PRIVACY NOTICE AND COOKIE POLICY


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.

Data Privacy Statement for Old Mutual Guernsey Branch

I understand that Old Mutual will process personal information about me and any other party whose personal information I have provided.

The type of personal information processed about me will depend on the purpose for which it has been collected and will include:

  • my contact details
  • information to verify my identity
  • information about my family, lifestyle, health and finances
  • my payment details
  • my policy details

The processing of my personal information may take place in a number of jurisdictions and may be shared with other parties within or outside OMG for the general purpose of establishing, maintaining and servicing an insurance policy. The sharing of my personal data may be used for any or all of the following purposes, to:

  • check against credit reference or other databases to verify information provided for regulatory due diligence purposes and to prevent or detect financial crime including money laundering, terrorist financing, bribery and corruption, sanctions listing or fraud;
  • allow for the provision of services relating to enhanced due diligence, underwriting, reinsurance, data hosting, online services, payment or reporting of any tax or levy, or any other services provided from time to time;
  • enable an appointed financial adviser or fund adviser to assist in the provision of services to the policyholder;
  • compile statistical analysis or market research, where information is not specific to the individual;
  • comply with any legal obligation which includes the releasing of personal information to regulators, law enforcement authorities or other bodies where there is a legal requirement to do so, including the sharing of information under regulations relating to the U.S Foreign Account Tax Compliance Act and The Organisation for Economic Co-operation and Development Common Reporting Standards;
  • enable an appointed discretionary asset manager or custodian to meet their legal or regulatory requirements, where that discretionary asset manager or custodian providing services in relation to a policy requests the personal data of an individual linked to an application, and where we are satisfied that such a discretionary asset manager or custodian has a legal or regulatory requirement to make such a request.

Where my personal information is shared with a third party for the provision of services relating to my policy, my personal information will only be used for the purposes for which it was collected. In some circumstances this may involve a transfer of my personal information to a third party outside the European Economic Area (EEA). Whenever my personal information is shared it will be subject to the same levels of security and protection that OMG would apply.

I may ask OMG to:

  • provide a copy of personal information held about me and an explanation of how this data is processed;
  • update or correct my personal information;
  • delete information about me (where it is no longer necessary in relation to the purpose for which it was originally collected);
  • restrict processing of my personal information where appropriate. I may also object to OMG processing my data but understand that this may have consequences in OMG being able to continue servicing my policy.

I have been made aware that a full explanation of how OMG collects, uses and shares my personal information can be found at www.oldmutualinternational.com. If I have any questions about data privacy I can address these to:

The Data Protection Manager;
Old Mutual International (Guernsey) Limited,
Albert House,
South Esplanade,
St Peter Port,
Guernsey, GY1 1AW.
Tel: +44 (0) 1481 726726
Fax: +44 (0) 1481 728953


If I have a complaint about the processing of my personal information and OMG is unable to provide a satisfactory response I may contact the appropriate regulator:

Office of the Data Protection Authority:
St Martin’s House,
Le Bordag,
St. Peter Port,
Guernsey, GY1 1BR,
Telephone: +44 (0) 1481 742074,
Email: enquiries@odpa.gg


I have read and understood the Data Privacy Statement set out above and will make it available to other individuals whose personal information has been provided by me to OMG either in this application or within accompanying documentation.



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.

We 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


Use of cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Our websites may automatically collect information from your computer using Cookies which provide us with limited personal information. We will use this data primarily for the following purposes:

  • security
  • enhance and personalise aspects of our service
  • show that you have read any relevant legal information
  • analyse how our site is used

The tables below explain all the cookies we use and why. This privacy policy supports more than one Old Mutual International website. The list below shows the websites included in this privacy policy. Please see the relevant table for the website you are visiting:

Old Mutual Wealth and Old Mutual Limited may use your data for assessment and statistical analysis purposes.

Old Mutual International's public website: http://www.oldmutualinternational.com

Cookie Name Purpose
Google Analytics _utma
_utmb
_utmc
_utmz
These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
Adviser check advisor_verification This cookie remembers the choice made by a user when entering the adviser section of the site. The cookie only stores the fact that a user has identified themselves as an adviser and means that they will not see the question on future visits to the site.
CMS ASPSESSIONIDCCBBSRDS & ASPSESSIONIDSAABRRQD The content management system (CMS) that is used to update the content on the site uses cookies to record whether users are logged into that system. Only users who can update content will have this cookie placed on their machine. No personal data is stored.

Google privacy & analytics opt-out

View an overview of privacy at Google. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout .


YouTube cookies

We embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode. To find out more please visit YouTube’s embedding videos information page .


Search engines

The search engines on our websites are designed to be as powerful and easy to use as the popular search engine Google. The search is made possible on some of our websites by a piece of hardware (a search ‘appliance’) supplied by Google that is plugged into our server and continuously indexes the content on our site. All search requests are handled by the appliance and no personal information is passed on to any third party, including Google.


Content posted by you

If you post any personal information to any of our public forums/blogs, this information may be made immediately available to other users throughout the world who may use it to send you unsolicited communications. If you post any content in breach of our site’s terms of use we may inform any Internet provider and law enforcement agencies about the content and your behaviour.


Legal and contact information

The registered and head office of Old Mutual Isle of Man Branch of OMLACSA is at:
5A Village Walk,
Onchan,
Isle of Man IM3 4EA

You have a right to access the personal data held about you. To obtain a copy of the personal information we hold about you, please write to us at the relevant above address.

We will use all reasonable efforts to answer any questions or resolve any concerns regarding your privacy promptly.

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