It is of importance for us at IPM that you feel confident that your personal integrity is safeguarded with us. We have therefore been working actively to ensure that our processing and services comply with your expectations and with external requirements of data protection (under the requirements set by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, (“GDPR”)).
Personal Data is any information relating to you as an individual, for example your name, contact information or any other information that can be tied back to you. Below you are provided with all relevant Personal Data currently processed by IPM and where necessary, additional information enabling you to better understand how we at IPM handle your Personal Data.
What Personal Data we collect, how and why
Depending on your relationship with IPM, one or several of the descriptions below describe why we may process Personal Data concerning you and how we may have obtained the Personal Data.
- IPM may save or document any communication between you and IPM, for example when you request a service, enter an agreement with us, contact our client service, or use our digital channels. Hence, the Personal Data that is stored can include your contact information and any other information that you may have shared about yourself in e-mails, phone calls, or via any other form of communication. We do this to provide better, more personalised and more effective service in your future interactions with IPM.
- If you have entered into a legal agreement with IPM, then we may store any communication concerning the agreement and will store the agreements themselves. The Personal Data may include your name, contact information, signature, passport information, bills or any other information provided by you to confirm your identity in relation to the agreement.
- If you are, or represent, an investor for which IPM carries out investment management services, information will be collected about your background for purposes of complying with legal or regulatory obligations related to prevention of terrorist financing or money laundering. The relevant Personal Data includes your contact information, passport details, if you are a politically exposed person (PEP), any potential criminal background, and any other information necessary for these purposes. We will use a combination of manual routines and automated tools for looking up the required data.IPM will not use information that may have been collected about you to meet legal or regulatory obligations related to prevention of terrorist financing or money laundering for other purposes than to comply with the requirements.
- If you are, or represent, an investor in funds managed by IPM, your Personal Data may be processed in connection to the fund investment, that is necessary in order to act on requests for changes in the investments and to enable tracking of the performance of the investment. We will receive this information about you from fund administrators.
Your Rights as a Data Subject
It is of importance for us at IPM that you are aware of your rights which you can exercise in relation to the information we hold about you, they are the following:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you, i.e. to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure ‘right to be forgotten’ of your personal information. This enables you to ask us to delete or remove your personal information. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Right to data portability. You may ask us to transfer your Personal Data to another party. Thus, you have the right to receive a copy of your Personal Data in a structured, commonly used, machine-readable format that supports re-use or store your data on a private device for personal use.
- Right to withdraw consent. You can withdraw any consent you may have provided for the collection, processing and transfer of your personal information for a specific purpose, at any time.
- Automated decisions-making. You have the right not to be subject to a decision based solely on automated processing, including profiling, which have legal effect on you.
- Right to lodge a complaint. If you wish to lodge a complaint about privacy related topics you can contact the Swedish Data Protection Authority.
If you choose to exercise any of your abovementioned rights in connection with your Personal Data, IPM will provide a response within one month of the date of the request. Please contact us at firstname.lastname@example.org to submit such a request, or to pose any other questions you may have regarding IPM’s processing of your Personal Data.
Third parties that we may share your Personal Data with
We may need to share your personal information with external parties. If we share your Personal Data, the third party is required to process the information in a safe and accurate way and they are contractually bound to comply with external requirements of data protection and all other applicable regulatory and legal obligations.
Your Personal Data may be transferred to third countries (countries outside the EU and EEA). If your information is transferred to third countries, IPM have put in place appropriate data transfer mechanisms, such as contractual clauses, to ensure your information is protected.
How we protect your Personal Data
IPM AB has taken physical, technical and organisational measures to protect your Personal Data from unauthorised use, loss, destruction or damage. Within IPM AB employees are only given the minimum access permissions required for performing their assigned work tasks, thereby access to your personal data will only be given to authorised persons that require the access for legitimate purposes.
Your information is retained for as long as necessary to meet legal, regulatory and business requirements. Upon request IPM will provide you with more information on the exact retention periods applying to your Personal Data in each case.