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YOUR PRIVACY

When you visit any website, it may store or retrieve information on your
browser, mostly in the form of cookies. This information might be about you,
your preferences or your device and is mostly used to make the website work as
you expect it to. 

The information does not usually directly identify you, but it can give you a
more personalized web experience. Because we respect your right to privacy, you
can choose not to allow some types of cookies. Click on the different category
headings to find out more and change our default settings. However, blocking
some types of cookies may impact your experience of the site and the services we
can offer.

View Website Privacy Notice 




ESSENTIAL COOKIES

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These cookies are necessary for the website to function and cannot be switched
off in our systems. They are usually only set in response to actions made by you
which amount to a request for services, such as setting your privacy
preferences, logging in or filling in forms.

You can set your browser to block or alert you about these cookies, but some
parts of the site will not then work. These cookies do not store any personally
identifiable information.

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FUNCTIONAL COOKIES

Functional Cookies

These cookies allow us to know which pages are the most and least popular and
see how visitors move around the site. All information collected is anonymous
unless you provide personal information to us. 

If you do not allow these cookies we will not know when you have visited our
site, and will not be able to monitor its performance.

They may also be used to personalize your experience on our website by
remembering your preferences and settings.




ANALYTICS COOKIES

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this information on to our trusted third parties so that they can advertise our
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All information these cookies collect is aggregated and therefore anonymous. No
personal information is shared with third parties. 


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PRIVACY


PEACE OF MIND




WHY AND HOW WE HANDLE PERSONAL INFORMATION

Many countries have data protection laws that protect the privacy of individuals
by regulating the way in which businesses handle personal information, as well
as requiring businesses to be open and transparent about why and how they handle
personal information, among other things.

Our Client Privacy Notices, linked below, provide a general explanation of why
and how we handle personal information relating to our clients, business
contacts and other persons in connection with the client-facing business we
conduct:

 * Client Privacy Notice – Legal Services (Asia). This notice applies to the
   legal services we provide through our partnerships in Hong Kong and
   Singapore.
   
   
 * Client Privacy Notice – Legal Services for Private Clients based in China. 
   (Simplified Chinese | Traditional Chinese)  This notice applies to the legal
   services we provide to private individuals who are residents of mainland
   China, through our partnerships which practice BVI law and/or Cayman Islands
   law.

 * Client Privacy Notice – Legal Services (BVI). This notice applies to the
   legal services we provide through our partnership in the British Virgin
   Islands.

 * Client Privacy Notice – Legal Services (Cayman). This notice applies to the
   legal services we provide through our partnership in the Cayman Islands.

 * Client Privacy Notice – Legal Services (Europe). This notice applies to the
   legal services we provide through our partnerships and other entities in
   Europe, Jersey and the United Kingdom.

 * Client Privacy Notice – Legal Services (DIFC). This notice applies to the
   legal services we provide through our partnership in the Dubai International
   Financial Centre.
   
   
 * Client Privacy Notice – Private Client Services for Private Clients based in
   China.  (Simplified Chinese | Traditional Chinese)  This notice applies to
   the private trust services and other related fiduciary services we provide to
   private individuals who are residents of mainland China, through our
   fiduciary services division’s Hong Kong office.  

 * Client Privacy Notice – Fiduciary Services (Hong Kong). This notice applies
   to the fiduciary services and related services, such as entity formation /
   registration services, registered office services and corporate secretarial
   services we provide in Hong Kong.

 * Client Privacy Notice – Fiduciary Services (Singapore). This notice applies
   to the fiduciary services and related services, such as entity formation /
   registration services, registered office services and corporate secretarial
   services we provide in Singapore.

 * Client Privacy Notice – Fiduciary Services (BVI). This notice applies to the
   non-legal services we provide in the British Virgin Islands.

 * Client Privacy Notice – Fiduciary Services (Cayman). This notice applies to
   the fiduciary services and related services, such as entity formation /
   registration services, registered office services and corporate secretarial
   services we provide through our entities in the Cayman Islands.

 * Client Privacy Notice – Fiduciary Services (Europe). This notice applies to
   the fiduciary services and related services, such as entity formation /
   registration services, registered office services and corporate secretarial
   services we provide through our European entities.

 * Client Privacy Notice – Fund Services (Hong Kong). This notice applies to the
   fund administration and related services we provide in Hong Kong.

 * Client Privacy Notice – Fund Services (Singapore). This notice applies to the
   fund administration and related services we provide in Singapore.

 * Client Privacy Notice – Fund Services (Cayman). This notice applies to the
   fund administration and related services we provide through our entities in
   the Cayman Islands.

 * Client Privacy Notice – Fund Services (Europe). This notice applies to the
   fund administration and related services we provide through our European
   entities (excluding MPMF Fund Management (Ireland) Limited).

 * Client Privacy Notice – Fund and Fiduciary Services (ADGM+DIFC). This notice
   applies to the fund administration service, entity formation / registration
   service, registered office service and corporate secretarial service, and
   other related services we provide in the Abu Dhabi Global Markets and the
   Dubai International Financial Centre.

