Our privacy policy is:
Our policy applies to:
We decide why and how your personal data are processed. We are responsible for processing your personal data.
We collect your personal data from the following sources:
We collect your personal data in the following ways:
These are the personal data you:
We process your:
Our legal ground for processing your regular personal data is:
Personal data we process based on this legal ground is:
Personal data we process based on this legal ground is:
We provide a link to a document that explains how we balance our legitimate interest and your interests, or fundamental rights and freedoms. We specify our legitimitate interests, and we specify the personal data we process based on this legal ground.
1) Enable Fearnleys to provide financial services to our clients, partners, Fearnleys and the society. 2) email addresses, phone numbers
We collect personal data:
We are:
We process your personal data in the:
We process your personal data in a situation that concerns:
We do not use your personal data to automatically evaluate aspects of your personality.
We do not use your personal data to make automated decisions about you.
We process your personal data for the purposes that are described in Section 3.
Our processing purposes are:
We do not process your personal data for secondary purposes that are inconsistent with the primary purposes for which your personal data is collected initially,
We inform you before we process your personal data for secondary purposes
We limit the duration we store your personal data to what is necessary for our processing purposes.
We continuously review the necessity of our continued storage of your personal data:
We delete your personal data within a specified time-limit:
If the further retention of your personal data is necessary for the purposes that are specified by law, we can further retain your personal data.
We disclose your personal data to the following recipients:
Our legal grounds for disclosing your personal data to the recipients are:
If we in the future disclose your personal data to a recipient, then we do not inform you of:
We transfer your personal data to:
The personal data are transferred to:
Our legal ground for transferring your personal data is:
Personal data we process based on this legal ground is:
We secure your personal data:
We have measures to:
If we have a reasonable degree of certainty of a breach of the security of the processing of your personal data, then we will:
We are not obliged to notify you directly if
We self-assess that the:
You have specific legal rights relating to the personal data we collect from you.
We will respect your individual rights and will deal with your concerns adequately.
Where you have given consent for the processing of your personal data, you have the right to withdraw your consent at any moment.
You may ask from us information regarding personal data that we hold about you, including:
We will provide you with a copy of your personal data upon your request.
If you ask for further copies of your personal data, then we can charge you with a reasonable fee that we base on the administrative costs.
You have the right to obtain from us rectification of your personal data, that are inaccurate or incomplete, in the latter case provided you supply the corrected or supplementary information.
You have the right to request that we delete the personal data we process about you.
We must comply with this request if we process your personal data, and if:
We must not comply with this request your personal data is necessary:
You have the right to obtain from us restriction of processing of your personal data, if:
You have the right to object – at any time – to the processing of your personal data due to your particular situation, provided that the processing is not based on your consent but on our legitimate interests or those of a third party.
In this event we shall no longer process your personal data, unless we can demonstrate:
If you object to the processing, please specify whether you also wish the erasure of your personal data, otherwise we will only restrict it.
You have the right to always object to the processing of your personal data for direct marketing that was based on our legitimate interest, regardless of any reason.
If the marketing was based on your consent, you can withdraw consent.
You have the right:
These two rights are rights you have if:
You have the right to receive your personal data in a structured, commonly used and machine-readable format.
Your right to receive your personal data must not adversely affect the rights and the freedoms of other persons. This may be the case if a transfer of your personal data to another organization also involves the transfer of the personal data of other (non-consenting) individuals.
We invite you to communicate with us about the exercise of your rights concerning the protection of your personal data.
We only accept written requests since we cannot deal with verbal requests immediately without first:
Your request should contain a detailed, accurate description of which right you want to exercise.
You must provide us with a copy of an identification document to confirm your identity, for example:
The document should contain:
Any other data contained in the copy of the identification document such as a photo or any personal characteristics, may be masked out.
We will not accept other means of assuring your identity.
If you wish to propose alternatives, we will assess them on a case-by-case basis.
Our use of the information on your identification document:
You can send your request that concerns the protection of your personal data to:
You receive our answer to your request that concerns the protection of your personal data at:
We have a person who is responsible for handling of your request that concerns the protection of your personal data.
We have policies that ensure that your requests concerning the protection of your personal data are
We inform you of our handling of your request that we exercise your rights (regarding the protection of your personal) within:
You can lodge a complaint to a supervisory authority:
The Supervisory Authority should within a reasonable period inform you of:
You can mandate that an organization lodges a complaint on your behalf with a Supervisory Authority.
The Supervisory Authority should within a reasonable period inform you of:
You can seek a judicial remedy in the EU and the EEA against:
You can mandate that an organization exercises your right:
You can choose why and how we process your personal data in your privacy settings:
In your privacy settings options you can:
We enable you to choose why and how we process your personal data via our:
We make sure to communicate your choice about the processing of your personal data to the recipients that we disclose the personal data to.
If we change our privacy policy, then we publish a new version of it.
We do not make available the prior versions of our privacy policy.
Personal data means any information relating to an identified or identifiable natural person (data subject).
An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as:
Regular personal data are - in the GDPR - personal data that are not special categories of personal data. There is no exhaustive list of such personal data.
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as:
Processing Purpose means the reason why you process personal data.
Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for in Union or Member State law.
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Supervisory Authority means an independent public authority which is established by a Member State pursuant to Article 51 GDPR.
Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
The EU-U.S. Privacy Shield Framework was designed by the U.S. Department of Commerce, and the European Commission to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring personal data from the European Union to the United States in support of transatlantic commerce. On July 12, 2016, the European Commission deemed the EU-U.S. Privacy Shield Framework adequate to enable data transfers under EU law.
The European Commission has the power to determine, on the basis of article 45 GDPR, whether a country outside the EU offers an adequate level of data protection, whether by its domestic legislation or of the international commitments it has entered into.
The effect of such a decision is that personal data can flow from the EEA (EU and Norway, Liechtenstein and Iceland) to that third country without any further safeguard being necessary.
The European Commission has so far recognised Andorra, Argentina, Canada (commercial organisations - PIPEDA), Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the US (limited to the Privacy Shield framework) as providing adequate protection.
Personal Data Breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Enterprise means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity.
Group of undertakings means a controlling undertaking and its controlled undertakings.