Privacy Notice

1. Who We Are

In this notice, “Averell,” “we,” and “us” refer to the Averell businesses responsible, as controllers, for personal data collected through averell.com:

• Tracy Wong, trading as Averell, registered in the Monaco Trade and Industry Register (RCI) under number 26P10982, Le Panorama, 57 Rue Grimaldi, 98000 Monaco;
• Averell Ltd, a private limited company registered in England and Wales under company number 16502545, with its registered office at 96 Kensington High Street, London W8 4SG, in respect of personal data handled by our London office; and
• Averell LLC, a Florida limited liability company, document number L25000267065, 121 Alhambra Plaza, Coral Gables, Florida 33134, in respect of personal data handled by our Miami office.

Questions about this notice may be sent to averell@averell.com.

2. The Information We Collect

• Information you provide: your name, email address, telephone number (if given), and the content of your message when you submit an enquiry or contact us.
• Information collected automatically: your IP address, browser type, device information, and the pages you visit, collected through strictly necessary cookies and, only where you consent, analytics cookies (see our Cookie Notice).
• Information required before an engagement: where you become a client, the identity and source-of-wealth information required for our client acceptance checks. This processing is also governed by our engagement letter.

We do not seek sensitive information (such as health data or political opinions) through this website. Please do not include it in your enquiry.

3. How We Use Your Information and Our Legal Basis

• To respond to your enquiry and arrange an initial conversation: steps taken at your request before entering into an engagement, and our legitimate interest in responding to enquiries.
• To carry out identity and source-of-wealth checks before accepting an engagement: compliance with our legal obligations and our legitimate interest in managing risk.
• To operate, secure, and maintain the website: our legitimate interest in providing a secure website. Analytics cookies are used only with your consent.
• To comply with law, regulation, and lawful requests from competent authorities: compliance with our legal obligations.

We do not sell personal data, we do not use it for marketing without your consent, and we do not make decisions about you by automated means.

4. Who We Share Your Information With

We share personal data only where necessary and on a confidential basis with: our service providers (such as website hosting, email, and IT support), under written data protection terms; our professional advisors, such as lawyers and auditors; with your agreement, the licensed professionals engaged in connection with your matter; and competent authorities where required by law. Personal data may be shared between Averell’s offices in Monaco, the United States, and the United Kingdom in order to respond to you.

5. International Transfers

Because Averell operates in Monaco, the United States, and the United Kingdom, your personal data may be transferred outside the country in which it was collected. Where data is transferred to a country that does not provide an equivalent level of protection, we use appropriate safeguards, such as standard contractual clauses, or rely on another basis permitted by applicable law. You may request details of these safeguards by contacting us.

6. How Long We Keep Your Information

Enquiries that do not lead to an engagement are deleted within 24 months of our last contact with you. Client records, including client acceptance records, are kept for the period required by applicable anti-money laundering, tax, and record-keeping laws, after which they are securely deleted.

7. Security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. Access is limited to those who need it to respond to you or to perform our services.

8. Your Rights

Depending on where you live, you may have the right to access your personal data; to have it corrected or erased; to restrict or object to its processing, including processing based on our legitimate interests; to receive it in a portable format; and to withdraw your consent at any time, without affecting processing carried out before withdrawal. To exercise any of these rights, contact averell@averell.com. We will respond within one month, which may be extended where permitted by law, and we may need to verify your identity before doing so.

9. Complaints

If you have a concern, please contact us first so that we can address it. You also have the right to complain to a data protection authority: in Monaco, the Autorité de Protection des Données Personnelles (APDP); in the United Kingdom, the Information Commissioner’s Office (ICO); and in the European Union, the data protection authority of the country in which you live or work.

10. Changes to This Notice

We may update this notice from time to time. The current version is always available on this page, with the date on which it was last updated.