relating to claims, court cases and convictions, politically exposed person (PEP) status, personal data available in the public domain and such other information as may be necessary for Saltgate to provide its services and to complete its CDD process and discharge its AML/CFT obligations);
4.1.2 Your tax status information (which may include your tax residency, tax ID, tax status);
4.1.3 Your contact information (which may include postal address and e-mail address and your home and mobile telephone numbers);
4.1.4 Your family relationships (which may include your marital status, the identity of your spouse and the number of children that you have);
4.1.5 Your professional and employment information (which may include your level of education and professional qualifications, your employment, employer’s name and details of directorships and other offices which you may hold);
4.1.6 Financial information, sources of wealth and your assets (which may include details of your assets, sources of wealth, shareholdings and your beneficial interest in assets, your bank details and your credit history); and
4.1.7 Your image (which may include still or moving recordings).
4.2 If you apply for a position with us we may collect personal information relating to your past employment, professional qualifications and education, your nationality and immigration/residential status, opinions from third parties about you (such as references) and other details about you which may be gathered during the recruitment process. We may also review publically available information about you on your social media accounts.
4.3 We may also collect and process personal data regarding people connected to you, either by way of professional (or other) association or by way of family relationship.
5. Where we obtain your personal information:
5.1 We may collect your personal information from the following sources:
5.1.1 personal information which you give to us, including but not limited to:
(a) such other forms and documents as we may request that are completed in relation to the administration/management of any of our services;
(b) information gathered through client due diligence carried out as part of our compliance with regulatory requirements; or
(c) any personal information provided by way of correspondence with us by phone, e-mail or otherwise;
5.1.2 personal information we receive from third party sources, such as:
(a) entities in which you or someone connected to you has an interest;
(b) your legal and/or financial advisors;
(c) other financial institutions who hold and process your personal information; and
(d) credit reference agencies and financial crime databases for the purposes of complying with our legal and regulatory requirements; and
(e) where you apply for a position with us previous employers, educational institutions and professional bodies to which you belong.
5.1.3 personal information collected from publicly available sources;
5.1.4 personal information collected pursuant to CCTV recording at Saltgate premises for the purpose of security; and
5.1.5 personal information received in the course of dealing with advisors, regulators, official authorities and service providers by whom you are employed or engaged or for whom you act.
6. Information collected through our website
You are not required to provide any personal information on the public areas of our website; however, you may choose to do so by completing the form on the ‘Join Us’ page.
In addition to we collect the domain names and IP addresses of visitors, along with usage statistics, analytics and browsing history. This data is used to improve the experience of visitors to our site. Please see our Cookies Statement for more details about this. You may also provide us with personal information if you contact us by email, telephone or letter.
7. Why we collect your personal information:
Lawful grounds for processing:
7.1 We may hold and process your personal information on the following lawful grounds:
7.1.1 the processing is necessary for our legitimate interests, provided your interests and fundamental rights do not override those interests;
7.1.2 the processing is necessary to comply with our contractual duties;
7.1.3 the processing is necessary to comply with our legal and regulatory obligations;
7.1.4 on exceptional occasions, where we have obtained your consent to processing your personal information for a specific purpose; and
7.1.5 on rare occasions, where it is needed in the public interest.
Purposes of processing:
7.2 Pursuant to paragraph 4.1 above, your personal information may be processed for the purposes set out below ("Purposes"). The Purposes based on our legitimate interests are set out in paragraphs 7.2.1 to 7.2.4 inclusive):
7.2.1 facilitating the administration of our business and/or our service providers;
7.2.2 communicating with you as necessary in connection with our services;
7.2.3 monitoring and recording telephone and electronic communications and transactions (subject to local regulations):
(a) for quality, business analysis, training and related purposes in order to improve service delivery; and
(b) for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act);
7.2.4 disclosing your personal information to any bank or financial institution in providing our services;
7.2.5 where you have applied for a position with us, to review and process your application and considering whether to enter into an employment or consultancy contract with you;
7.2.6 to enforce or defend our legal and contractual rights or those of third party service providers;
7.2.7 to comply with a legal or regulatory obligations imposed on us;
7.2.8 collecting, processing, transferring and storing customer due diligence, source of funds information and verification data under applicable anti-money laundering and terrorist financing laws and regulations; and
7.2.9 liaising with or reporting to any regulatory authority (including tax authorities) with whom we are either required to cooperate or report to, or with whom we decide or deem it is appropriate to cooperate in relation to an investment, and which has jurisdiction over the Fund or its investments.
8. Sharing personal information
8.1 We may share your personal information with our group companies and third party service providers, including, banks, financial institutions or other third party lenders, IT service providers, auditors, legal professionals and other professional advisors to facilitate our business and services which we provide. The group companies to whom your information may be transferred are based in the following jurisdictions: Jersey, the UK and Luxembourg.
8.2 Where we share your information with a third party, we require the recipients of that personal information to put in place adequate measures to protect it.
