Legal Disclaimers
Group Eleven (IOM) Limited, registered no 035589C, registered address is 3rd Floor Quay House, South Quay, Douglas, Isle of Man IM1 5AR. The directors of Group Eleven (IOM) Limited are: S L M Preskey, M A Keating, D A Laderman, M Veale, P J McCarrick, J D Kneen, J V Higgins and W Corrin.
Group Eleven (IOM) Limited is licenced by the Isle of Man Financial Services Authority.
Group Eleven Funds Services Limited, registered no 135917C, registered address is 3rd Floor Quay House, South Quay, Douglas, Isle of Man IM1 5AR. The directors of Group Eleven Funds Services Limited are: S L M Preskey, M Veale and P J McCarrick.
Group Eleven Funds Services Limited is licenced by the Isle of Man Financial Services Authority.
Law Trust Solutions Ireland Limited, registered no 515414, registered address is Suite 332, The Capel Building, Mary’s Abbey, Dublin 7, D07 FXF8, Ireland. The directors of Law Trust Solutions Ireland Limited are: M A Keating and M J Hennessy.
Law Trust Solutions Ireland Limited is licenced by Ireland’s Department of Justice.
Entities within the Group include:
- Group Eleven Limited (Registered Company No: 135916C)
- Group Eleven Trustees Limited (Registered Company No: 136485C)
- Group Eleven FS Directors 1 Limited (Registered Company No: 020742V)
- Group Eleven FS Directors 2 Limited (Registered Company No: 020741V)
- Group Eleven FS Nominees 1 Limited (Registered Company No: 020740V)
- Group Eleven FS Nominees 2 Limited (Registered Company No: 020739V)
- Group Eleven FS Secretaries Limited (Registered Company No: 020738V)
- Group Eleven Funds Services Limited (Registered Company No: 135917C)
- Group Eleven (IOM) Limited (Registered Company No: 035589C)
- L.T. Secretaries Limited (Registered Company No: 011302V)
- Corporate Management & Business Services Limited (Registered Company No: 041279C)
- C.M.B.S Nominees Limited (Registered Company No: 041281C)
- PCS Trustee Limited (Registered Company No: 115971C)
- PCS Nominee Limited (Registered Company No: 114434C)
- Dolmen Holdings Limited (Registered Company No: 126637C)
Data Protection Registration Numbers are noted below:
- Group Eleven Funds Services Limited – R003745
- Group Eleven Limited – R003746
- Group Eleven Group Limited – R003747
- Group Eleven (IOM) Limited – R001285
Email Disclaimer
Any email sent by a company within the Group Eleven Group of companies should be read in conjunction with the following disclaimer.
- All emails and attachments are confidential and should not be shared with a third party without the express permission of the sender.
- The content of any emails and attachments may be legally privileged.
- Whilst we do have appropriate safeguards in place, we cannot guarantee that emails sent by Group Eleven are secure or free from viruses or error
- If you are not the intended recipient, please immediately notify the sender and delete the message from your system.
Website Terms
Use of website
The use of this website is subject to the following terms of use:
- The content of the pages of this website is for your general information and use only. It is subject to change without notice.
- Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.
- Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.
- This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.
- All trademarks reproduced in this website, which are not the property of, or licensed to the operator, are acknowledged on the website.
- Unauthorised use of this website may give to a claim for damages and/or be a criminal offence.
- From time to time this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).
- You may not create a link to this website from another website or document without Group Eleven Group prior written consent.
- Your use of this website and any dispute arising out of such use of the website is subject to the laws of the Isle of Man.
Website Disclaimer
The information contained in this website is for general information purposes only. The information is provided by Group Eleven Group of companies and whilst we endeavour to keep the information up-to-date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk.
In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of or in connection with the use of this website.
Through this website you are able to link to other websites which are not under the control of Group Eleven Group of companies. We have no control over the nature, content and availability of those sites. The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them.
Every effort is made to keep the website up and running smoothly. However, Group Eleven Group of companies takes no responsibility for and will not be liable for the website being temporarily unavailable due to technical issues beyond our control.
