Privacy Notice

Abacus plc and its subsidiaries that form Abacus Trust Group respect your privacy and are committed to protecting your personal data. This privacy policy explains how we collect and use personal data when you visit our website (regardless of where you visit it from), contact us directly, or engage us to provide a service. The privacy policy  also informs you of your privacy rights and how the law protects you. We keep this notice under review to ensure that it is accurate and up to date and we will place any updates on our intranet.

The IOM Data Protection Law 2018 and the UK General Data Protection Regulation (UK GDPR) apply to relevant Abacus Group companies. Personal data is information that relates to an identified or identifiable living individual, and it is possible to identify an individual directly or indirectly from the information.

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1. Purpose of this privacy policy
This privacy policy explains how we collect and process your personal data and how we apply the data protection principles. It is important that you notify us of any changes to your personal information so that we can ensure that the information we hold on you is accurate and up to date.

It is important you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

1.2. Controller
Abacus Trust Group is made up of different legal entities. This privacy policy is issued on behalf of the Abacus Trust Group’s constituent legal entities so when we mention “Abacus Trust Group”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in Abacus Trust Group responsible for processing your data.

Abacus Trust Company Limited is the controller and responsible for the website.

We will process your personal data in a lawful, fair and transparent manner.

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise, please contact the DPO using the details set out below.

Contact details:
Email address: datacontroller@abacustrustgroup.com
Postal address: Data Controller, Abacus, Sixty Circular Road, Douglas, Isle of Man, IM1 1AE.

1.3. Third-party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

2.1. Personal data
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Personal Identity data including, but not limited to, name, title, date and place of birth, and gender
• Photographic Identification
• Contact data including, but not limited to, residential address, email address, telephone and mobile numbers
• Financial Information including, but not limited to, income, bank account details, tax details, and wealth information.
• Special Category Data only collected upon your explicit consent and may consist of physical or mental health details, details of race, ethnicity, political opinions, religious or philosophical beliefs, sexual orientation.

We only process criminal offense data to the extent permitted and required by law.

2.2. If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a service). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED AND WHY WE HAVE IT?

We collect most of the personal data that we process directly from you by filling in forms or by corresponding with us by email, or otherwise, for the following purposes:

• To provide a service and administer the client relationship
• Where we need to perform a contract entered into with you or about to enter into
• Where we need to comply with legal and regulatory obligations including, but not limited to, employment, tax, national insurance, and financial services regulation where applicable
• 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
• To inform you about our services and news that you have subscribed to, or send marketing that you have requested
• For specific purposes where you have provided consent (and you can withdraw your consent at any time).

We may also receive your information indirectly from the following sources for the purposes set out below:

• LSEG World Check for the purposes of ongoing sanction screening checks
• Internet searches to research information or adverse media reports.

3.1. Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please ask the DPO.

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

3.2. Automated technologies or interactions
As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please refer to our Cookie Policy for further information.

We do not use automated decision-making systems, or any profiling to process your personal information.

4. OUR LAWFUL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

The lawful basis that we rely on for processing your personal information are:

• Contractual obligation (to fulfil our contractual obligations with you)
• Legal obligation (to fulfil our legal and regulatory obligations)
• We have a legitimate interest
• For your own legitimate interest
• Consent obtained from you.

In respect to “special category data” (for example, religious belief, political affiliations, or health information) this will be only processed where necessary under legal claims, if the data has been made public by you, and/or your explicit consent.  Special category data will be held and controlled in accordance with conditions set out in data protection legislation.

5. TRANSFERRING AND SHARING YOUR PERSONAL

We may share your personal data with internal and external parties as detailed below.

Within the Abacus Trust Group’s constituent companies, where each of these companies are in countries with equivalent standards of data protection requirements.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or assets.

Additionally, we may share your personal data with professional service providers to conduct identification and monitoring checks, as part of Know Your Customer requirements, or where necessary to carry out services provided to you.

We will not share with anyone else unless we are required to do so by law.

If we are required to transfer your personal data outside the UK, Isle of Man, European Union, or the European Economic Area, we will ensure an equivalent degree of protection is afforded to it.

6. COOKIES POLICY

Our online cookies policy (here) explains how we collect and process your personal data when you visit our website.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

7. DATA SECURITY

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

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

8. DATA RETENTION

8.1. How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We keep your personal data for a period of 6 years following the end of the business relationship unless we are required to keep it for longer under law.

Any data we process under your consent is deleted immediately on withdrawal of your consent.

9. YOUR LEGAL RIGHTS

Under data protection law you have a number of rights in relation to your own personal data that we process, including:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent.

Some rights only apply under certain circumstances - if you wish to exercise any of the rights set out above, please contact the DPO.

9.1. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.2. Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. COMPLAINTS/APPEALS

Abacus welcomes complaints and positive feedback, both of which provide information which helps us to improve our services.

If you have a question, complaint, or concern about our privacy policy, the way in which Abacus processes your personal or sensitive data, you can contact our DPO as detailed above.

You can also complain with a supervisory authority. Should you wish to report a complaint or if you feel that Abacus has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.

11. UPDATES ON THIS PRIVACY POLICY

We reserve the right to make changes to this Privacy Policy, for example government regulation, new technologies, developments in data protection laws or privacy generally, or how we treat (process and control) your personal data. You should check the Privacy Policy on our website from time to time to view the most up to date version. This will available at all times and published here:

Privacy Policy | Abacus

This Privacy Policy was last updated on 15 July 2026.