United States: Data Protection Notice

What is held, and on what basis

The United States entity holds identification documents, ownership and control records, tax residence declarations, settlement instructions, transaction and valuation records, correspondence, meeting notes and the access logs of the client portal. Each processing activity appears in the group processing register with its origin, its lawful basis, its retention period and a named owner. The firm buys no personal data from data brokers, builds no behavioural profile of a client, and draws no inference about an individual that the mandate does not require. Client data is never sold, and it is never used to train a model that serves another client.

What an individual can require

Any individual whose data the firm holds may ask what is held, ask for a copy, ask for a correction, object to a particular use, or ask for deletion where no retention rule requires the record to be kept. Requests go to privacy@iguako.tech and are answered within 30 days, without charge, whatever the size of the relationship. Where a decision has been assisted by a model, the client may require that a person take the decision again, and the office in Palm Beach arranges that review within ten business days. A refusal is explained in writing and names the rule relied on.

Where the data goes and how long it stays

Client records sit on group systems and are copied to the regional hub that holds United States records, under the intra-group transfer agreement binding every entity in the network. External processors, principally administrators, custodians and auditors, receive only what their function requires, and each is engaged on written terms carrying the same standard. Data is encrypted at rest and in transit, and access to client records is logged and reviewed monthly. Records are kept for seven years after a relationship ends and are then deleted on a scheduled cycle, not at the discretion of the desk that holds them.

The local regime and the reporting of breaches

Data protection law differs across the 28 domiciles. IGUAKO Capital Americas LLC records in the group processing register which regime governs its files, which authority supervises that regime, and what the local rule requires beyond the group minimum.

The United States has no single federal privacy statute, and the group's entities meet several regimes at once: the federal privacy rule for financial institutions, which requires an annual privacy notice and limits the sharing of non-public personal information; the state laws of Florida, New York and Delaware, which govern breach notification and the safeguarding of personal information; and the group standard, which is stricter than any of them on access rights and retention. A breach affecting an individual is notified within the period the relevant state sets, the shortest of which is 30 days, and in practice within the group's 72-hour internal standard. The privacy contact for the four locations is in Palm Beach.

A suspected breach is reported to the Group Data Protection Officer within 24 hours of discovery and assessed within 72 hours wherever in the network it occurs, and the North America regional compliance officer is told at the same time.

Personal data is a liability the firm carries on behalf of the people it belongs to, and it is treated that way. The firm collects the minimum the mandate needs, keeps it only as long as a rule requires, and answers for it through a named officer in every jurisdiction where it holds a file.