Cookies
groupeleven.im Cookie Policy
Last updated: April 2024
Group Eleven Group of companies (“us”, “we”, “Group Eleven” or “our”) uses cookies on groupeleven.im (the “Site”). By using the Site, you consent to the use of cookies.
Our Cookie Policy explains what cookies are, how we use cookies, how third parties we may partner with may use cookies on the Site, your choices regarding cookies and further information about cookies.
What Are Cookies
As is common practice with almost all professional websites Group Eleven use cookies, which are tiny files that are downloaded to your computer, to improve your experience on the site. Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the Site or a third party to recognize you and make your next visit easier and the Site more useful to you.
Cookies can be “persistent” (meaning they remain after your visit to assist with future visits) or “session” cookies (only kept for the time of your single visit).
This page describes what information they gather, how we use the information and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the site’s functionality.
For more general information on cookies see http://www.aboutcookies.org/
How We Use Cookies
When you use and access the Site, we may place a number of cookies files in your web browser.
We use cookies for the following purposes: to enable certain functions of the Site, to provide analytics, to store your preferences, to enable advertisements delivery, including behavioral advertising.
We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:
- Essential cookies. We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.
- Third party cookies. In addition to our own cookies, we may also use various third parties cookies to report usage statistics of the Site, display embedded content deliver advertisements on and through the Site, allow for interaction with social platforms and so on.
Disabling or Controlling Cookies
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the Site.
To find out more on how to manage and delete cookies, visit aboutcookies.org. For more details on managing advertising cookies visit youronlinechoices.eu (EU based), or aboutads.info (US based).
The Cookies We Set
The Site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
When you submit data through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.
Third Party Cookies
In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.
Google Analytics
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This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.
The longest lasting cookie expires 2 years after your last visit to the website. Others are deleted 6 months, 30 minutes and the moment you close your browser.
Social Advertising (Twitter, LinkedIn, Google)
These cookies allow us to track the performance of our digital marketing activities with social networks including remarketing. This allows us to inform, optimize, and serve ads based on someone’s past visits to our website.
Social Media Cookies (Twitter, LinkedIn)
We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work, the following social media sites including; Facebook, LinkedIn, and Twitter, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
Embedded Content (Includes Vimeo/YouTube)
We embed content from third parties who will occasionally use cookies to optimise the user experience of the content.
There are some Vimeo cookies that expire 10 years after first viewing a Vimeo video while most of them expire between a few days for up to two years after the last viewing of a Vimeo video. Most of the YouTube cookies expire 10 years after your last visit to a page containing a YouTube video, although some expire sooner.
More Information
We hope this policy helps to clarify how we use Cookies to enhance your experience on the Site and the effectiveness of our campaigns. If you need any more information please contact us through the below contact methods.
Email: hello@groupeleven.im
Phone: +44 1624 826000
GDPR – Privacy Notice/Statement
1. General
The Group Eleven Group of Companies (Group Eleven) is comprised of a number of data controllers and processors. These Companies are Group Eleven (IOM) Limited (GEIL), Group Eleven Funds Services Limited (“GEFSL”), Group Eleven Limited (“GEL”), Group Eleven Group Limited (GEGL), and Law Trust Solutions Ireland Limited (LTSIL).
This Privacy Policy (“Policy”) sets out how Group Eleven, hereinafter to be referred to as Group Eleven, “we”, “us” or “our” collects, manages, and protects your personal data in the course of your interaction with Group Eleven.
2. Data Protection Legislation
The Isle of Man Data Protection Act 2018 (the Act) is the principal piece of primary legislation addressing data protection in the Isle of Man. Ireland’s Data Protection Act 2018 is the principal piece of primary legislation for data protection in Ireland. These Acts allows for the EU General Data Protection Regulation (GDPR) and the EU Law Enforcement Directive (LED) to be applied to the Isle of Man and Ireland by way of order and regulations.
The Data Protection (Application of GDPR) Order 2018 (the Order) implemented GDPR into domestic Isle of Man law and is supplemented by the GDPR and LED Implementing Regulations 2018 (Implementing Regulations). The Act, Order and Implementing Regulations comprise the Island’s Data Protection Legislation.
