Details of the processing
Nature and Purpose of Processing
As defined in the Personal Data Protection Policy of TMF Group (“PDPP”), TMF Affiliate involved in the rendering of Services to Client is a financial and corporate administration services provider, and will Process Client Personal Data as necessary and solely for the purposes of performing the Services pursuant to the Service Agreement, and as further instructed by Client or Client Affiliate in its use of the Services.
Duration of Processing
Subject to section 8 of the PDPP, TMF Affiliate will Process Personal Data for the duration of the Service Agreement, unless otherwise agreed upon in writing.
Types of Services and Personal Data Processed
Client (Affiliate) may submit Personal Data to TMF Affiliate to enable it to render the Services, the extent of which is determined and controlled by Client (Affiliate) in its sole discretion, and which may include the following types of Personal Data, depending on the type and scope of the Services:
| Service | Types of Personal Data |
| Accounting and Tax | First and family name, address, telephone, email, nationality, date of birth, place of birth, gender, marital status, job title, Client ID, signature, bank account details. |
| Capital Markets and Fund Services | First and family name, address, telephone, email, nationality, date of birth, place of birth, gender, (tax / social / national) identification number, compensation and benefits financials, user account details, job title, Client ID, signature, bank account details. |
| Consultancy Solutions | If required and as determined per scope in the Service Agreement (see other service types). |
| Family Business Wealth Services | First and family name, address, private and tax residence, copy of ID, telephone, email, nationality, date of birth, place of birth, gender, marital status, (tax / social / national) identification number, job title, signature, bank account details. |
| Global Entity Management (Corporate Secretarial Services) |
First and family name, address, telephone, email, nationality, date of birth, place of birth, gender, marital status, (tax / social / national) identification number, copy of curriculum vitae, compensation and benefits financials, user account details, job title, employee ID, Client ID, signature, bank account details. The following information is also collected in Know Your Client Services: ID from the Ultimate Beneficial Owners (UBOs) or executives (e.g. managing directors or board members), tax residence, private/residential address, profession and actual function, range of annual income, range of estimated wealth, the source of wealth and (where applicable) taxpayer identification number. |
| HR and Payroll | First and family name, address, telephone, email, nationality, date of birth, place of birth, gender, marital status, (tax / social / national) identification number, compensation and benefits financials, user account details, job title, employee ID, Client ID, signature, bank account details, health status related data. |
| HR Admin Services | Dependents data (spouse, children), race (only for specific HR reporting data in some countries), copies of passport or ID card, sick notes from a doctor or other health institution, degrees and educational certificates / educational information. |
*Client (Affiliate) may choose to deviate from the types included in the table above as it may be required for specific purpose under the Service Agreement and as determined by the same.
Categories of Data Subjects
Client may submit Personal Data to TMF Affiliate to enable it to render the Services, to the extent determined and controlled by Client in its sole discretion, and which may include the following categories of Personal Data, depending on the type and scope of the Services:
- clients who are (also) natural persons
- (candidate) employees or contact persons of Client (Affiliate)’s
- agents, advisors, suppliers, shareholders and other representatives of Client (Affiliate)’s - who are natural persons
(Sub)processors
Subject to section 5 of the PDPP, the subprocessors of TMF Group are listed on this page.
TMF Affiliates
TMF Group organisation structure and TMF Affiliates subject to TMF Group Binding Corporate Rules are listed here.
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