1. Who We Are
Alhambra Bank & Trust Limited ("Alhambra," "we," "us," or "our") is a Category B licensed bank and trust company incorporated in the Cayman Islands, authorised and supervised by the Cayman Islands Monetary Authority (CIMA) under the Banks and Trust Companies Act (Revised).
Our registered address is: 64 Earth Close, 2A3 Landmark Square, PO Box 30275, Seven Mile Beach, Grand Cayman KY1-1202, Cayman Islands.
This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you interact with our website, apply for our services, or maintain a banking relationship with us. Please read this policy carefully. If you do not agree with its terms, please discontinue use of our website.
2. Information We Collect
2.1 Information You Provide Directly
We collect personal information that you voluntarily provide when you:
- Submit an account application or enquiry form
- Communicate with us by email, telephone, or secure message
- Provide KYC/AML documentation during onboarding
- Use our online client portal or mobile application
- Request information about our products and services
This information may include: full legal name, date of birth, nationality, country of residence, passport or national ID number, tax identification number, source of wealth, net worth, occupation, employer, email address, telephone number, and financial transaction data.
2.2 Information Collected Automatically
When you visit our website, we automatically collect certain technical information including: IP address, browser type and version, operating system, referring URL, pages viewed, time and date of access, and device identifiers. This information is collected via cookies and similar tracking technologies as described in Section 9.
2.3 Information from Third Parties
We may receive information about you from third parties including: credit reference agencies, fraud prevention agencies, sanctions screening providers, public registers, and your legal or financial advisers (where authorised). This information is used to fulfil our regulatory obligations and to verify your identity.
3. How We Use Your Information
We use the personal information we collect for the following purposes:
- Account Opening & Onboarding: To process your application, conduct KYC/AML due diligence, and establish your banking relationship.
- Service Delivery: To provide private banking, trust, investment management, and related financial services.
- Transaction Processing: To process deposits, withdrawals, fund transfers, and other financial instructions.
- Regulatory Compliance: To meet our obligations under the Banks and Trust Companies Act, Anti-Money Laundering Regulations, Proceeds of Crime Act, FATCA, and OECD Common Reporting Standard (CRS).
- Fraud Prevention & Security: To detect, prevent, and investigate fraud, money laundering, and other illegal activities.
- Communications: To respond to your enquiries, provide account statements, and send important notices regarding your account.
- Service Improvement: To analyse website usage and improve our products, services, and digital platforms.
- Legal Obligations: To comply with applicable laws, court orders, and requests from regulatory authorities.
4. Legal Basis for Processing
We process your personal information under the following legal bases:
- Contractual Necessity: Processing is necessary to perform our obligations under your account agreement and to provide the banking services you have requested.
- Legal Obligation: Processing is required to comply with our obligations under Cayman Islands law, CIMA regulations, AML/CFT requirements, FATCA, and CRS.
- Legitimate Interests: Processing is necessary for our legitimate interests in operating a safe, secure, and compliant banking institution, including fraud prevention and business administration.
- Consent: Where we rely on consent (for example, to send marketing communications), you may withdraw your consent at any time by contacting us.
5. Sharing Your Information
We do not sell, trade, or otherwise transfer your personal information to unaffiliated third parties for commercial purposes. We may share your information with:
- Regulatory & Government Authorities: CIMA, the Cayman Islands Financial Reporting Authority (CIMA), foreign tax authorities (under FATCA and CRS obligations), law enforcement, and courts when required by law.
- Service Providers: Third-party providers who assist us in operating our website, processing transactions, conducting KYC checks, and delivering our services — bound by strict confidentiality agreements.
- Correspondent Banks: Banks and financial institutions used to facilitate international fund transfers, where disclosure is necessary to execute your instructions.
- Professional Advisers: Legal counsel, auditors, and compliance consultants engaged to advise or support our operations.
- Your Authorised Representatives: Legal advisers, trustees, or other persons you have authorised in writing to act on your behalf.
6. International Transfers
As an international private bank, the provision of our services may require the transfer of your personal information to countries outside the Cayman Islands, including jurisdictions where data protection laws may differ. Where such transfers occur, we implement appropriate safeguards including contractual data protection clauses and we ensure any recipient is bound by obligations of confidentiality no less stringent than those applied by Alhambra.
7. Data Retention
We retain your personal information for as long as necessary to fulfil the purposes for which it was collected and to comply with our legal and regulatory obligations. Specifically:
- Client account records and KYC documentation are retained for a minimum of 5 years after the conclusion of the business relationship, in accordance with CIMA requirements.
- Transaction records are retained for a minimum of 5 years from the date of the transaction.
- Website usage data is retained for no longer than 24 months.
- Enquiry and application records (where no account was opened) are retained for 2 years.
8. Your Rights
Subject to applicable law and our regulatory obligations, you have the following rights regarding your personal information:
- Right of Access: To request a copy of the personal information we hold about you.
- Right to Rectification: To request correction of inaccurate or incomplete information.
- Right to Erasure: To request deletion of your personal information where we no longer have a legal basis for processing it.
- Right to Restrict Processing: To request that we limit the way we use your information in certain circumstances.
- Right to Data Portability: To receive your personal data in a structured, commonly used format.
- Right to Object: To object to processing carried out on the basis of legitimate interests.
To exercise any of these rights, please contact us at privacy@alhambraprivate.com. We will respond within 30 days. Please note that certain rights may be limited where we are required to retain or process data under applicable law.
9. Cookies & Tracking Technologies
Our website uses cookies and similar technologies to improve your experience and analyse usage. Cookies are small text files stored on your device. We use:
- Essential Cookies: Necessary for the website to function correctly. These cannot be disabled.
- Analytics Cookies: To understand how visitors use our website (e.g., pages visited, time spent). Data is aggregated and anonymous.
- Security Cookies: To protect against fraud and unauthorised access to our client portal.
We do not use advertising or tracking cookies. You can control cookies through your browser settings. Disabling certain cookies may affect website functionality.
10. Security Measures
We implement industry-standard technical and organisational measures to protect your personal information against unauthorised access, disclosure, alteration, or destruction. Our measures include AES-256 encryption, TLS 1.3 for all data in transit, multi-factor authentication, regular security audits, staff training, and access controls on a need-to-know basis.
While we take all reasonable precautions, no transmission of data over the internet is completely secure. You transmit information to us at your own risk. If you become aware of any security issue, please contact us immediately.
11. Changes to This Policy
We reserve the right to update this Privacy Policy at any time. Changes will be posted on this page with a revised effective date. Where changes are material, we will notify active clients via their registered email address. Continued use of our website or services after such notification constitutes acceptance of the updated policy.
12. Contact Us
For any questions, concerns, or requests relating to this Privacy Policy or our data practices, please contact our Data Protection Officer:
- Email: privacy@alhambraprivate.com
- Post: Data Protection Officer, Alhambra Bank & Trust Limited, 64 Earth Close, 2A3 Landmark Square, PO Box 30275, Seven Mile Beach, Grand Cayman KY1-1202, Cayman Islands
- Phone: +1 (345) 949-4000