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Privacy Notice

Introduction

This privacy notice explains how Sevoria collects, uses, and shares the information you provide to us and the information we collect while operating our business.

In this notice, where we refer to "Sevoria" (or "we"/"us"/"our)", we mean Sevoria Limited and its subsidiaries, as set out at the end of this notice.

Sevoria is a corporate services provider and fund administrator operating in Guernsey. We use selected cloud-based systems operated by reputable third-party providers to manage and store personal data, which may be hosted and/or processed in Guernsey, the United Kingdom, the European Economic Area or in other jurisdictions recognised as providing an adequate level of protection.

We may collect information from you through your use of our website, when you request information from us, engage with our services, or otherwise during our business. References in this notice to “your information” are also to personal information that you provide to us or which we otherwise gather while operating our business.

The information we collect

We may collect various types of personal data about you, including:

  • Personal identification information, which may include your name and passport information, IP address, tax status and identification information, personal data relating to politically exposed person (PEP) status, personal data available in the public domain and such other information as may be necessary for Sevoria to provide its services, complete its Customer Due Diligence (“CDD”) process and discharge its Anti-Money Laundering/Countering the Financing of Terrorism/Countering Proliferation Financing (“AML/CFT/CPF”) obligations.
  • Contact information, which may include your residential address, postal address and e-mail address and your home and mobile telephone numbers.
  • Family relationships, which may include your marital status, the identity of your spouse and the number of children that you have.
  • 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.
  • Financial information, which may include details of your assets, source of wealth, source of funds, shareholdings and your beneficial interest in assets, your bank details, and your credit history.
  • 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.
  • 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 publicly available information about you on your social media accounts. Please refer to our Recruitment Privacy Notice for full details on what and how we process personal data for the purposes of recruitment.

Where we obtain your personal information

We collect your personal information from the following sources:

  • Personal information you give to us, such as:
    • Forms and documents we may request be completed in relation to the provision of any of our services
    • Information gathered through CDD carried out as part of our compliance with regulatory requirements; and
    • Any personal information provided by way of correspondence with us by phone, e-mail or otherwise.
  • Personal information we receive from third party sources, such as:
    • Our clients: in connection with matters upon which we are or may be engaged (for example where you are a counterparty to a transaction or an employee of one of our clients or a related party of a company in which our client is invested)
    • Entities in which you or someone connected to you has an interest
    • Financial institutions who hold and process your personal information
    • Credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements
    • Personal information received while dealing with advisors, regulators, official authorities, and service providers by whom you are employed or engaged or for whom you act.

Information that we collect through our website

In addition to any information you knowingly provide, when you browse our website it may automatically collect the following:

  • technical information, including your Internet Protocol (“IP”) address to help diagnose problems with the server and to administer the website. An IP address is a number that is assigned to your computer when you use the internet. Your IP address is also used to help identify you during a particular session and to gather broad demographic data; and
  • information about your visit including, for analytical purposes, using the Google Analytics service which collects information such as how often and what pages you visit on the website and what other sites you used prior to coming to the website.

Google Analytics places a cookie, which is only accessible by Google, on your computer to identify you as a unique user the next time you visit our website. Google's use of this cookie is governed by their Google Analytics Terms of Service (https://www.google.com/analytics/terms/) and their Google Privacy Policy (https://www.google.com/intl/en-GB/policies/privacy/).

We do not combine the information collected through our use of Google Analytics with any other information which may identify you personally.

How we use your information

At Sevoria we are committed to protecting and respecting your privacy. We provide corporate and other professional services to our clients and we use your personal data for those purposes. Normally the purposes for which we use your personal data will be clear when we collect that data. We will not use your personal data for purposes that are not clear when we collect that data and will only use your personal information to:

  • Conduct administrative or operational processes within our business
  • Provide and improve our services
  • Compile anonymous statistics, for example website usage statistics
  • Perform a contract which we may have with you
  • Comply with our legal and regulatory obligations
  • Establish, exercise or defend the legal rights of Sevoria or for the purpose of legal proceedings
  • Process and respond to requests, enquiries or complaints received from you or someone connected to you
  • Send you marketing material
  • Invite you to events
  • For other legitimate business purposes
  • Review and process your application should you apply for a position with us

How and why we share your information

We may share your personal information outside Sevoria. This may include disclosures to:

