Data Privacy Notice
Data Privacy Notice
Tokio Marine Asset Management (London) Limited
< December2020 >
Purpose of this Notice
We, Tokio Marine Asset Management (London) Limited (“TMAM London” or “we”), have an overall responsibility for the processing of your personal information and are committed to do this responsibly and securely.
This Data Privacy Notice is for individuals connected with or employed by institutional investors, financial intermediaries, business consultants, and other professional third parties with whom TMAM London has a business relationship. TMAM London is a “Data Controller.” This 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 in accordance with the General Data Protection Regulation (“GDPR”). 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.
If you are a candidate for recruitment, a separate data privacy notice is available for you upon request to TMAM London. (Email: firstname.lastname@example.org)
We may modify this Data Privacy Notice; therefore, you are advised to visit our website regularly to check for any amendments. If material changes are made, notification of these changes will be communicated to you 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, such as name, title, signature, addresses, telephone numbers, and email addresses.
- Information about your correspondence with us, such as phone calls, emails, and letters.
- Information that is automatically collected via tracking technologies, such as via cookies when you visit our website, Internet Protocol (IP) address and Google Analytics.
- Information connected to your products or services with us, such as bank account details and financial information.
- Information if you visit our office such as visual images collected via closed circuit television (CCTV).
- 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.
- Information classified as ‘sensitive’ personal information is not intentionally collected. 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.
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 for marketing purpose.
- Undertake market research and statistical analysis, including analysing your use of our website and developing new products.
- Improve our products and services.
- Fulfil our obligations as a data controller and those owed to a relevant regulators, 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.
- Investment manager, Tokio Marine Asset Management Co., Ltd. Tokyo
- Fraud prevention, law enforcement agencies and associations.
- As required by a court order or any other legal or regulatory requirements, such as Financial Conduct Authority, HM Revenue and Customs, Information Commissioner’s Officer, or any other relevant supervisory authority.
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 UK or the EEA. Any transfer of personal data outside of the UK or the EEA will be in compliance with the requirements of UK and EU data protection laws.
In the event that we transfer personal data outside the UK or the EEA, as set out in this notice, we will only process (or permit the processing) of personal data if one or more of the following conditions are satisfied:
- a) The personal data is processed in a territory that is subject to an an adequacy regulation made under UK data protection law or an adequacy decision made on the basis of the GDPR. In such case, personal data may be transferred in compliance with UK data protection law or the GDPR, as applicable.
- b) There is a valid cross-border transfer mechanism under which we (or the data processor, where appropriate) can ensure that appropriate safeguards are in place to ensure an adequate level of data protection with respect to the privacy rights of individuals as required by UK data protection law or the GDPR, as applicable.
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.
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.
You have several rights in relation to how TMAM London 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.
If you have any concerns related to your data privacy enquiry to TMAM London, or you 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.
If you have any questions about our Data Privacy Notice or the information we collect or use about you, please contact;
Tokio Marine Asset Management (London) Limited
Registered office address: 20 Fenchurch Street, London, EC3M 3BY