 * Client Privacy Notice – Compliance Services (Cayman). This notice applies to
   the AML compliance service and related services we provide through Maples
   Compliance Services (Cayman) Limited in the Cayman Islands. 

 * Client Privacy Notice – MPMF Fund Management (Ireland). This notice applies
   to the fund management services we provide through MPMF Fund Management
   (Ireland) Limited in Ireland.

 * Client Privacy Notice – Unit Trusts (Cayman). This notice applies where we
   act as trustees of unit trusts in the Cayman Islands, which are set up,
   sponsored, or promoted by our clients.

 * Client Privacy Notice – Maples Listing Services (Jersey). This notice applies
   to the various listing services provided by Maples Listing Services (Jersey).

Our Job Applicant Privacy Notice, linked below, describes how we handle personal
information relating to job applicants:

 * Job Applicant Privacy Notice (Asia). This notice applies to those applying
   for a job, summer internship or a work experience placement with one of our
   entities in Hong Kong or Singapore.

 * Job Applicant Privacy Notice (Europe). This notice applies to those applying
   for a job, summer internship or a work experience placement with one of our
   European, Jersey or UK entities.

 * Job Applicant Privacy Notice (Cayman+BVI). This notice applies to those
   applying for a job, summer internship or a work experience placement with one
   of our entities in the Cayman Islands or the British Virgin Islands.

 * Job Applicant Privacy Notice (Canada). This notice applies to those applying
   for a job, summer internship or a work experience placement with one of our
   entities in Canada.  Cliquez ici pour voir la version française.

 * Job Applicant Privacy Notice (DIFC). This notice applies to those applying
   for a job, summer internship or a work experience placement with one of our
   entities in the Dubai International Financial Centre. 

The Privacy Notices linked below explain why and how we handle personal
information relating to visitors to our website and web applications:

 * Website Privacy Notice. This notice applies to our main website
   at www.maples.com and includes an explanation of how we make use of cookies
   and similar devices.

 * Maples Secure File Privacy Notice. This notice only applies to Maples Secure
   File, our secure file sharing platform which can be accessed
   from securefile.maples.com.

 * Maples Entity Services Portal Privacy Notice.  This notice applies to
   eServices and Phoenix, the online portals our clients use to access their
   information, which can be accessed from www.mapleseservices.com and
   phoenix.maples.com respectively.


THE ASSURANCES WE OFFER WHERE WE ACT AS A 'PROCESSOR'

In European countries, where the General Data Protection Regulation (GDPR) and
equivalent legislation applies, businesses that engage a service provider that
acts as a 'processor' are legally required to ensure that the service contract
contains certain contractual assurances.  Similar requirement applies in other
jurisdictions as well, including the British Virgin Islands (Data Protection Act
2021 or "DPA"), the Cayman Islands (Data Protection Law 2017 or "DPL"), Hong
Kong (Personal Data (Privacy) Ordinance or "PDPO"), Singapore (Personal Data
Protection Act 2012 or "PDPA"), the Abu Dhabi Global Markets (Data Protection
Regulations 2021 or "ADGMDPR"), and the Dubai International Financial Centre
(Data Protection Law 2020 or "DIFCDP").

Our Data Processing Addendum (Europe), linked below, contains the assurances we
offer to our clients in accordance with Article 28 of GDPR, and, unless
specifically agreed otherwise, it applies to all client engagements of our
European entities where we act as a 'processor' in providing our services.

 * Data Processing Addendum (Europe), applicable from 25 May 2018 until 31 July
   2021.
 * New Data Processing Addendum (Europe), applicable from 1 August 2021.

Where appropriate and necessary, our Data Processing Addendum (Europe) can be
offered to our clients outside Europe who are serviced by our non-European
entities.  This may be the case, for example, where such clients trigger the
extra-territorial effect of GDPR by offering their products / services to
European residents.

Our Data Processing Addendum (BVI), linked below, contains the assurances we
offer to our clients in accordance with DPA, section 10(2).  Unless specifically
agreed otherwise, it applies from 1 September 2021 to all client engagements of
our entities in the British Virgin Islands where we act as a 'processor' in
providing our services.

 * Data Processing Addendum (BVI)

Our Data Processing Addendum (Cayman), linked below, contains the assurances we
offer to our clients in accordance with DPL, Schedule 1, Part II, paragraph 3. 
Unless specifically agreed otherwise, it applies from 30 September 2019 to all
client engagements of our Cayman entities where we act as a 'processor' in
providing our services.

 * Data Processing Addendum (Cayman)

Our Data Processing Addendum (Asia), linked below, contains the assurances we
offer to our clients in accordance with PDPO / PDPA, and, unless specifically
agreed otherwise, it applies from 1 May 2020 to all client engagements of our
entities in Hong Kong and Singapore where we act as a 'data processor' or 'data
intermediary' in providing our services.

 * Data Processing Addendum (Asia)

Our Data Processing Addendum (ADGM+DIFC), linked below, contains the assurances
we offer to our clients in accordance with ADGMDPR and DIFCDPL, and, unless
specifically agreed otherwise, it applies from 1 July 2020 to all client
engagements of our entities in the Dubai International Financial Centre, and
from 1 April 2021 to all client engagements of our entities in the Abu Dhabi
Global Markets, where we act as a 'Processor' in providing our services.