The Order provides that the GDPR applies as part of the law of the Island, subject to certain modifications as set out in Schedule 1 of the Order. The GDPR and the modifications are referred to in the Order as the “Applied GDPR” (i.e. the GDPR as amended and as it applies to the Isle of Man) which is the term that is used in this Privacy Notice (“Notice”).
3. Who we are
GEIL, GEFSL, GEL, and GEGL are all incorporated in the Isle of Man; LTSIL is incorporated in Ireland.
GEIL is the “data controller” of all personal data processed by GEIL and our employees. We are registered as a Controller and Processor with the Isle of Man Information Commissioner, Registration No. R001285.
GEGL is the “data controller” of all personal data processed by GEGL and our employees. We are registered as a Controller and Processor with the Isle of Man Information Commissioner, Registration No. R003747.
GEFSL is the “data controller” of all personal data processed by GEFSL and our employees. We are registered as a Controller and Processor with the Isle of Man Information Commissioner, Registration No. R003745.
GEL is the “data controller” of all personal data processed by GEL and our employees. We are registered as a Controller and Processor with the Isle of Man Information Commissioner, Registration No. R003746.
LTSIL is the “data controller” of all personal data processed by LTSIL.
When it comes to your personal data, we want you to be confident that it is safe and secure. We respect your fundamental right to privacy and process personal data in accordance with the Applied GDPR.
4. The type of data we collect
Personal data means any information about a living individual from which that living individual can be identified. It does not include data where the identity has been removed (anonymised data).
Depending on your relationship with us, we may collect, store, process and use the following categories of personal data about you:
- Name and/or job title;
- Contact information including your telephone number and personal email address;
- Date of birth;
- Place of birth;
- Address details;
- Gender;
- Passport details;
- Nationality;
- National identification numbers including tax reference numbers and tax codes;
- Tax status information;
- Source of wealth information;
- Bank account details;
- Photographs; and
- Any other relevant information obtained through background checks and online screening.
5. Why we collect your personal data
The term ‘processing’ may include Group Eleven obtaining, recording or holding your personal data or carrying out any operation on the information or data, including organising, altering, retrieving, consulting, using, disclosing or destroying the personal data.
There are five legal bases for processing that may be appropriate: consent, contract, legal obligation, vital interests of the data subject, or legitimate interests of the controller and third parties.
We offer a wide range of services and the amount and type of information we collect, hold and process will be dependent upon the services we provide. We will only process personal data which we require and will always explain why we require any additional data we ask you to provide.
If you decide not to provide any requested data, please be aware that we may not be able to provide you with the services you require or respond to your queries.
When you enquire about our services, we collect your personal data to take steps prior to entering a contract with you, including:
- Responding to enquiries;
- Assessing the services that are right for you; and
- Negotiating and agreeing terms of business.
When you engage us to provide services, we process your personal data to administer those services, including:
- Communicating with you about the services you have asked us to provide and informing you of changes that affect those services;
- Providing fiduciary services;
- Setting up and administering trusts, companies and collective investment schemes;
- Managing property portfolios;
- VAT registrations and calculations, and submission of VAT returns;
- Buying, selling and financing of assets such as yachts and art;
- Providing fund administration services;
- Processing licence applications;
- Supervision of audits, where applicable; and
- Obtaining certificates of competency and qualification certificates.
We are required to collect your personal data to comply with our legal or regulatory obligations, such as:
- To maintain accurate Customer Due Diligence and conduct anti-money laundering, sanctions and background screening;
- To fulfil foreign and domestic legal, regulatory, governmental, tax, law enforcement and compliance requirements;
- To protect and/or enforce our legal rights and interests, including defending any claims;
- To verify the identity or authority of relevant individuals, representatives who contact us or may be contacted by us;
- To investigate and resolve complaints and remediate errors occurring;
- For risk assessment, statistical and trend analysis and planning purposes, including to carry out data processing, statistical and anti-money laundering and sanctions analyses;
- For crime and fraud detection, prevention, investigation and prosecution;
- To contact you and to respond to communications from you, including a complaint;
- To perform internal management and management reporting, to operate control and management information systems, and to carry out business risk, control or compliance review or testing, internal audits or enable the conduct of external audits;
- To comply with contractual arrangements or to support initiatives, projects and programmes by or between financial industry self-regulatory organisations, financial industry bodies, associations of financial services providers or other financial institutions;
- To manage contentious regulatory matters, investigations and litigation;
- To manage our relationship with you; and
- To improve the quality of our products and services, to develop additional products and services, and for staff training and quality assurance purposes.
