Wilmington Trust

Website Privacy Notice

(UK & EU)

Last updated: November 9, 2020

Wilmington Trust (“Wilmington Trust”, "we", "us", and "ours") respects your right to privacy. This Website Privacy Notice explains how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Website Privacy Notice only applies to personal information that we collect from UK and EU users through their use and interaction with our website and online services (“Online Services”).

For personal information that we collect when you interact with us as a Client of Wilmington Trust, please see our Wilmington Trust Privacy Notice, or if you are a user located outside of the UK or the EU please see our Internet Privacy Notice.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Website Privacy Notice.

What personal information does Wilmington Trust collect and why?

The personal information that we may collect about you broadly falls into the following categories:

Information that you provide voluntarily

Certain parts of our Online Services may ask you to provide the following personal information voluntarily:

Contact details: your name, company, job title, email address and other contact details you may need to provide in order to register an account with us, to apply for our online products or services, to subscribe to marketing communications from us, and/or submit enquiries to us.
Account details: answer to security questions, user name/ID, passcode to access and login to your account/s with us.
Other information provided when engaging with us: you may provide other information to us such as when you volunteer to participate in one of our online surveys or promotions.

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

Information that we collect automatically

When you visit our website or interact with our Online Services, we may collect certain information automatically from your device. In some countries, including the UK and countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Online Services, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our website, where they come from, and what content on our website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our website to our visitors.

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.

·Information that we obtain from third-party sources

From time to time, we may receive information about you from third-party sources (including search engines and our advertising partners), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your information to us.

The types of information we collect from third parties include advertisements you viewed or clicked, and we use the information we receive from these third parties to improve the relevancy of the content we serve and the experience we provide you.

In general, we will use the personal information we collect from you only for the purposes described in this Website Privacy Notice or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

Who does Wilmington Trust share my personal information with?

We may disclose your personal information to the following categories of recipients:

·to our group companies, third-party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Website Privacy Notice or notified to you when we collect your personal information;
·to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
·to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Website Privacy Notice;
·to any other person with your consent to the disclosure.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, for example to provide you with access and use of some of our Online Services in accordance with any applicable terms & conditions; (ii) where the processing is in our legitimate interests and not overridden by your rights, for example where we use information to operate our Online Services and improve our service offering to you; or (iii) where we have your consent to do so, for example where you choose to participate in any of our surveys or promotions. In some cases, we may also collect personal information from you, to comply with a legal obligation to which we are subject, such as money laundering regulations.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Online Services and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Online Services, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you, including to serve interest-based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice [LINK].

How does Wilmington Trust keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. We have established and continually maintain security standards and procedures to help us protect you from unauthorized access to confidential information we may have about you, including through the Internet. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. We protect information you provide us online in several ways. We use encryption standards and SSL (Secure Socket Layer) technology to help ensure that information passes to Wilmington Trust without being intercepted by third parties. User IDs and passcodes are operational measures used to help safeguard access to your information on some of our Online Services.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

Specifically, our group companies and third-party service providers and partners around the world, including in countries outside the UK or the European Economic Area such as the U.S. This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Website Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the UK or the EEA in accordance with the UK or the European Union data protection law, respectively.

We rely on similar appropriate safeguards with our third-party service providers and partners and may also rely on representations from third parties that appropriate safeguards are in place through their compliance with approved data transfer frameworks. Further details can be provided upon request.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We retain your personal information for the life of your customer relationship with us. Once your customer relationship is terminated, we will continue to retain your personal information only for as long as it is needed for the purposes set forth in this Website Privacy Notice, and for no longer than the maximum time period allowable under applicable law and regulation.

Your data protection rights

You have the following data protection rights:

If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
·You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
·You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Updates to this Website Privacy Notice

We may update this Website Privacy Notice from time to time in response to changing legal, technical or business developments. A Website Privacy Notice will be available to you each time you visit our Website. You will be able to see when this Website Privacy Notice was last updated by checking the "Last updated" date displayed at the top of this Website Privacy Notice.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact us using the following details: gdproffice@wilmingtontrust.com.

The data controller of your personal information is as follows:

Name of Controller

Wilmington Trust SP Services (London) Limited
Wilmington Trust (London) Limited
Wilmington Trust SP Services (Dublin) Limited
Wilmington Trust SP Services (Frankfurt) GmbH
Wilmington Trust S.A.S.
Wilmington Trust (Milano) S.r.l.

Controller Contact Information

Wilmington Trust SP Services (London) Limited Third Floor, 1 King’s Arms Yard
London, EC2R 7AF
gdproffice@wilmingtontrust.com