Your personal privacy is important to us. We want you to feel secure that we handle your personal data in a responsible manner. This document explains how we collect and store your personal data and what rights you have.
Description of our processing of personal data
• Enter into and perform agreements relating to investment advice: We collect information provided to us by or on behalf of our business contacts, or generated by us before or in conjunction with the entering into or the performance of contracts concerning the provision of investment advice. This collection of data is based on our legitimate interest as an investment advisor when we provide services.
We also use personal data collected in connection with investment matters in order to fulfil our statutory duties, for example in the context of measures to combat money laundering and knowledge of our business contacts’ procedures.
The personal data collected relates to identification, contact information and case-related background information provided by our business contacts, their representatives or their counterparts.
In certain cases your personal data has been supplemented with information obtained from other sources, including searches via public search engines, sector-specific newsletters, social media and your employer’s website to verify your current professional position.
• Newsletters, publications, meetings and network of advisors: When you become registered as a contact with us or sign up to the mailing list for newsletters, we will use the information that you provided to us for the purpose in question, as well as for the provision of information and other communications. We use the personal data for these purposes until you inform us that you no longer wish to receive any information from us. You can do so at any time by clicking the unsubscribe link in any of our mailings or by contacting us at the e-mail address email@example.com.
This use of your personal data is based on our legitimate interest to provide inform about our activities or keep in touch with different stakeholders.
In conjunction with meetings where we serve food, we may collect your dietary and other preferences. Any such information provided by you will be immediately erased when we no longer have a reason to store the data.
• Cookies: We may also receive information about your use of our site through cookies that enable us to make certain parts of the website easier to use. When you visit the site, we may also collect information about your computer, your IP address, operating system and browser type, for example for statistical purposes or system administration. This information generally contains data that does not allow individual identification of information related to a specific user.
• Job and assignment applications: Personal data that you have provided through job and assignment applications of various kinds is stored in a separate system.
How is the personal data processed?
Segulah processes only personal data for the purposes for which it was collected as described above, and personal data is accessible only to authorised employees who have a position that requires them to process personal data in order to carry out their work. Personal data is not retained longer than necessary for the specific purpose. Segulah has taken appropriate technical and organisational measures to keep your personal data secure. We ensure that only authorised persons have access to your personal data. We also have an internal policy for secure processing of personal data.
Where is the personal data processed?
Segulah’s intention is for all personal data to be processed within the EU/EEA. It may however happen that some suppliers process personal data outside the EU/EEA. In such cases, we ensure that the data is protected and that safeguards are in place through agreements which impose the same requirements as regulations within the EU.
Is personal data transmitted to third parties?
We will not provide personal data to third parties unless this is required to be done under applicable laws, we are preparing for legal proceedings or defending claims, or are performing investment advisory services. Your personal data may however be transmitted to and processed by external suppliers who provide services to Segulah, but only to the extent necessary to enable these suppliers to perform the services Segulah requests. Only personal data necessary to fulfil the above purposes will be provided to these external companies. All external suppliers must comply with our instructions and applicable data processing agreements and implement appropriate technical and organisational measures to protect the personal data.
We have a legal obligation to ensure that your data is kept accurate and up-to-date. We urge you to help us fulfil this obligation by making sure that you inform us of any changes to your contact information by contacting us at the e-mail address firstname.lastname@example.org.
You can at any time exercise the following rights in relation to the personal data processed by us:
• Right of access and rectification: You have the right to request access to personal data relating to you. This includes for example the right to be informed as to whether personal data relating to you is processed, what personal data is processed, and the purpose of the processing. You also have the right to request that inaccurate or incomplete personal data relating to you be rectified.
• Right to object: Segulah’s processing is carried out on the grounds of so-called legitimate interest. You have the right to object to processing carried out on the grounds of legitimate interest. The right to object means that you can request that Segulah’s processing on the grounds of legitimate interest not be carried out.
• Right to erasure: You can request that your personal data be erased if for example the personal data is no longer necessary for the purpose for which it was collected, if the processing is unlawful, or if the personal data must be erased in order for us to comply with a legal requirement.
• Right to data portability: You have the right to request to be given personal data in a structured, commonly used and machine-readable format, provided that it concerns the data that you yourself have provided to Segulah where this data has been processed on the grounds of your consent or on the grounds of a contract.
• Right to withdraw your consent: If you have given your consent to Segulah’s processing in any respect, you have the right to withdraw that consent. When you withdraw your consent, the processing that the consent concerned will cease and personal data collected based on your consent will be erased provided that it is not needed for another purpose for which Segulah has the right to process your personal data.
• Decline information: We give you the opportunity to decline future information mailings. When we send you newsletters, invitations, or other information, you can opt out at any time by contacting us.
If you wish to exercise any or all of your rights as described above, contact us at the e-mail address email@example.com. Segulah will process your request promptly. Should Segulah not intend to grant your request, or to refuse it in its entirety, you will be informed of this and the reasons for our decision.
If you have any complaints about how we process your personal data or if you would like more information, please contact us and we will be pleased to help you. If you wish to lodge a complaint with the national supervisory authority regarding our processing of your personal data, you can do so by contacting the Data Protection Authority.
Segulah Advisor AB (556701-3072) is the data controller.
Stockholm, May 23, 2018
Do you have any questions, contact us here.