Privacy Policy

FRESH BUSINESS VENTURES LTD

PRIVACY POLICY

Effective Date: 30 September 2026
Last Updated: 30 September 2026

Fresh Business Ventures Ltd (“FBV”, “we”, “us” or “our”) respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, use, store and protect personal information when you communicate with us, use our services, complete a client profile or authority, visit our website, or otherwise engage with FBV.

FBV is based in the Isle of Man and processes personal information in accordance with applicable data protection legislation.

  1. WHO WE ARE

Fresh Business Ventures Ltd
The Engine House, Alexandra House, Castletown, Isle of Man. IM9 1TG

Telephone: 01928 787 603

For the purposes of applicable data protection legislation, FBV may act as the data controller in relation to personal information that we collect and determine how and why to process.

Where FBV processes personal information strictly on behalf of another organisation, FBV may instead act as a data processor, with the respective responsibilities determined by the relevant agreement.

 

  1. INFORMATION WE MAY COLLECT

Depending on the nature of our relationship with you, we may collect information including:

Personal and Contact Information

· Name

· Date of birth

· Nationality

· Residential and correspondence addresses

· Telephone numbers

· Email addresses

· Identification information

· Professional or business information

Family and Connected-Person Information

Where relevant to the services requested, we may collect information concerning:

  • Spouses and partners
  • Family members
  • Beneficiaries
  • Business partners
  • Directors and shareholders
  • Trustees and other connected persons
  • Family governance and succession arrangements

Where you provide information relating to another individual, you should ensure that you are authorised to provide that information or otherwise have a lawful basis for doing so.

Financial and Commercial Information

Where relevant to our engagement, this may include:

  • Business interests and ownership
  • Assets and liabilities
  • Property interests
  • Banking and financial arrangements
  • Investments and holdings
  • Trusts, foundations and other structures
  • Sources of wealth and funds
  • Proposed movements of funds
  • Business valuations
  • Succession arrangements
  • International interests and jurisdictions

Professional Adviser Information

With your authority, we may collect information from or communicate with:

  • Accountants
  • Lawyers
  • Tax advisers
  • Banks
  • Wealth managers
  • Trustees
  • Corporate service providers
  • Immigration advisers
  • Other professional advisers
  1. HOW WE COLLECT INFORMATION

We may collect information:

  • Directly from you;
  • Through forms, questionnaires and strategic profiles;
  • During meetings, telephone calls and correspondence;
  • Through our website;
  • From documents that you provide;
  • From professional advisers where you have authorised us to communicate with them;
  • From publicly available sources where appropriate;
  • From organisations or individuals involved in providing services to you; and
  • From other lawful sources where permitted.

We will seek to collect only information that is relevant and reasonably necessary for the purpose for which it is being processed.

  1. WHY WE USE YOUR INFORMATION

We may process your information for purposes including:

  • Understanding your circumstances and objectives;
  • Conducting strategic reviews;
  • Mapping family, business, asset and international interests;
  • Identifying areas requiring further professional advice;
  • Coordinating with your existing professional advisers;
  • Introducing or coordinating appropriately qualified professional advisers where requested;
  • Providing agreed services;
  • Managing our relationship with you;
  • Communicating with you;
  • Preparing proposals, reports and strategic recommendations;
  • Carrying out appropriate due diligence;
  • Meeting legal and regulatory obligations;
  • Maintaining appropriate business and financial records;
  • Protecting our business, clients and systems; and
  • Managing disputes, complaints or legal matters.
  1. OUR LEGAL BASES FOR PROCESSING

Where applicable, we will rely on one or more lawful bases for processing personal information, including:

Contract

Where processing is necessary to enter into or perform an agreement with you.

Legal Obligation

Where we are required to process information to comply with applicable legal or regulatory obligations.

Legitimate Interests

Where processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights and interests.

Consent

Where we have asked for and obtained your consent to a particular form of processing.

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal of consent does not affect processing that took place before the withdrawal.

 

  1. SPECIAL CATEGORY AND SENSITIVE INFORMATION

In the course of a private-client relationship, information provided to FBV may sometimes include information requiring additional protection under applicable data protection legislation.

This may include information relating to matters such as:

  • Health or incapacity;
  • Family circumstances;
  • Identification information;
  • Political exposure;
  • Religious or philosophical considerations;
  • Criminal allegations or proceedings; or
  • Other information falling within protected categories.

We will only process such information where there is an appropriate lawful basis and, where required, an additional condition for processing.

We will seek to limit the collection and use of sensitive information to what is reasonably necessary for the relevant purpose.

  1. INFORMATION ABOUT OTHER PEOPLE

Our clients may provide information concerning family members, beneficiaries, business partners, advisers or other connected persons.

You should not provide personal information about another person unless you are entitled or authorised to do so, or there is another lawful basis for providing it.

Where appropriate, FBV may ask you to confirm your authority to provide such information.

  1. SHARING INFORMATION

We do not sell personal information.

