At House of Reach AB (hereafter HofR) we are committed to protect and respect your privacy in compliance with EU- General Data Protection Regulation (GDPR) 2016/679, dated 27 April 2016. This privacy statement explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
This Privacy Statement applies to the use of our products and to our marketing and customer contract fulfilment activities on behalf of HofR and the asset managers we represent in the Nordics. It also applies to employees and individuals seeking a job at HofR.
HofR acts as outsourced C-suit for alternative- and niche asset managers with ambitions to build their institutional business in the Nordics, including assisting the managers in marketing of their funds to professional investors. HofR also acts as strategic advisors to companies in the financial industry such as for example asset managers, fund companies, banks, mortgage providers, insurance companies and others. HofR have its office at Convendum, Biblioteksgatan 29, 114 35 Stockholm, Sweden. HofR is the data controller and can be contacted by email email@example.com and the latest version of this policy is published at www.houseofreach.com.
When do we collect personal data about you?
When you interact with us in person, through correspondence, by phone, by social media, or through our website.
When we collect personal information from other legitimate sources, such as our clients, through public sources or social networks, we will only use this data if you have given your consent to them to share your personal data with others.
We may collect personal data if it is considered to be of legitimate interest, and if this interest is not overridden by your privacy interests. Before data is collected we make sure an assessment is made, ensuring that there is an established mutual interest between you and HofR.
Why do we collect and use personal data?
All types of action with personal data constitute personal data processing, for example collecting, registration, organisation, structuring, storage, manipulation, alteration, retrieval, reading, use, disclosure, dissemination or provision in other ways, adjustment or combination, limitation, erasure or destruction.
We collect and use personal data mainly to perform marketing and client service activities. We also collect data about suppliers, partners and persons seeking a job or working in our company. We may use your information for the following purposes:
Send you marketing communication. This may include information about our products and services, events, activities, and promotions as well as those of the clients we represent. Part of this communication is subscription based and requires your consent. Part of it is based on legitimate and mutual interest.
Send you information about the products and services of our clients that you might have invested in.
Perform direct marketing activities in cases where legitimate and mutual interest is established.
Provide you content and venue details on a webinar or event you signed up for.
Follow up on incoming requests (customer support, emails, chats, or phone calls).
Perform contractual obligations such as invoices, reminders, and similar.
Process a job application.
Legal basis for collecting personal data
The collection of personal data based on consent from the data subject will be done by using a standardised format that will store documentation related to the consent given by the individual.
We use personal information for fulfilling our obligations related to contracts and agreements with customers, partners and suppliers.
We may use personal data if it is considered to be of legitimate interest, and if the privacy interests of the data subjects do not override this interest. Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between HofR and the individual person has been identified. This legal basis is primarily related to our marketing purposes. We will always inform individuals about their privacy rights and the purpose for collecting personal data.
What type of personal data is collected?
We collect information such as name, phone numbers, contacts details, title and email address, in addition to your company’s name and contact information. We may also collect feedback, comments and questions received from you in communication and activities, such as meetings, phone calls, documents, and emails. From our websites we may collect IP-address and actions taken on the site.
If you apply for a job at HofR, we collect the data you provide during the application process.
HofR do not collect or process any special categories of personal data, such as sensitive personal data from external contacts. For internal use sensitive personal data is only collected and processed if required for administrative or regulatory purposes.
How long do we keep your personal data?
We store personal data for as long as we find it necessary to fulfill the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.
This means that we may retain your personal data for a reasonable period after your last interaction with us. When the personal data that we have collected is no longer required, we will delete it in a secure manner. ‘
You have the following rights with respect to your personal data
The right to request a copy of your personal data that HofR holds about you.
The right to request that HofR corrects your personal data if inaccurate or out of date.
The right to request that your personal data is deleted when it is no longer necessary for HofR to retain such data.
The right to request that HofR provides you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
The right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.
The right to withdraw any consent to personal data processing at any time. For example, your consent to receive e-marketing communication:
If you want to withdraw your consent to for example e-marketing, please email us at firstname.lastname@example.org.
How we share your data
We do not share, sell, rent, or trade your information with any third parties without your consent, except from what is described below.
We may pass your information on to our sub-contractors and other associated organisations with the purpose of them providing services to you on our behalf. In such case, the providers should sign necessary agreements to ensure that your privacy rights remain intact.
We work closely with our clients to bring you a range of products and services designed to meet your needs related to asset management. When you enquire about these products and services, our client may use your details to provide you with information and carry out their obligations arising from any contracts you have entered with them. Our clients may share your information with us, which we will use in accordance with this Privacy Statement.
We will disclose your personal information if required by law or if we, as a company, reasonably believe that disclosure is necessary to protect our company’s rights and/or to comply with a judicial proceeding, court order or legal process. However, we will do what we can to ensure that your privacy rights continue to be protected.
We protect your data
We have technological and operational procedures in place to protect your personal data from loss, misuse, alteration, or unintentional destruction through our CRM system.