Updated: May 2018
For the purposes of the General Data Protection Regulation (EU) 2016/679 (the 'GDPR'), the data controller is the relevant Fidante Partners Europe entity.
1. Information Fidante Partners Europe may collect and process about you
However Fidante Partners Europe uses personal data it ensures that the usage complies with law and the law allows and/or requires it to use personal data for a variety of reasons. These include where Fidante Partners Europe:
• has obtained your consent;
• has legal and regulatory obligations that it must discharge (including recording of telephone calls);
• needs to do so in order to establish, exercise or defend its legal rights or for the purpose of legal proceedings;
• is fulfilling contractual obligations;
• is using your personal data for the legitimate business interests of Fidante Partners Europe and the Challenger Limited group, such as:
− allowing it to effectively and efficiently manage and administer the operation of its business;
− maintaining compliance with its internal policies and procedures;
− monitoring the use of its copyrighted materials;
− enabling quick and easy access to information on Fidante Partners Europe and Challenger products and the investment opportunities offered by each; and
− offering optimal, up-to-date security solutions for mobile devices and IT systems; and
− obtaining further knowledge of current threats to network security in order to update its security solutions.
2. Sensitive data
Fidante Partners Europe does not seek to collect sensitive personal data (such as data revealing political opinions, religious beliefs or data concerning health or sex life). If Fidante Partners Europe does seek to collect such data, your explicit prior consent will be sought.
3. International transfers and storage of personal data
The Challenger Limited group is an international life insurance and asset management business. Our customers and operations are spread around the world. As a result, the data that Fidante Partners Europe collects from you may be transferred to, and stored at, destinations inside or outside the European Economic Area ("EEA"). It may also be processed by staff operating inside or outside the EEA who work for Fidante Partners Europe or the Challenger Limited group, or for one of its agents. Such staff may be engaged in, amongst other things, the provision of support services.
Where Fidante Partners Europe transfers your personal data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the EEA, for example, this may be done in one of the following ways:
• the country that Fidante Partners Europe sends the data to might be approved by the European Commission as offering an adequate level of protection for personal data;
• the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data;
• where the recipient is located in the US, if it is a certified member of the EU-US Privacy Shield scheme; or
• in other circumstances the law may permit Fidante Partners Europe to otherwise transfer your personal data outside Europe.
You can obtain more details of the protection given to your personal data when it is transferred outside Europe (including a copy of the standard data protection clauses which Fidante Partners Europe have entered into with recipients of your personal data) by contacting us as described in paragraph 11 below.
Unfortunately, the transmission of information via the internet is not completely secure. Although Fidante Partners Europe will do its best to protect your personal data, Fidante Partners Europe cannot guarantee the security of your data transmitted to its website; any transmission is at your own risk.
4. Purposes of processing
Fidante Partners Europe uses information held about you in the following ways:
• to provide you with information including but not limited to newsletters about products or services that you request from Fidante Partners Europe or products or services offered by Fidante Partners Europe, the Challenger Limited group and/or its associated entities or investment managers with which Fidante Partners Europe has a commercial relationship which Fidante Partners Europe feels may interest you, where you have consented to be contacted for such purposes (or in the other circumstances described in this paragraph 4);
• compliance with legal obligations (e.g. comply with diversity disclosures or anti-money laundering and anti-terrorism financing purposes);
• compliance with contractual obligations; or
• to notify you about changes to products or services.
If there is any change to your personal data which you have submitted to Fidante Partners Europe, please contact Fidante Partners Europe at the address in paragraph 11 so that it may ensure its records of your personal data are accurate and, where necessary, kept up to date. Personal data shall not be retained for longer than is necessary for the purpose for which it is held.
5. Disclosure of your information
Fidante Partners Europe may disclose your personal information to the following categories of third parties and for the following purposes:
• with our business partners. For example, this could include our partners from whom you or your company or your organisation invested in the Fidante product(s). Personal data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
• if substantially all of Fidante Partners Europe's assets or business are acquired by a third party, in which case personal data held by it may be one of the transferred assets; or
6. How long Fidante Partners Europe keeps your personal data
How long Fidante Partners Europe will hold your personal data for will vary and will be determined by the following criteria:
• the purpose for which Fidante Partners Europe is using it – Fidante Partners Europe will need to keep the data for as long as is necessary for that purpose; and
• legal obligations – laws or regulations may set a minimum period for which Fidante Partners Europe has to keep your personal data.
7. Your rights
In all the above cases in which Fidante Partners Europe collects, uses or stores your personal data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
• the right to obtain information regarding the processing of your personal data and access to the personal data which Fidante Partners Europe holds about you;
• the right to withdraw your consent to the processing of your personal data at any time. Please note, however, that Fidante Partners Europe may still be entitled to process your personal data if it has another legitimate reason for doing so. For example, it may need to retain personal data to comply with a legal obligation;
• in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that Fidante Partners Europe transmits those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided directly to Fidante Partners Europe;
• the right to request that Fidante Partners Europe rectifies your personal data if it is inaccurate or incomplete;
• the right to request that Fidante Partners Europe erases or puts beyond reasonable use your personal data in certain circumstances. Please note that there may be circumstances where you ask Fidante Partners Europe to erase or put beyond reasonable use your personal data but it is legally entitled to retain it;
• the right to object to, or request that Fidante Partners Europe restricts, its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask Fidante Partners Europe to restrict, its processing of your personal data but it is legally entitled to refuse that request; and
• the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by Fidante Partners Europe.
You can exercise your rights by contacting Fidante Partners Europe at the address given below.
Fidante Partners Europe may use third party web analytics providers to collect information on how people use our website and to help us know what our customers find interesting and useful in our website. Our web analytics providers use "cookies" to collect information. For more information on our web analytics providers, please visit Omniture and Google Analytics sites.
Fidante Partners Europe uses Google AdWords Remarketing to trigger advertisements across the Internet. AdWords remarketing will display advertising based on what parts of our website have been visited by placing a cookie on your machine. This cookie does not identify you as an individual. Google AdWords Remarketing allows us to tailor our marketing to better suit your online activity and display ads that are relevant to you. Visit Google's Ads Preferences Manager for more information on the Google AdWords Remarketing cookie and how to opt out from the use of these cookies.
10. How to contact Fidante Partners Europe
1 Tudor Street, London, EC4Y 0AH, United Kingdom
Telephone: +44 (0) 207 832 0900;
or via e-mail at firstname.lastname@example.org.
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our Data Protection Officer, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, Fidante Partners Europe’s Data Protection Officer will provide you with the contact information for that regulator.