 * Data Processing Addendum (ADGM+DIFC)

Please note that when we provide legal services, director services, AML
services, fund management services, and other like services which we provide by
exercising our professional autonomy and discretion, we will not enter into
addendums or agreements that seek to impose the requirements of Article 28 of
GDPR or other equivalent requirements (including those that are imposed under
DPL, PDPO, PDPA, or DIFCDPL) on us.


RESTRICTION ON CROSS-BORDER DATA TRANSFER

In European countries where GDPR and equivalent legislation applies, businesses
that allow personal information to be handled outside Europe are generally
required to take steps to ensure that the personal information sent outside
Europe (or accessed from outside Europe) continues to be protected to the same
European standard.

We can offer to enter into the relevant, prevailing form of EU standard
contractual clauses (either the 'controller-to-controller' form or the
'controller-to-processor' form) to address this restriction, where it is
appropriate and necessary to do so.  This may be the case where our clients
inside Europe need to share personal information with our non-European entities,
or where our clients outside Europe need to share personal information that was
sourced from Europe with our non-European entities.  

In some non-European jurisdictions, the applicable data protection law imposes a
similar restriction on the cross-border transfer of personal information, and
the local regulators sometimes endorses the use of EU standard contractual
clauses.  Accordingly, we can also offer to enter into the relevant, prevailing
form of EU standard contractual clauses where this is appropriate and necessary
to address the requirements of a non-European data protection law. 


CLARIFICATION REGARDING DUE DILIGENCE CHECKS

The nature of the services we provide means that we regularly have to conduct
due diligence checks on individuals who are directly or indirectly affected by
the services we provide.  Such checks can, depending on the context, include the
so-called “KYC Checks” (which are mandated by laws that tackle money laundering,
terrorist financing etc. and typically involves checking someone’s identity,
source of wealth, any legal restriction applicable, etc.), the so-called
“FATCA/CRS Checks” (which are mandated by laws that tackle tax evasion and
typically involves checking someone’s identity, nationality/residency, tax
status, accounts details, etc.), or both.

The nature of the services we provide also means that we frequently encounter
situations where we have to conduct the same due diligence checks (KYC Checks,
FATCA/CRS Checks, or both) multiple times in respect of the same person (e.g. a
director/beneficial owner of a client entity, a private client, or an investor),
in connection with the services we provide to our clients.  

 * An investor subscribes to an investment fund that receives fund
   administration/AML compliance service from us (fund X) and subsequently
   subscribes to another investment fund that also receives fund
   administration/AML compliance service from us (fund Y).  Because fund X and
   fund Y each has its own legal requirement to conduct investor due diligence,
   Maples has to repeat the due diligence checks on behalf of fund Y, even if
   Maples has already completed the due diligence checks in relation to the same
   investor on behalf of fund X.

 * A director is newly appointed to the board of a SPV which was established by
   a client of Maples and which receives a range of services from Maples
   (SPV1).  The same director is subsequently appointed to the board of a new
   SPV which Maples incorporates on behalf of a different client (SPV2). 
   Because SPV1 and SPV2 each has its own legal requirement to conduct director
   due diligence, Maples has to repeat the due diligence checks on behalf of
   SPV2, even if Maples has already completed the due diligence checks in
   relation to the same director on behalf of SPV1. 

This can result in directors/beneficial owners of client entities, private
clients, investors, and other relevant persons receiving identical or very
similar requests for due diligence checks from us, repeatedly.  In turn, this
can inconvenience such persons, reduce our operational efficiency, and result in
unnecessary and excess collection of personal information by us, without
providing any additional benefit to our clients.

In order to address these issues, from August 2019 onwards, the Maples Group
will start sharing due diligence information/documentation supplied by the
relevant individuals (or compiled in respect of the relevant individuals based
on such information/documentation) across different clients and service lines of
the Maples Group, provided that we have secured the prior consent of the
relevant individuals.  

We will revise the relevant documentation and business processes to ensure that
the relevant individuals who interact with us are given the opportunity to opt
into have their due diligence information/documentation reused for the purpose
of additional due diligence we may be required to conduct on them on behalf of
our clients.  We will also be looking to reach out to those relevant individuals
who already benefit from the services we provide.

As a general rule, we do not rely on 'consent' as a legal basis to handle
personal information which our clients entrust to us and this is reflected in
our various Client Private Notices.  The reuse of due diligence
information/documentation for the purpose of performing additional due diligence
checks on behalf of multiple different clients will be an exception to this
general rule, as it will be performed only where the relevant individuals give
their consent.

Please note that where we conduct due diligence checks to fulfil our own legal
obligations, we reserve the right to share the due diligence
information/documentation we obtain, internally for our own compliance purposes
(provided that there is no legal or contractual restriction which prevents us
from doing so), and we will not be relying on 'consent' in doing so.  For
example, if a client receiving legal services from Maples and Calder requests
that we provide fund services as well, then Maples Fund Services may reuse the
due diligence information documentation previously obtained from the client by
Maples and Calder.



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