8.3 Where we share your information with a third party not based in the EEA or a country assessed by the European Commission as offering ‘adequate’ levels of protection, such measures of protection may include entry into appropriate data transfer agreements such as the EU standard contractual clauses. If you would like further information about the safeguards we have in place to protect your personal information, please contact firstname.lastname@example.org
9. Retention of personal information
9.1 Your personal information will be retained for as long as required:
9.1.1 for the purposes for which the personal information was collected;
9.1.2 in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations; and/or
9.1.3 as required by data protection laws and any other applicable laws or regulatory requirements.
10. Access to and control of personal information
10.1 You have the following rights in respect of the personal information about you that we process:
10.1.1 the right to access and port personal information;
10.1.2 the right to rectify personal information;
10.1.3 the right to restrict the use of personal information;
10.1.4 the right to request that personal information is erased; and
10.1.5 the right to object to processing of personal information.
10.2 You also have the right to lodge a complaint about the processing of your personal information either with us, with the data protection authority in the relevant Saltgate jurisdiction or the data protection authority in the EU member state of your usual residence or place of work.
10.3 Where we have relied on consent to process your personal information, you have the right to withdraw consent at any time.
10.4 If you wish to exercise any of the rights set out in this paragraph 7, please contact email@example.com
11. Inaccurate or amended information
Please let us know as soon as possible if any of your personal information changes (including your correspondence details) by contacting us at firstname.lastname@example.org. Failure to provide accurate information or to update information when it changes may have a detrimental impact upon our ability to provide our services.
12. Data security
12.1 We will ensure that appropriate measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
12.2 We have in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. We will only transfer personal data to a third party if it agrees to comply with those procedures and policies, or if it puts in place adequate measures itself.
If you have any questions about this Data Protection Notice or how we handle your personal information (e.g. our retention procedures or the security measures we have in place), or if you would like to make a complaint, please contact email@example.com.
14. Policy updates
We may change this policy from time to time by updating this page. You should check this page periodically to ensure that you are satisfied with any changes.
Website Legal Notice
This website contains information about the Saltgate Group (“Saltgate”). The entities below are the main entities within Saltgate. You should read the information below before using this website. This sets out legal and regulatory provisions applicable to the content of this website. By accessing this website, you agree to be bound by the following provisions.
Saltgate Limited is regulated by the Jersey Financial Services Commission in the conduct of AIF services business, fund services business and trust company business. Saltgate Property Trustees Limited, SJ Secretaries Limited, SJT Limited, SJN1 Limited and SJN2 Limited are regulated by the Jersey Financial Services Commission in the conduct of trust company business. Saltgate is the registered business name in Jersey of Saltgate Limited.
Saltgate (UK) Limited is authorised and regulated by the Financial Conduct Authority.
Saltgate S.A. is regulated by the Commission de Surveillance du Secteur Financier.
The registered office and contact details of each of the above companies are:
St Helier | Jersey | JE1 1SG
T + 44 (0) 1534 850 750
Saltgate (UK) Limited
28 Clements Lane
London | United Kingdom | EC4N 7AE
T +44 (0)20 3143 4500
40 Avenue Monterey
L-2163 | Luxembourg
T +352 26 20 511
Disclaimer and Limitation of Liability
The content of this website does not constitute advice and should not be used as such. Saltgate does not warrant the adequacy, accuracy or completeness of any of the information contained within this website.
Saltgate accepts no responsibility or liability whatsoever:
for any loss which may arise from or in connection with the use of this website or the content of any of its pages; and in relation to or in connection with any computer virus or similar defect which may have infected this website. Users of this website must take their own precautions regarding virus protection and security.
Saltgate is not responsible for third-party links provided herein as these are not under its control and have been provided for information purposes only. They do not constitute any recommendation or endorsement of the respective website. Hyperlinks can become out-of-date and cease to work or they can direct users to a website page whose contents or use have been changed by its owner. Saltgate can therefore accept no responsibility or liability whatsoever for any losses or penalties that may be incurred or for the accuracy of hyperlinks to third party websites, or for the content of such third party websites.
Saltgate shall not be responsible for any matter relating to the availability of the internet and, in particular any or all of the following (whether or not illegal or malicious): transmission errors, technical faults, failures, intrusion into network equipment, network overload, blocking of electronic access by third parties, internet malfunctions, and loss of service or other deficiencies on the part of network operators. Saltgate shall not be responsible for any damages caused to users’ own software or hardware as a result of access to the internet or use of service.
Unless otherwise stated the copyright in the content of this website and any downloadable material is owned by Saltgate. Permission is granted for the viewing and printing of any of the contents of this website and downloading of any materials provided that such usage is only for personal use and that any reproduction of such materials clearly shows the Saltgate name and logo and no charge is made for such reproduction. For all other uses of the information on this website prior consent must be sought and obtained from Saltgate.
The information contained in this website shall be governed by and construed in accordance with the laws of the Island of Jersey and by accessing the website, you agree to submit to the non-exclusive jurisdiction of the Island of Jersey in connection therewith and waive the right to object to an action brought in the courts of the Island of Jersey on the basis of an action brought in an inconvenient forum. To the fullest extent permitted by law, you agree and undertake that any action brought against Saltgate in connection with the information set out in this website shall be brought in the Jersey courts.