There are occasions where it is in our legitimate interest to collect and process your personal data, for example:
- CCTV monitoring of our shared office spaces. This is maintained for the purposes of crime prevention/detection and helps to keep our employees and visitors safe. It also protects your personal information from unauthorised access. Where a data subject can be identified, such images may be given to law enforcement agencies as evidence if we think an offence has been committed;
- When you ask us to provide services, we need to assess the risks associated with providing that service. This may involve processing your information through background checks and credit reference agencies. This evaluates the risks to you, to us and to any organisations whose products or services we are providing for you;
- Analysing details of the number of visits to our website and the pages visitors viewed. This allows us to refine the website and make your visits to our website more informative; and
- To make you aware of additional or new services that we think could be of benefit to you and will complement the services we already provide.
6. Processing of third party personal data
In addition to processing personal data about individuals linked to our clients, we also collect and use data that can identify:
- Intermediaries who are linked to our client structures; and
- Individuals employed by or linked to our service providers and sub-processors.
When you supply us with personal data about another individual, you must ensure that you;
- Inform the individual that you are providing their personal data to us and obtain their permission;
- Provide them with a copy of this Notice;
- Promptly notify the third party of any changes to this Notice that we notify you of; and
- Ensure that, to the best of your knowledge, the personal information is accurate and up to date, and promptly notify us if you become aware that it is incorrect.
7. Legal basis for processing your personal data
We comply with our obligations under the Applied GDPR by keeping personal data up to date; storing and destroying it securely; not collecting or retaining excessive amounts of data; protecting personal data from loss, misuse, unauthorised access and disclosure, and by ensuring that appropriate technical measures are in place to protect your personal information.
We will process your personal data in the following lawful circumstances:
- Where we need to perform the contract we have entered into with you;
- Where we need to comply with a legal obligation; and
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override these interests.
8. Special categories of personal data
Group Eleven does not generally but may, from time to time, be required to process special categories of personal data, revealing/concerning:
- racial or ethnic origin
- political opinions
- religious or philosophical beliefs
- trade union membership
- genetic data
- biometric data
- health
- sex life or sexual orientation
If we ask you to provide such personal data, we will explain your options before requesting you to provide it. These categories of data will be held as strictly confidential and will only be processed in the following circumstances:
- Where we need to carry out our legal obligations or exercise our rights in connection to the service being provided;
- Where it is needed to protect your vital interests (or someone else’s interests).
9. Sharing your personal data within the Group Eleven Group of Companies
We may share your personal data with other Group Eleven Companies where it is necessary for us to provide you with services, company reporting, system maintenance support and for compliance with imposed regulations. Whenever possible, statistical information shared to meet reporting and governance purposes will be anonymised.
There are, however, times when we cannot provide the relevant services without using some personal information. In these cases, access is only granted to Group Eleven parties who require access in order to provide the service. The amount of personal data shared is limited to the minimum level that will allow them to fulfil their functions.
10. Sharing your personal data with other organisations
Any personal data we receive will be kept strictly confidential unless we are compelled by law to disclose it. On occasions it may be appropriate for us to share your personal data with contractors, consultants, regulatory bodies, government, tax authorities, professional advisers, financial institutions, background check agencies, IT service providers and other parties who require such information to assist us with establishing, managing or terminating our relationship with you.
Under these circumstances, we require third parties to implement appropriate security measures to protect your personal data in line with our internal policies.
These external organisations have a legal obligation to comply with privacy and data protection legislation and may also operate under a professional duty of confidentiality due to the type of service they provide.
11. Transferring your personal data to other countries
We may share your personal data with organisations which are located in a different jurisdiction to enable us to perform our contract with you and when required to do so by law. In such circumstances we will ensure they apply equivalent levels of protection.
Countries in the European Economic Area and those that are recognised as providing adequate protection by the European Commission provide an equivalent level of protection as the Isle of Man or Ireland. Personal information can flow freely between these countries because their laws give you the same rights and protections in relation to your personal data.
