Governance People Policy

1) Our Details

Governance People Limited, a company incorporated in the Isle of Man,  with company number 132347C and registered office at 1 The Church View, Braddan, Isle of Man IM4 4TF.

You can contact us by telephone on +44 7624 200355 or by email to info@governancepeople.com with the subject title FAO: Data Protection Officer.

2) Information Collection

We call data that identifies or could reasonably be used to identify you as an individual ‘Personal Data’. This includes information about you that you give us by registering for a course, filling in forms on this site, or by corresponding with us by phone, live web chat, email or otherwise. This information may include your full name, job title and contact details including your email address and telephone number.

If you complete a course on our web based platform (learning management system) we may also collect data about your progress in the course, the answers you provide to questions, and the score you achieve.

We do not collect or process any special categories of Personal Data.

3) Your Information and How We Use It

We collect your data, including Personal Data, for certain legitimate business interests of ours, AILO or that of your employer. Processing under this basis may occur in the following circumstances:

• When you make a request for further information on our website, either through a demo form, live web chat, contact form or similar transmission, we will use the data you provide to fulfil your request for information. We will also store this information on our database and use it to follow up with you, either by telephone or through an electronic communication.
  
• When you register on our website, we will use the data provided to give you access to resources on the website.
  
• When you or your employer registers you for a course that runs on our website.
  
•  When you subscribe to our newsletter, your email address will be stored with our third party processor, MailChimp, and we will use this to fulfil your subscription request.
  
• Where you have provided us with your details, we may contact you to notify you of changes to our services.
  

When you register on our website, you are also given the opportunity to provide us with your consent. If you choose to do this, then we will use the Personal Data provided with your registration to let you know about our products and services which we think you will find interesting. You will be able to access resources on the website and will be sent relevant email notifications based on your interests. We may also contact you by telephone.

You can subsequently withdraw your consent at any time by contacting us, or following the ‘unsubscribe’ link that is provided in newsletter emails from Governance People Limited.

Any information that we process, including Personal Data, will be stored on a secure server. We will not retain your Personal Data for longer than is necessary for the processing. Where you have registered and provided your consent to receive communications from us, then we will retain your Personal Data for this purpose until your consent is withdrawn.

4) Where Will Your Information Be Shared?

We use third party processors to assist us in storing your data safely and securely while interacting with our websites. These third parties are carefully screened so we can ensure that there are adequate controls in place and, where relevant, that such third parties are GDPR compliant. Additionally, where this would result in the transfer of Personal Data outside the EEA, we have confirmed that there are appropriate transfer mechanisms in place.

Our third party processors include:

• Microsoft Office 365

If the course that was purchased is a product from a third-party provider, the data held within our Learning Management System may be shared with that provider once you start accessing the course.

We share all data with your employer (AILO Member) in the form of course registration and progress reports. 

All data is shared with the Association of International Life Offices (AILO).

5) Your Rights

Under the EU General Data Protection Regulation, you possess a number of rights in relation to your Personal Data. These rights include (i) the right to be informed; (ii) the right of access; (iii) the right to rectification; (iv) the right to erasure; (v) the right to restrict processing; (vi) the right to data portability; (vii) the right to object; and (viii) rights in relation to automated decision making and profiling. We are committed to upholding these rights. If you wish to exercise any of these rights, please contact us using the details below.

Where you have provided us with consent, you have the right to withdraw this consent at any time. To reiterate, you can do this at any time by contacting us directly or following the ‘unsubscribe’ link provided in any electronic communications you receive from us.

You also have the right to complain to a supervisory authority where you feel that our processing of your Personal Data has infringed your rights.

6) Accessing Your Information

If you wish to exercise your right of access, then you may make a subject access request by contacting us as per the below. In most cases, we will not charge you a fee and will respond within one month. Fees may be charged for repeated or vexatious requests and we may take two months to provide all information in response to particularly complex requests. We will let you know if this is the case.

7) Cookies

Our site uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our site.

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser. They enable the site or service provider systems to recognise your browser and capture and remember certain information, such as items saved in your online shopping basket.

Any data gathered through the use of cookies will not identify you personally. It is strictly aggregate statistical data about our visitors and how they used the resources on this web page. No Personal Data will be shared at any time via cookies.

You may choose to decline all cookies on your computer. Your browser has an option to disable the use of cookies. If you do choose to decline cookies, then you may be limited to certain areas of our website.

8) Third Party Links

We may sometimes include or offer third party products or services on our website. The websites of these third parties will have separate and independent privacy policies, with which you should familiarise yourself. We bear no responsibility or liability for the content and activities of these third-party sites. Nonetheless, we seek to protect the integrity of our website and welcome any feedback regarding these third-party websites.

This Privacy Policy was last updated in 1 October 2025.

