Client portal

Privacy Policy

1. Introduction

AXYS provides fiduciary, administration, wealth management, and trusteeship services to corporate, institutional and private investors. This Privacy Policy explains how the entities falling under AXYS/ACI Group collect, manage and protect your personal data if we need to process it as a data controller or processor for the purposes of providing services to our clients. References to “we”, “us” and “our” in this policy are to one or more entities within the AXYS/ACI Group, which are as follows as : AXYS Investment Partners Limited, AXYS Stockbroking Ltd and AXYS Corporate Advisory Ltd ”, AIB-AXYS Africa Ltd, NWT (Mauritius) Limited, NWT Trustees Ltd, NWT Conseil SA, TrustExec Ltd, London CO – TBC. A corporate structure of AXYS Group can be found here.

We collect and process your personal data if you are:

  • a client that is an individual signing a mandate or a service agreement with us;
  • Associated with a corporate structure because we have identified you as beneficial owner, director, employee, signatory, consultant, beneficiary, or investor in the structure;
  • If you represent an organization that we deal with, for example, law firms, auditors, banks, advisers, suppliers or any other competent bodies
  • An employee or a potential employee of the Group;

Purpose of the Privacy Policy. AXYS respects your rights and privacy and is committed to protecting your personal data under the Data Protection Act 2017, Data Protection
Regulations 2020 and any guidelines issued by the Data Protection Commission. Unless
otherwise superseded by alternative terms and conditions (such as in users or employee contracts), the method by which the user’s personal data is collected, used, distributed, and
maintained will be in line with this policy.

2. Data we Collect and Hold on You

The personal data that we collect, and hold will depend on our relationship with you and will
include the following:

  • Identification data & personal details such as name, date of birth, nationality, gender,
    marital status, place of birth, employment status, educational background & interest,
    country of tax residence, TAN/TIN/GINN Number, social security number, any political affiliations, telephone & fax number, email address, work & home address, financial and banking information such as financial reports, accounts, bank account number, bank statements, details of any criminal convictions or any adverse media articles. The list which is non-exhaustive will be subject to our requirement to meet the regulatory obligations such as the Financial Intelligence and Anti-Money Laundering Acts and Regulations.

Use of our Products or Services – your personal data will be used by AXYS to provide you
with products and services being provided or distributed by AXYS.

By participating in our Events – if you have attended any of our events, we may collect
your name, organisation, job title, telephone numbers and email address.

When you visit or register to use our website – we may automatically collect some data
through cookies or similar technologies such as Internet Protocol (IP) address which include
your country of location, time zone setting, information on how you use of our website,
including the pages you viewed, any document downloads, any subscription for alerts or
newsletters and any search terms entered.

Use of Subscription Data – if you seek or subscribe to any services of AXYS, we will collect and use relevant data to carry out our regulatory due diligence processes, including amongst others, your name, phone number, title, email address and National Identity Card/Passport details. This data may be shared with approved third-party service providers of  AXYS and with relevant regulatory authorities.

Use of Technology Systems of AXYS – while using any software application made available by AXYS, personal data may be collected regarding your device, operating system, browser, application name, vendor, IP address, and country of origin.

Use of AXYS Market Data – we may collect personal data such as names, titles, phone numbers and emails for our own business and administrative purposes.

Recruitment and Employment – we may collect personal data from applicants and employees as a part of our recruitment process, to conduct interviews and employee onboarding. We may collect personal data such as name, contact details, professional background, reference, background checks and bank account information for payroll and for employee insurance.

Use of Social Networks – you may be able to connect your personal or business social media accounts to social media accounts maintained by AXYS (LinkedIn, Facebook, etc.).Your use of this functionality shall be treated as your consent for AXYS to obtain the
personal data available on the social media account you link to AXYS, in accordance with the privacy policies of those social media sites.

Records of Correspondence – we keep records of communications, which take place between you and us, including emails, letters, meetings and telephone calls.

Other Information – additional information you provide to us or created by us when providing services to you.

Marketing emails and correspondences – If you subscribe to our marketing communications or your contact details have been added to our contact lists, we will collect and process your personal details such as your full name, address, job position and your company name in order to send you promotional updates about our services. You may unsubscribe to the marketing communications at any time.