  • Third party agents, suppliers, or contractors, in connection with the processing of your personal information for the purposes described in this policy, which may include but is not limited to:
    • IT and communications service providers;
    • Software/hosting providers; and
    • Our own advisers such as auditors, bankers, tax advisers and any external legal advisors which we may instruct from time to time.
  • Third parties relevant to the services that we provide, which may include but is not limited to:
    • Counterparties to transactions
    • Other professional service providers
    • Regulators
    • Tax authorities
    • Law enforcement agencies
    • Governmental institutions
    • Tribunals and courts
  • To the extent required by law, regulation, or court order, for example if we are under a duty to disclose your personal information to comply with any legal obligation such as our AML/CFT/CPF obligations.
  • In the event of a sale, merger, re-organisation or transfer of business assets, personal data may be transferred to the successor entity (subject to appropriate safeguards).
  • We may disclose your personal information for the purposes of seeking references and confirmation of the details which you have provided should you apply for a position with us.

International transfers

Where we transfer your personal information outside the European Economic Area (the "EEA"), we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. This can be done in several different ways, for instance:

  • The country to which we send the personal information may have been assessed by the European Commission ("EC") as providing an "adequate" level of protection for personal data (this includes Jersey and Guernsey).
  • The recipient may have signed a contract based on standard contractual clauses approved by the EC.

In other circumstances, the law may permit us to transfer your personal information outside the EEA. In all cases, however, any transfer of your personal information will be compliant with applicable data protection law. You can obtain more details of the protection given to your personal information when it is transferred outside Europe by contacting us using the details set out below.

Direct marketing

We may ask whether you wish to receive marketing from us, and this will be presented to you as an option on the relevant application form or page on our website where necessary. We may also contact you by email or other means to inform you about other services or events which may be of interest to you. You have the right at any time to stop us from contacting you for marketing purposes. If you wish to do so, please either unsubscribe or contact dataprivacy@sevoria.group.

Retention of personal information and security

Your personal information will be retained for as long as required:

  • For the purposes for which the personal information was collected
  • To establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations
  • As required by data protection laws and any other applicable laws or regulatory requirements.

We will ensure that the personal information that we hold is subject to appropriate security measures.

Access to and control of your personal information

You have the following rights in respect of the personal information about you that we process:

  • Right of access – to obtain a copy of personal data we hold about you.
  • Right of rectification – to correct inaccurate or incomplete data.
  • Right of erasure – to request deletion in certain circumstances.
  • Right to restrict processing – to request that processing is suspended.
  • Right to object – to object to certain processing (e.g. direct marketing).
  • Right to withdraw consent – where processing is based on consent.
  • Right to data portability – to receive or transfer your data in a structured, machine-readable format.
  • Right not to be subject to automated decision-making or profiling

You also have the right to lodge a complaint about the processing of your personal information either with us, or with the Office of the Data Protection Authority (ODPA) https://www.odpa.gg.

As noted above, where we have relied on consent to process your personal information, you have the right to withdraw consent at any time.

If you wish to exercise any of the rights set out above, please contact our data protection representative at dataprivacy@sevoria.group.

Inaccurate or amended information

Please let us know as soon as possible if any of your personal information changes (including your correspondence details). Failure to provide accurate information or to update information when it changes may have a detrimental impact upon our ability to provide services to you.

Questions and contact information

If you have any questions in relation to this notice, please contact our Data Protection Representative at the address listed below or by emailing dataprivacy@sevoria.group.

Changes to this policy

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure you are happy with any changes. We last updated this policy on 1 January 2026.

Sevoria entities

Sevoria Limited is a non-cellular company limited by shares, registered in Guernsey with registration number CMP74747 and registered office situated at PO Box 222, 20 New Street, St Peter Port, Guernsey GY1 4JG.

Sevoria Limited has two wholly owned subsidiaries, SV Directors Limited and BH Nominees Limited, which are each a non-cellular company limited by shares, registered in Guernsey with registration number CMP77145 and CMP77146 respectively. The registered office address of both companies is the same as Sevoria Limited.

Sevoria Limited is licensed and regulated by the Guernsey Financial Services Commission under the Protection of Investors (Bailiwick of Guernsey) Law, 2020 and the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc. (Bailiwick of Guernsey) Law, 2020 (“Fiduciary Law”). SV Directors Limited and BH Nominees Limited are secondary licensees under the Fiduciary Law.