All users are also required to agree to the standard AILO policy as follows:

PRIVACY STATEMENT

FOR AILO MEMBERS

ASSOCIATION OF INTERNATIONAL LIFE OFFICES

 

LAST UPDATED: 1 October 2025                        

Under the GDPR and LED Implementing Regulations 2018 and the Data Protection Act 2018, an Act of Tynwald (collectively the “Law”), organisations which handle personal information (as defined in the Law) have legal responsibilities in relation to that information and what they do with it.

Who we are

AILO (referred to in this policy as “we” and “us”) is the Association of International Life Offices. We are an unincorporated association based in the Isle of Man and operating internationally. Our contact details can be found in the “Contact Us” section of this website.

Data Processing

For the purposes of the Law, we are the ‘data controller’. We are committed to protecting and respecting your privacy. This policy (together with our website terms and conditions and any other documents referred to on our website) sets out the basis on which we will process any personal data we collect from you or which you provide to us. Please read these documents carefully to understand our practices regarding your personal data.

Where you submit personal data to us, you do so on the basis that it will be processed in accordance with this Privacy Policy as amended from time to time. Where you submit personal data on behalf of someone else, you should only do so on the basis that that the processing of his or her personal data, will be in accordance with this privacy policy and to your receiving on his or behalf any data protection notices which we issue

Information we may collect from you

We may collect and process the following data about you, which is necessary for purposes of the legitimate interests pursued by us:

• Information which you provide by filling in forms on our website at www.ailo.org, both on our home page and at all other web pages which form part of our website (the “Site”). This includes information provided at the time of registering to use the Site, subscribing to our services, posting material on our Site or requesting further services. We may also ask you for information when you report a problem with our Site.
• If you contact us, we may keep a record of that contact and related correspondence.
• We may also ask you to complete surveys which we will use for research purposes. Responses supplied by you may be used by us for purposes including, but not limited to, publicity, representation, education and compiling market trend data. However, any such data supplied by you will be treated confidentially, will not be attributable to you and will only be published when combined with other Members’ data.
• Details of transactions which you carry out through our Site and of the progress and completion of your transaction.
• Details of any participation by you in any promotions or competitions offered by us.
• Details of your visits to our Site including, but not limited to, traffic data, location data and other communication data, and the resources that you access.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the Isle of Man, including, but not limited to Belgium, Ireland, Liechtenstein, Luxembourg, and the United Kingdom. It may also be processed by individuals acting on behalf of us operating outside the Isle of Man who work for one of our members or suppliers. If your personal data is transferred outside of the Isle of Man or the European Economic Area we will take the required steps to ensure it has equivalent protection. Such suppliers may be engaged in, among other things, the processing, holding and storage of information, the supply of services, disaster recovery services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely by any such person and in accordance with this privacy policy.

All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Uses made of the information

We process personal information for the following purposes:

• To store it for AILO membership purposes including access to the Members’ Lounge.
• To ensure that content from our Site is presented in the most effective manner for you and for your computer.
• To provide you with information, products or services that you request from us or which we feel may interest you.
• To share with our Members if it is necessary to do so to respond to any matter you raise with us.
• To carry out our obligations arising from any contracts entered into between you and us.
• To allow you to participate in interactive features of our service, when you choose to do so.
• To notify you about changes to our services.
• To help us manage our business effectively, including in relation to administration, marketing, staff education, compliance with legal obligations and other operational needs.

Disclosure of your information

We may disclose your personal information to any third party data processor we appoint. We will only share and exchange your personal information with data processors who agree in writing to protect your personal information. We may also disclose your personal information where we are required to do so by law or by any regulatory or law enforcement body.

Keeping personal information

We will only store your personal information for as long as reasonably necessary for the purposes outlined in this policy. Personal data will be deleted when it is no longer required and at the latest when membership or your relationship with AILO has been terminated.

Links to other websites

Our Site contains hyperlinks to third party websites. Where hyperlinks are provided, these are for the convenience of users only. You should not regard provision of such hyperlinks or other similar mention of third parties on our Site as in any way representing an endorsement by us of such third parties. If you decide to enter into any kind of contractual arrangement or similar with a third party for whom a hyperlink appears on our Site, we recommend that you take steps to satisfy yourself regarding the goods or services offered by that third party and as to that third party’s data protection policies.

Your rights

• You have the right to see all personal information we hold on you. Should you wish to have access to all or a particular part of your personal information, please request this by emailing us at secretariat@ailo.org.
• We will give you access to personal data in accordance with the Law and any guidance issued by the Isle of Man Information Commissioner from time to time.
• You have the right to request access to and rectification or erasure of your personal data. If your information changes or you believe we have information which is inaccurate or not up-to-date please let us know and we will change it.
• You also have the right to object to the processing of your personal data and have the processing of your personal data restricted.
• In the first instance please contact the AILO Secretariat at secretariat@ailo.org with a request to change or remove any of the data we hold for you.

You may lodge a complaint with the Isle of Man Information Commissioner , who can be contacted at:

P.O. Box 69

Douglas

Isle of Man

IM99 1EQ

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and you should therefore review this page regularly. Where we are required to do so, we shall notify you of changes by e-mail.