1. Introduction
First Elite Trust Bank (“the Bank,” “we,” “us,” or “our”) is committed to protecting the confidentiality, integrity, and security of your personal and financial data. This Privacy Policy explains how we collect, use, store, disclose, and protect your personal information in accordance with applicable U.S. laws (such as the Gramm-Leach-Bliley Act and California Consumer Privacy Act), international laws (including the General Data Protection Regulation (GDPR) in the European Union), and other global privacy standards.
Our services are strictly private, by-invitation-only, and designed exclusively for qualified High-Net-Worth Individuals (HNWI), Ultra-High-Net-Worth Individuals (UHNWI), family offices, and institutional clients.
2. Information We Collect
We collect only the information necessary to provide bespoke financial services, comply with regulatory obligations, and manage risk appropriately. The types of information we collect include:
2.1 Personal Identification Information
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Full legal name
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Date of birth
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Social Security Number / Tax Identification Number
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Government-issued identification (e.g., passport, driver’s license)
2.2 Contact & Communication Data
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Physical and mailing addresses
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Email addresses
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Phone numbers
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Preferred communication channels
2.3 Financial Information
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Bank account and investment portfolio details
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Source of wealth and income
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Credit history and liquidity status
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Lending history and risk profile
2.4 Due Diligence & Compliance Data
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KYC/AML documents
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FATCA/CRS declarations
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Beneficial ownership structures
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Legal entity information
2.5 Digital Interaction Data
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IP addresses
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Device information
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Login credentials and access logs (for digital platforms)
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Communications history, including emails, messages, and call recordings (where permitted)
3. How We Use Your Information
We use the information we collect for lawful business and compliance purposes, including:
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Client onboarding and identity verification
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Providing tailored financial and banking services
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Performing credit, risk, and legal assessments
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Complying with legal, regulatory, and tax obligations
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Preventing fraud, money laundering, and other financial crimes
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Communicating updates, performance insights, and strategic advice
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Conducting internal analytics and operational enhancements
4. Legal Basis for Processing
We process your personal data under the following legal bases:
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Contractual Necessity – to fulfill our agreements with you.
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Legal Obligation – to comply with applicable laws and regulations.
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Legitimate Interest – to manage our business effectively and safeguard client trust.
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Consent – where required, for specific marketing or data-sharing purposes.
For clients subject to the GDPR, we ensure that all data processing adheres to Articles 6 and 9 of the regulation.
5. Information Sharing and Disclosure
We do not sell, rent, or trade your personal information. Information is disclosed strictly under these conditions:
5.1 Internal Use
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Shared among authorized departments within the Bank on a need-to-know basis, bound by strict confidentiality.
5.2 Third-Party Vendors
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Secure sharing with trusted third-party service providers (e.g., custodians, auditors, IT vendors), bound by data protection agreements and confidentiality clauses.
5.3 Legal & Regulatory Disclosure
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When required by law or requested by regulatory bodies (e.g., IRS, SEC, FINRA, FATF-compliant bodies).
5.4 International Transfers
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For clients or services outside the U.S., personal data may be transferred across borders, but always in compliance with the applicable laws (e.g., GDPR Standard Contractual Clauses, U.S.-EU Data Privacy Framework).
6. Data Retention
We retain client information only for as long as is necessary for the purposes outlined in this policy, including:
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The duration of the client relationship
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The period required by tax, legal, and regulatory obligations
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Statutory limitation periods for legal claims
Retention periods typically range from 7 to 10 years after relationship termination, unless longer periods are required by law or litigation.
7. Data Security Measures
We employ industry-leading physical, digital, and procedural safeguards to protect your information, including:
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256-bit AES encryption for all stored data
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SSL/TLS for all communications
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Biometric and multi-factor authentication
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Access controls and audit logs
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Encrypted offsite and cloud backups
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Regular third-party penetration testing and vulnerability scans
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Employee training and access limitation by role
8. Your Rights
Depending on your jurisdiction, you may have the following rights concerning your data:
8.1 United States (including California residents)
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Right to know what data we collect and how we use it
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Right to access and receive a copy of your data
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Right to request deletion of personal data (subject to legal exceptions)
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Right to opt out of data sharing for non-essential services
8.2 European Union (GDPR)
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Right to access, rectify, or erase your data
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Right to restrict or object to processing
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Right to data portability
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Right to lodge a complaint with a supervisory authority
To exercise any of these rights, please email us at [email protected]. Verification of identity will be required.
9. Cookies and Online Tracking
Our digital platforms may use cookies or other tracking technologies to enhance user experience, optimize site performance, and maintain session security. We do not use behavioral advertising, third-party analytics sharing, or remarketing tools.
You may control cookie preferences via your browser settings.
10. Children’s Privacy
Our services are not directed to, and we do not knowingly collect data from, individuals under the age of 18.
11. Changes to This Privacy Policy
We reserve the right to amend this Privacy Policy at any time. Clients will be notified of significant changes through direct communication or system notices. Continued use of our services after any updates constitutes acceptance of the revised policy.
12. Contact and Queries
For questions, data requests, or complaints regarding this Privacy Policy, please contact:
First Elite Trust Bank
Privacy Compliance Office
37th Floor, General Motors Building
Fifth Avenue, New York City, NY 10022
Email: [email protected]