We may share information where necessary and appropriate with:

  • Professional advisers;
  • Lawyers and accountants;
  • Tax advisers;
  • Banks and financial institutions;
  • Wealth managers and investment professionals;
  • Trustees and corporate service providers;
  • Immigration or relocation advisers;
  • Other professional service providers;
  • Technology and IT service providers;
  • Compliance and due-diligence providers; and
  • Regulators, government authorities or law-enforcement bodies where legally required.

Where you have specifically authorised FBV to contact your existing advisers, we will use that authority to facilitate appropriate communication and coordination.

FBV does not have authority to give instructions to your existing advisers, operate your accounts or make regulated legal, tax, investment or financial decisions on your behalf unless separately and lawfully authorised to do so.

 

  1. INTERNATIONAL TRANSFERS

Because FBV works with clients, businesses and professional advisers with international interests, personal information may need to be transferred to or accessed from jurisdictions outside the Isle of Man.

Where this occurs, FBV will take appropriate steps to ensure that such transfers are made in accordance with applicable data protection requirements and that appropriate safeguards are used where required.

 

  1. DATA SECURITY

We take reasonable technical and organisational measures to protect personal information against:

  • Unauthorised access;
  • Unauthorised disclosure;
  • Loss;
  • Destruction;
  • Accidental alteration; and
  • Misuse.

Access to client information will be limited to individuals and service providers who reasonably require access for legitimate purposes.

However, no electronic transmission or storage system can be guaranteed to be completely secure.

 

  1. HOW LONG WE KEEP YOUR INFORMATION

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including to:

  • Provide services;
  • Maintain appropriate client records;
  • Meet legal, regulatory and accounting requirements;
  • Establish or defend legal claims;
  • Resolve disputes; and
  • Maintain appropriate business records.

Retention periods may vary depending on the type of information and the nature of our relationship with you.

Where information is no longer required, we will take appropriate steps to securely delete, destroy or anonymise it, subject to applicable legal or regulatory requirements.

 

  1. YOUR DATA PROTECTION RIGHTS

Subject to applicable law and any relevant exemptions, you may have rights including:

  • The right to be informed about how your information is processed;
  • The right to request access to personal information we hold about you;
  • The right to request correction of inaccurate or incomplete information;
  • The right to request restriction of processing in certain circumstances;
  • The right to object to certain processing;
  • The right to request deletion of information in certain circumstances;
  • The right to data portability where applicable;
  • The right to withdraw consent where processing is based on consent; and
  • Rights relating to certain automated decision-making and profiling.

These rights are not absolute and may be subject to legal or regulatory limitations.

 

  1. HOW TO EXERCISE YOUR RIGHTS

If you would like to exercise a data protection right or ask a question about how FBV handles your information, please contact:

Fresh Business Ventures Ltd
The Engine House, Alexandra House, Castletown, Isle of Man. IM9 1TG

Telephone: 01928 787 603

Please provide sufficient information to allow us to identify you and understand your request.

We may need to verify your identity before responding to a request.

  1. COMPLAINTS

If you have concerns about how FBV has handled your personal information, we encourage you to contact us first so that we can investigate and seek to resolve the matter.

You also have the right to contact the Isle of Man Information Commissioner, the independent authority responsible for information rights and data protection in the Isle of Man.

Isle of Man Information Commissioner
PO Box 69
Douglas
Isle of Man
IM99 1EQ

 

  1. COOKIES AND WEBSITE INFORMATION

Our website may use cookies and similar technologies to operate the website, understand how visitors use it and, where appropriate, improve our services.

Where required, we will obtain appropriate consent before using non-essential cookies or similar technologies.

Further information may be provided in our Cookie Policy.

 

  1. DIRECT MARKETING

Where permitted by applicable law, FBV may contact existing clients or prospective clients regarding relevant services, events, publications or business developments.

Where consent is required, we will obtain it.

You may opt out of marketing communications at any time by contacting us or using the unsubscribe mechanism included in the relevant communication.

 

  1. THIRD-PARTY WEBSITES

Our website or communications may contain links to third-party websites.

FBV is not responsible for the privacy practices, security or content of third-party websites.

You should review the privacy policy of any third-party website before providing personal information.

 

  1. AUTOMATED DECISION-MAKING

FBV does not intend to make decisions producing legal or similarly significant effects on individuals solely through automated processing.

If this changes, we will provide appropriate information and safeguards as required by applicable data protection legislation.

 

  1. CONFIDENTIALITY

Privacy and confidentiality are fundamental to the way FBV works with clients.

Information provided to FBV in connection with a client engagement will be treated as confidential and handled only for legitimate business, service, legal, regulatory or administrative purposes.

Confidentiality does not prevent FBV from disclosing information where disclosure is required by law, regulation, court order, competent authority, or where necessary to protect FBV’s legal rights.

 

  1. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our services, technology, legal requirements or business practices.

The latest version will be made available through our website and will show the date on which it was last updated.

 

  1. CONTACT US

If you have questions about this Privacy Policy or how FBV processes personal information, please contact:

Fresh Business Ventures Ltd
The Engine House, Alexandra House, Castletown, Isle of Man. IM9 1TG

Telephone: 01928 787 603

Last Updated: 30 September 2026

 

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