FundGlobam GDPR POLICY
FundGlobam may gather information about individuals (the “Personal Data”); Individuals include customers, suppliers, business contacts, employees or any other individual having a relationship with FundGlobam.
This FundGlobam GDPR policy discloses how Personal Data shall be collected, handled and stored in compliance with the GDPR.
General principles
FundGlobam is committed to processing data in accordance with its responsibilities under the GDPR.
The FundGlobam GDPR policy ensures that Personal Data are processed in accordance with its responsibilities under the GDPR.
FundGlobam shall:
- Process Personal Data lawfully, fairly and in a transparent manner;
- Collect Personal Data for specified purpose(s) and not further process such Personal Data in a manner that is not in relation with those purpose(s);
- Adequately use Personal Data limited to what is necessary in relation to the purposes for which they are processed;
- Keep Personal Data accurate and up to date using every reasonable steps;
- Keep Personal Data in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
- Process Personal Data in a manner that ensures appropriate security, including the protection against unauthorised processing and against accidental loss, destruction or damage.
Fair and transparent Personal Data processing
Any individual may request FundGlobam to disclose all its Personal Data gathered, collected and/or stored by FundGlobam and FundGlobam shall answer to such request within one month starting from the moment of your identity confirmation.
Purposes of Personal Data
All Personal Data gathered, collected and/or stored by FundGlobam shall be the result of a voluntary provision (e.g. the provision of contact details on FundGlobam website), any kind of client or supplier agreement, legal obligation, or any other provision of Personal Data under consent (e.g. through email, discussion, telephone conversation, discussion, etc).
Fundglobam may process your Personal Data for providing you with the information or services you have requested (including a commercial offer or a response to a contact request). If there are other purposes, they will be communicated at the end of each form.
A prior consent will be requested to any individual wishing to receive or authorising FundGlobam to send information or communication (the “Individual’s Prior Consent”); no information or communication shall be made without the Individual’s Prior Consent. In addition, the option to revoke the Individual’s Prior Consent shall be clearly available at any time to ensure an immediate revocation if the revocation is wished by an individual.
Data minimisation
FundGlobam shall ensure that Personal Data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
Accuracy
FundGlobam shall keep Personal Data accurate and up to date using every reasonable steps.
Archiving
To ensure that personal data is kept for no longer than necessary, FundGlobam has a specific archiving policy for Personal Data; this archiving policy may be reviewed on annual basis, For the sake of clarity, the specific archiving policy shall take specific elements into considerations, such as, the reason/the use of a Personal Data stored, as well as the duration of the storage.
Security
FundGlobam shall take all necessary measures to ensure the security of the storage of the Personal Data.
The access to Personal Data governed by the Information Asset Classification policy and shall be limited to personnel who need access for an appropriate usage. In addition, a Security Management policy shall be in place to avoid unauthorised sharing of information.
Any Personal Data deletion must be made in such way that Personal Data are irrecoverable.
The GDPR policy and the Personal Data are entre part of FundGlobam’s Appropriate back-up and disaster recovery.
Breach
FundGlobam shall promptly assess the risk to people’s rights and freedoms in the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised us of, or access to Personal Data.
Duration of the processing
Your Personal Data is stored by FundGlobam only for the time in relation to the purpose of our communication exchanges.
Internal policies
List of internal policies applicable to employee and third parties granted to any part of FundGlobam’s information
The following internal policies are in force and applicable to any FundGlobam’s employee or director, and any third party granted to access a part of FundGlobam’s information:
- CI policy : Confidential Information
- SM policy: Security management
- IAC policy: Information Asset Classification
- IS policy: Internet Security
- ER policy: Email Retention
These policies are confidential information and may be provided to clients or suppliers on request and subject to the prior agreement of the FundGlobam’s confidentiality terms.
Rights
You have a right of objection, deletion of your Personal Data and withdrawal of your consent. You can also request a transfer of your Personal Data.
You may request access to your personal information (commonly called “request for access to his personal data”). This request allows you to receive a copy of your personal information and to verify that we are legally processing this data.
You may request the limitation of the processing of your personal information. This allows you to suspend the processing of your personal information, for example if you want to establish the accuracy or the reason of the data processing.
To request your rights execution, you can contact us via the following email address dpo@fundglobam.com.
You can also file a complaint with the National Commission for Data Protection if you feel that your rights are not respected.