Data Privacy Notice

Data Privacy Notice (Website)

Tokio Marine Asset Management (London) Limited

Version: May 2018

 

Purpose of this Notice

 

This Data Privacy Notice contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.

 

We, Tokio Marine Asset Management (London) Limited, have an overall responsibility for the processing of your personal information and are committed to do this responsibly and securely. This Data Privacy Notice applies to Tokio Marine Asset Management (London) Limited and its legal entities which manage the products and services we offer to our EU customers.

 

We may need to make changes to our Privacy Notice; so please check our website for updates from time to time. If there are important changes such as changes to where your personal data will be processed; we will contact you to let you know. If the changes are substantial, we may notify you of changes to this policy by email.

 

Information we collect and use

We collect personal information about you in order to perform our service and offerings to you as our customer. This includes:

  • Information about who you are e.g. name, address, date of birth, gender and contact details.

  • Information connected to your products or services with us e.g. bank account details and financial information. We do not retain a complete view of your payment card information. 

  • Information about your correspondence with us e.g. phone calls, emails and letters.

  • Information that is automatically collected via tracking technologies e.g. via cookies when you visit one of our websites, Internet Protocol (IP) address, Facebook, Google Analytics and Criteo.

  • Information if you visit one of our offices e.g. visual images collected via closed circuit television (CCTV).

  • Information classified as ‘sensitive’ personal information is not intentionally collect via our website for e.g. genetic or biometric data for the purpose of a unique identifier, marital or social security status. This information will only be collected and used where it is needed to provide the product or service you have requested or to comply with our legal obligations such as recruitment purposes.  

  • In order to understand more about you and to verify your identity, we also supplement and combine the personal information that we collect from you with other categories of data obtained from other sources available.

     

The Legal Basis for using your Information

 

Your privacy is important to us and we will only collect and use your personal information where it is necessary, fair and lawful to do so. We will use your information to:

 

Administrate your account as per contractual agreement.

Perform anti-fraud and anti-money laundering checks and verify your identity.

Send you information about our products and services.

Undertake market research and statistical analysis, including analysing your use of our website and developing new products.

Fulfil our obligations owed to a relevant Regulator, Tax Authority, Supervisory Authority or Revenue Service as per our legal obligations.

 

If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to perform our services to you. This is referred to a legitimate interest for business and commercial interests in operating our business in a client-focused, efficient and sustainable manner, in compliance with applicable legal and regulatory requirements.

 

Who we share your data with

We may share your information with third parties, where relevant, to provide the products and services we offer to you. These include:

 

  • Third party service providers who support the operation of our business, such as IT and marketing suppliers, financial service providers and other administrative support services to operate our website.

  • Fraud Prevention, Law Enforcement Agencies and Associations.

  • As required by a court order or any other legal or regulatory requirements such as Regulators (Financial Conduct Authority), HM Revenue and Customs or any other relevant Supervisory Authority (Information Commissioners Officer).

     

We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.

 

If we, or a fraud prevention agency, determine that you pose a risk of fraud or money laundering, we may refuse to provide new and/or existing products or services to you. A record of any fraud or money laundering risk will be retained by us and the fraud prevention agencies which may also result in others refusing to provide products, services, financing or employment to you.

 

Where your information is processed

The majority of your information is processed in the UK and European Economic Area (EEA). There will be some instances where your information is being processed outside of the EEA, where we have implemented additional measures to ensure your data is processed and transferred securely using Standard Contractual Clauses. These agreements have been put in place to ensure they meet to the requirements of UK and EEA data protection laws, and will be reviewed on a regular basis with any third party supplier to ensure they meet to these obligations.

 

How long your information is kept

We will keep your personal information only where it is necessary to provide you with our products or services while you are a customer. Where you have consented to us using your personal information for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

 

We may also keep your information after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.

 

Use of Cookies

A Cookie is a small file which is saved onto your computer or device when you visit our website. Cookies store small pieces of information to remember when you have performed a specific action or visited our website.

We use web technologies such as Cookies to improve our website performance and to understand more about you so we can offer you a more personalised and enhanced browsing experience. There cookies we typically use are:

  • Essential/Strictly Necessary Cookies: which are essential to the functioning of our website and remembering your account log-in details.

  • Performance Cookies: to help us with the performance and design of our website. This allows us to measure how many times a page has been visited and/or whether a page has been visited on our website through an advertisement or by other means.

  • Functionality Cookies: to help us remember your settings which you may have selected on your return visit, or assist with other functionality when you browse and use our website.

  • Targeting and Tracking Cookies:  to help us understand your interests as you browse the internet, so we can tailor and deliver to you a more personalised service in the future. This assists us in delivering relevant advertising to you during various advertising campaigns we may run from time to time through participating third party sites.  We own the anonymous data collected, which is not shared with any other organisation.

    Tokio Marine Asset Management operates on many platforms, systems, third party applications and websites, which use, store and process your data specific to the application. For more details on our Cookies policy please click on the following link: http://www.tokiomarineam.co.uk/disclaimer/cookies.aspx. You have the option of setting your browser to notify you when using Cookies, so that you can determine whether to accept it or not. If you do select not to use Cookies whilst browsing, you may not be able to fully experience the functionality of our website. 

     

Using your Personal Information for Marketing

We consider that it is within our legitimate interests to send you information about our products and services for marketing purposes. We may occasionally use your personal information to send you marketing about similar products and services by post, telephone, email, SMS, and through various digital channels. Digital channels may include social media and similar such digital marketing channels. 

You can object to receiving marketing from us at any time by selecting the unsubscribe link in our marketing communications. You can also contact us on the details provided below.

Social Media Platforms

We use various blogs, forums and other social media platforms to facilitate and allow you to share content. We do not take any responsibility for any personal information you share on social media platforms that is subsequently used, misused by another user.

 

Your Rights

You have several rights in relation to how Tokio Marine Asset Management (London) Limited uses your information such as the right to:

  • Request for a copy of the personal information we hold on you.

  • Rectify and correct your personal information. It is important that the personal data we hold about you is accurate and up-to-date, so please do keep us informed if your personal information changes.

  • Delete your personal information.

  • Transfer your personal information to other organisations.

  • Be informed on any automated decision making we make on your data.

  • Restrict processing of your personal information.

  • Withdraw consent or request to unsubscribe from any direct marketing at any point of time.

 

If you wish to exercise these rights, or if you have any queries on the personal information we process please contact us on the details listed below. Please note that these rights may be limited by data protection legislation, and we may be entitled to refuse requests where exceptions apply.

Complaints

If you have any concerns related to your data privacy enquiry to Tokio Marine Asset Management (London) Limited, or are not satisfied with the way in which we have resolved your complaint, you have the right to raise a complaint with the local data protection authority. The local data protection authority for the UK is the Information Commissioner’s Office.

 

Contact Us

If you have any questions about our Data Privacy Notice or the information we collect or use about you, please contact:

 

Rie Usui, Chief Operating Officer (accountable for Data Protection)

20 Fenchurch Street, London, EC3M 3BY, UK

tmalgdpr@tokiomarine.co.uk

 

Registered office address for Tokio Marine Asset Management (London) Limited:

20 Fenchurch Street, London, EC3M 3BY

Email: tmalgdpr@tokiomarine.co.uk