3. Purposes & lawful basis for processing your personal data

We primarily use your data for the following purposes:

  • Performance of a contract/agreement to which you are party, or in order to take steps following your instructions before entering into a contact, for example, to incorporate a company, investing your funds into our financial products, opening a bank account or any other services to you under the service agreement;
  • To meet our legal, compliance and regulatory obligations such as the Anti-Money Laundering & Terrorist Financing Laws, Common & FATCA reporting to which we, as Controller are subject to :
    • To protect your vital interest as data subject;
    • For the performance of any task carried out by the public interest or in the exercise of official authority vested in the Controller;
    • For the performance of any task carried out by the public authority;
    • In the exercise, by any person on the public interest, of any other functions of a public nature;
    • For the legitimate interest pursued by us as Controller or by a third party to whom the data are disclosed, except if the processing is unwarranted in any particular case having regard to the harm and prejudice to your rights and freedoms or your legitimate interest;
    • For historical, statistical or scientific research;


In addition, we may use your data:

  • To provide you with a proposal with regards to the services we offer to you;
  • To handle queries or complaints you may have in order to improve our services;
  • To process complaints and feedbacks
  • To forward to any competent Court, Regulatory  Body or any other competent Authority as may be required for court matter or any other investigation;
  • Request marketing information to be sent to you.

4. Transferring/Sharing your Personal Information

Where we cause your data to be transferred or shared, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information and where required, with your consent

We may, during the course of business transfer, store your personal data to a web hosting and/or cloud service provider, which may be located outside of our usual place of business as part of our disaster recovery plan, which may include processing of such information by
staff operating outside of our usual place of business

You can request further details about the safeguards that we have in place in respect of transfers of personal data outside of our usual place of business

By submitting your personal data to us, you agree to us transferring, processing and storing your data as described above.

5. Retention of your Data

We retain your personal data for the length of time required under any applicable and relevant laws for the specific purpose or purposes for which it was collected. However, we may be obliged to store some personal data for a longer time, considering factors including:

  • legal obligation(s) under applicable laws to retain records for a certain period
  • maintain business records for analysis and/or audit purposes
  • defend or bring any existing or potential legal claims
  • deal with any complaints regarding the services; and
  • guidelines issued by relevant data protection authoritiess.

6. Data Security

We will hold your personal data securely whilst it is under our control. We keep the data for as long as is necessary for the relevant purpose.

We have appropriate security measures to prevent your personal data from being used, or accessed in an authorized way, altered or disclosed. We have document and office premise access protocols in place to ensure strong protection of data.

You should be aware that the transmission of  information via the Internet is not completely secure we cannot guarantee the security of your data transmitted to our website.

7. Your legal Rights

You have a number of rights in relation to the personal data that we hold about you and you can exercise your rights by contacting us using the details in ‘Contact Us’ section.

These rights include:

  • Obtaining information regarding the processing of your personal data and access to the personal data which we hold about you.
  • Withdrawing your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
  • Request that we correct your personal data if it is inaccurate or incomplete.
  • Requesting that we erase your personal data in certain circumstances. Please note that there may be circumstances where though you ask us to erase your personal data, we cannot erase it as we are legally entitled/obliged to retain it.
  • Requesting that your personal data is only used for restricted purposes.
  • Objecting that your personal data are processed for certain purposes, for example, for marketing.
  • In some circumstances, require that some of your personal data to be transferred to you or a third party.
  • Lodging a complaint with the relevant regulatory body in Mauritius – Data Protection Office.
  • There may be circumstances in which we are entitled to refuse requests for access to copies of personal information, such as if the data is subject to legal professional privilege.

8. Your Consent

By using our website, you agree to the terms of this Privacy Policy, as may be updated from time to time.

10. Applicable Legislation

Use of our website and any activities concluded with us are governed by the laws of the Republic of Mauritius and/or by the laws of the jurisdictions where any of the entities forming part of the AXYS, operates.

11. Changes to Privacy Policy

Our website and/or any other information that we display publicly may change from time to time, due to many factors such as the applicable laws or our own internal processes. As a result, it may be necessary for us to make changes to this Privacy Policy.

You may request a full copy of this Privacy Policy from us using the contact details set out below. If we change this Privacy Policy in any way, the updated version will be posted on our website in a timely manner.

12. Contact Us

If you have questions or wish to exercise any of your rights, then you can contact the data protection officer of each of the entities under the AXYS Group:

NWT (Mauritius) Ltd and NWT Trustees Ltd

Darshini Callichurn
[email protected]

AIP , ACA and ASL
Adèle Jeannot
[email protected]

If you feel that your request or concern has not been resolved satisfactorily, you may contact the local data protection commission in the jurisdiction in which we provide services to you.

Mauritius
Data Protection Office, 5th Floor, SICOM Tower, Wall Street, Ebene, Republic of Mauritius;
Tel: +(230)460‐0251; Email: [email protected]; Website: http://dataprotection.govmu.org/

Disclosures

AXYS Investment Partners Ltd (Reg No 113032) is regulated by the Financial Services Commission (Licenses: CM13000024 | DF13000020 |IX13000038)

AXYS Stockbroking Ltd (Reg No C7948) is regulated by the Financial Services Commission (License: IQ08000011)

AXYS Corporate Advisory Ltd (Reg No 134022 C1/GBL) is regulated by the Financial Services Commission (License: C115015077)