This policy sets out how FIM Capital, as a data controller, treats any data it holds in relation to you either as an applicant for business or an existing client.
We recommend you read this notice to ensure you are fully aware of who holds your data and your rights under the EU General Data Protection Regulation.
FIM has an obligation to only hold information that is
- Processed lawfully, fairly and in a transparent manner;
- Collected for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes;
- Adequate, relevant and limited to what is necessary;
- Accurate and, where necessary, kept up to date;
- Kept in a form that permits identification of data subjects for no longer than is necessary;
- Processed in a manner that ensures appropriate security of the personal data including protection against unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
In entering into a contract for services with FIM Capital Limited you are agreeing to the legitimate use of your personal data by us. If you do not consent you must inform us immediately.
The policy will cover:
- What information is collected and why
- Who is collecting it
- How is it collected
- How will it be used
- How long will it be kept
- Who it will be shared with
- How the information will be kept secure
- Your rights, including how to access and update information
If you have any questions in relation to this notice, please contact our Data Protection Officer.
Mrs Julie Haslett
Email – firstname.lastname@example.org
FIM Capital Limited, IOMA House, Hope Street, Douglas, Isle of Man, IM1 1AP
- What information is collected and why?In order to establish a client relationship with you we are obliged under various Isle of Man Legislation and guidance to verify your identity. We will do this by asking you to provide documents such as an application form (for investment management services) a copy of your passport or identity card, proof of your address and tax status and the source of your investment funds and general wealth. We may also refer to specific online data bases or websites to assist us in verifying the information you have provided. When you telephone FIM please note that your call may be recorded.
- How is it collected?The information will be provided by you direct or via an agent acting on your behalf. Normally this will be by post, however, more recently emailed and scanned documents have been deemed acceptable in certain circumstances.
- How will it be used?We will use the data to establish an account in your name and to manage that account going forward, including providing updates or information in relation to your account, our services, the investment markets or changes to our terms and conditions. You have the option on your application form to confirm how you wish us to contact you and can update these preferences at any time by contacting us.
- How long will it be kept?Isle of Man Regulations state that information must be retained for at least 6 years from the end of your relationship with FIM. If appropriate after that time, it will be destroyed so that it is not retained for longer than necessary.
- Who it will be shared with?We may disclose your personal information to our agents, nominees, custodians and our associates for the purposes of effectively managing your account with us. We will not share your information with any other third party unless obliged to do so by law.
- How the information will be kept secure?FIM has safeguards in place to ensure all personal information held electronically is retained securely and tests that these safeguards are sufficiently robust on a regular basis. All paper based personal information is held in locked cabinets. Only authorised staff, our auditors and / or our regulators are able to view your information.
- Your rights, including how to access and update informationYou have the following rights in relation to the personal information we hold about you.
- Right of access – should you ask us in writing we will provide you with a copy of all personal data held in relation to you. We will acknowledge your request and advise you of a timeframe for supplying the information.
- Right to rectification – If you believe the personal data relating to you is inaccurate you can apply to have it amended.
- Right of erasure (right to be forgotten) – you can apply to have your data with us erased, once your account is closed under certain circumstances as long as it does not conflict with any of our compliance under Isle of Man law.
- Right to restriction of processing – you may restrict the way in which we use your data under certain circumstances.
- Right of data portability – you can request that we provide your personal data, or aspects of it, to a third party nominated by you.
- Right to object to processing – you can object to automated profiling (note this is not used by FIM).
- Right to complain – you have the right, should you believe that your personal data has not been handled correctly, to complain to either our Data Protection Officer or directly to the Supervisory Authority, The Information Commissioner at First Floor, Prospect House, Prospect Hill, Douglas, Isle of Man, IM1 1ET.
Should you wish to exercise any of your rights please contact our Data Protection Officer, ideally in writing (including electronic formats) with details. Equally FIM has the right under the Regulations to refuse a request from you where it is deemed excessive or unmerited; if this is the case we will respond to you in writing justifying our decision.