Privacy Statement

Last updated 25 May 2019


Overview

We at, Old Mutual Isle of Man Branch (OMIM) of Old Mutual Life Assurance Company (South Africa) Limited are committed to protecting the privacy and security of the personal information of our data subjects (“you”). This Privacy Notice describes how, in accordance with the General Data Protection Regulation (“GDPR”), we collect and use your personal information given to OMIM in relation to investing into The Investment Portfolio+ contract.

It is important that you read this Privacy Notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.


Data protection principles

OMIM will comply with relevant data protection law. GDPR requires that the personal information we hold about you must be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

How do we collect your personal information

We collect the majority of your personal information through our forms and correspondence provided by the you, the contractholder. There may be circumstances where your information has been provided by another party, in which case the information is most likely to be obtained from:

  • The settlor and/or trustees of a trust of which you are a beneficiary or protector.
  • Signatories of a corporate applicant for whom you are an ultimate beneficial owner, shareholder or director.
  • Publically accessible media sources.

Purposes and legal bases of processing

We use your personal information to:

  • Enable us to enter into a contract with you to hold an Investment Portfolio+ contract and for ongoing performance of this contract.
  • Prevent, detect or investigate financial crime including fraud or other criminal activity under the laws of the Isle of Man relating to Anti-Money Laundering and Countering the Financing of Terrorism.
  • Fulfil our reporting obligations under the Automatic Exchange of Information legislation in the Isle of Man.
  • do not use your personal information for marketing purposes.
  • It is mandatory for you to provide certain information in order for OMIM to fulfil their contractual and statutory obligations. If you do not provide us with the necessary personal data, OMIM will be unable to enter into contract with you.

Sharing your personal information

OMIM shares your personal information, based on the purpose for which it was collected, only with:

  • The relevant authorities only if required by law.
  • Third party suppliers and outsourced service providers (including cloud- based services).
  • Your appointed Authorised Custodian.

International Transfers of data outside the European Union

We do not transfer your personal information outside of the European Union.


Automated Decision Making

We do not carry out any automated processing which may lead to an automated decision being made based on your personal information.


Your rights

Under the GDPR you have the right to:

  • Request from us access to your personal information through a ‘data subject access request'.
  • Ask us to rectify any inaccurate personal information we hold about you.
  • Request erasure of your personal information, unless we have a legal obligation to process your personal information.
  • Request the restriction of processing of your personal information in certain circumstances.
  • Object to processing of your personal information in certain circumstances.
  • Request portability in relation to your personal data we hold.
  • Ask not to be subject to decisions based solely on automatic processing.
  • Withdraw consent where processing of your personal information is based on consent.

The Data Controller and the Data Protection Officer

Your personal information is controlled by:

Old Mutual Isle of Man Branch of Old Mutual Life Assurance Company (South Africa) Ltd
5A Village Walk
Onchan
Isle of Man
IM3 4EA
Tel number: +44 (0) 1624 690200

If you have any questions or complaints in relation to our use of your personal information or if you wish to exercise any rights listed under section 6, please contact our Data Protection Officer at the above address or by emailing enquiries@impactiom.com

In the unlikely event that you are dissatisfied with our response, you have the right to take up the matter with the Information Commissioner's Office (ICO), whose details are:

Information Commissioner's Office
First Floor
Prospect House
Prospect Hill
Douglas
Isle of Man
IM1 1ET


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