Privacy Policy

Last updated: 3 November 2025

1. Who we are

GWIAC Nominee Services (the "Provider", "we", "us") is the data controller for personal data processed in connection with our nominee services and related activities. Contact: Fern Hill Business Centre, Todd St, Fernhill, Bury BL9 5BJ · nomineeservices@gwiac.co.uk.

2. The data we collect

• Identity data: name, date of birth, nationality, NI number, ID documents (passport/driving licence), selfies for verification.
• Contact data: address, email, phone.
• Compliance data: sanctions/PEP/adverse media screening results, AML questionnaires, proof of address and bank statements.
• Technical data: IP address, device/browser info, cookies (see Cookies section).
• Communications: emails, support messages, signatures and confirmations.

3. Purposes and legal bases

• To onboard and provide nominee services (contract: Article 6(1)(b)).
• To meet legal/AML obligations incl. CDD/EDD, sanctions/PEP checks, record‑keeping (legal obligation: Article 6(1)(c); public interest for AML where applicable: Article 6(1)(e)).
• To protect our legitimate interests incl. fraud prevention, security, and service administration (legitimate interests: Article 6(1)(f)).
• Marketing communications where you opt‑in (consent: Article 6(1)(a)) with an unsubscribe option at any time.

Where we process sensitive data from ID documents (e.g., biometric images in selfies), we do so only where necessary for identification/verification and subject to additional safeguards or your explicit consent.

4. Retention

We retain AML/KYC records for 5 years from the end of the business relationship or the date of an occasional transaction, unless a longer period is required/permitted by law. Other data is kept only as long as necessary for the purposes above.

5. Sharing your data

• Verification and screening providers (e.g., electronic ID checks, sanctions/PEP tools).
• Regulators, law enforcement or HMRC where required.
• Professional advisers (accountants, lawyers) under confidentiality.
• Cloud and IT providers for secure hosting and email delivery.

We do not sell your personal data.

6. International transfers

Where data is transferred outside the UK, we use appropriate safeguards such as the UK International Data Transfer Agreement (IDTA) or Addendum, or rely on adequacy regulations where applicable.

7. Your rights

• Access, rectification, erasure, restriction, objection, portability.
• Withdraw consent where processing is based on consent.
• Lodge a complaint with the UK Information Commissioner’s Office (ICO).

To exercise your rights, email nomineeservices@gwiac.co.uk. We may need to verify your identity.

8. Cookies

We use essential cookies to operate the site and optional analytics cookies to improve performance. On your first visit, we will ask for your preferences.

• Essential: required for security, forms and navigation.
• Analytics (optional): help us understand usage. Disabled unless you consent.

You can change preferences at any time via the cookie banner or your browser settings.

9. Security

We implement technical and organisational measures appropriate to the risk, including encryption in transit, access controls, staff training and vendor due diligence. No method is 100% secure; we continuously review and improve our safeguards.

10. Children

Our services are not directed to children. We do not knowingly collect data relating to persons under 18.

11. Contact

Questions about this policy or data requests: Fern Hill Business Centre, Todd St, Fernhill, Bury BL9 5BJ · nomineeservices@gwiac.co.uk.

12. Changes to this policy

We may update this Privacy Policy from time to time. We will post the new version with an updated “Last updated” date.