Whenever we transfer your personal data to an organisation outside of the European Economic Area, we will only do so where:
- The country or organisation we are transferring your data to is recognised by the European Commission as providing adequate data protection standards; or
- We have implemented appropriate safeguards to ensure the protection of your personal data.
12. Storing and deleting your personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting obligations.
When considering 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 data 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 client of Group Eleven, we will retain and securely destroy your personal information in accordance with our Data Retention Policy.
13. How we keep your information secure
We have implemented appropriate security measures designed to protect your personal data from accidental loss, use, unauthorised access, alternation and disclosure.
These measures include industry standard firewalls, intrusion detection and restricting access to personal data to Group Eleven employees, agents, contractors and other third parties who have a specific business purpose. These parties are limited in number, subject to strict confidentiality obligations, and will only process your personal data on our instruction and are subject to a duty of confidentiality.
These measures safeguard the confidentiality, integrity and availability of your personal information.
Unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of any data transmitted electronically, and any such transmission by you is at your own risk. Once we have received your personal data, we implement strict procedures and security features to minimise the risk of unauthorised access.
14. Your rights
Group Eleven will uphold your rights and comply with the principles as outlined in the Applied GDPR. Your rights are as follows:
- right to information about processing
- right of access
- right to rectification
- right to erasure (’right to be forgotten’)
- right to restriction of processing
- right to data portability
- right to object to processing
You will not have to pay a fee to exercise any of your rights. However, if your request for access is clearly unfounded or excessive, we may charge a reasonable fee. Alternatively, we may refuse to comply with the request in such circumstances.
We may require specific information from you to assist us in confirming your identity and ensure your right to access the information. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
If you wish to exercise any of these rights, or if you have any queries about how we process your personal information which are not answered in this Notice, please contact the Data Protection Officer using the following details:
The Data Protection Officer
Group Eleven
3rd Floor, Quay House
South Quay
Douglas
Isle of Man
IM1 5AR
Telephone: +44 1624 826000
Email: dpo@groupeleven.im
15. Further information, enquiries and complaints
If you think that our collection and/or use of your personal data is unfair, misleading or inappropriate, please contact us to discuss your concerns. We take any complaints we receive about the way we process your information very seriously and we would like to hear from you if you have any concerns.
If you feel our processing of your personal information infringes data protection laws, you have the right to make a complaint to the relevant Information Commissioner depending on the jurisdiction of the Group Eleven Company:
Isle of Man
You have the right to lodge your complaint with the Isle of Man’s Information Commissioner, whose contact information can be found at: www.inforights.im.
Ireland
You have the right to lodge your complaint with the Irish Data Protection Commission, whose contact information can be found at: www.dataprotection.ie.
Personal Data
Personal data you have provided is used to supply you with the information or advice you have requested.
Cookies
A cookie is a computer file that contains a small amount of information recording details of your visit to our website. A cookie does not identify you. The cookie is created by our web server and saved on your PC’s hard drive. Each time you visit our website the web server will check to see if you have a cookie for our website. If you do, the web server will be able to check the last time you visited. This information is used if you wish to view what has been updated since your last visit. This is done by clicking the ‘NEW’ button on the menu bar. If you do not want to receive cookies or if you would prefer to be prompted first you should check the settings in the ‘Internet Options’ of your web browser. If you are not sure on how to check or alter these settings, you should contact your software provider.
Use and disclosure of personal information
Your information and personal data is not disclosed, sold or shared with any other organisation. Some information is held and processed by our Internet Service Provider, but it is only held and processed for and on our behalf and under our instruction.
Links
We may provide links within our website to other sites. We neither control, nor review the content of such websites, or of the privacy policies of such sites.
Security
Internet communications are not secure unless the data being sent is encrypted. We cannot guarantee the privacy of any information or accept any responsibility for the unauthorised access by a third party and/or the corruption of data being input on this site or sent to us on the Internet. Any information, communications, or material you transmit to this website by electronic mail or otherwise, including data, questions, comments, or suggestions will be treated as non-confidential and non-proprietary and will become the property of Group Eleven.