Privacy Policy
Introduction and Purpose
The Data Protection (Bailiwick of Guernsey) Law, 2017 (“the Law”) governs the controlling and processing, such as the use or holding, of personal data, which is essentially any information about identifiable living individuals, and also gives those individuals certain rights and remedies in respect of that information.
The purpose of this notice is to supply you with the required information at the time of providing us with your personal data. This will lay out the essentials such as to the what; where; when; and how in relation to the personal information collected. This should help you feel more confident about the privacy and the security of your personal information.
Please read this Privacy Notice carefully. By visiting our website or using any of our services, you indicate your agreement to our use of your personal information as set out in this Privacy Notice.
Identity and contact details of the Data Controller
Nexus Portfolio Management Limited (company number 67291) whose registered office is at PO Box 488, Anson Court, La Route des Camps, St Martin, Guernsey GY1 6BR is the Data Controller and is committed to protecting the rights of individuals in line with the Law.
Information we collect about you and why
We will collect information from you when you apply to use any of our services, become our client, or contact us in person, by telephone, by email or by post.
We may collect information about you from fraud prevention agencies and other organisations when we undertake checks such as identification verification checks, as explained further below.
We do not use cookies for collecting user information from the site and we will not collect any information about you except that required for system administration of the Web server.
We may collect the following specific information depending on the service provided:
· Your contact details, such as your name, address, telephone number and email address;
· Your date of birth, nationality, country of birth, country of residence, employment status and tax identification number (i.e. National Insurance Number);
· Passport details, driving licence and utility bills;
· Details of the services you request from us;
· Any records held by financial crime prevention agencies, on the Electoral Register and by providers of utility services; and
· Details of your employment status, income and source of wealth.
How will we use your information?
We use information held by us in the following ways:
- to process your application to use our services;
- to undertake checks such as identification verification checks to enable us to comply with our anti-money laundering obligations and for the purposes of crime prevention and fraud prevention;
- to comply with our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to help protect your information and prevent unauthorised access to it;
- to deal with any queries, complaints or problems reported by you;
- if required to do so by law and to the extent necessary for the proper operation of our systems, to protect us/our clients, or for the enforcement of any agreement between you and us;
- to notify you of changes to our services; and
- to help improve the services we provide to you.
Unless otherwise stated in this Privacy Notice, the legal basis for our use of your personal data will be that this information is required for one or more of the legitimate interests described above.
How will we protect your information?
We take appropriate security measures (including physical, electronic and procedural measures) to help protect the confidentiality, integrity and availability of your personal information from unauthorised access and disclosure.
Data retention
We are committed to only keeping your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this notice, and for as long as we are required or permitted to keep it by law.
We retain copies of our client contracts in order to enable us to deal with any legal issues and the information provided to us for identification verification checks, financial crime and anti-money laundering checks (as required by law) for 7 years after termination or expiry of our contract with you.
We retain details of complaints for 7 years from the date of receipt.
We shall keep records of the following for 7 years:
- call recordings, electronic communications and minutes of face-to-face meetings;
- suitability and appropriateness assessments;
- periodic statements (for example, valuations); and
- all orders and transactions in financial instruments on your behalf (including information about your identity).
Nexus Portfolio Management Limited retain copies of all records aforementioned for a maximum of 7 years.
Your rights
You have a right to learn and have access to what personal information is held by Nexus Portfolio Management Limited and be able to ask us for details on this.
When we receive such a request we will endeavour to provide you with these details without delay and at the latest within one month of receipt.
We may extend the period of compliance by a further two months where requests are complex or numerous. In such instances we will inform you within one month of the receipt of the request and explain why the extension is necessary.
When we receive a subject access request we will provide a copy of the information held free of charge. However, we may charge a reasonable fee to comply with requests for further copies of the same information. This does not mean that we will charge for all subsequent access requests rather that the Nexus Portfolio Management Limited reserves the right to charge a fee based on the administrative cost of providing the information.
If after reviewing a request Nexus Portfolio Management Limited believes a request is manifestly unfounded or excessive, particularly if it is repetitive, then we may charge a ‘reasonable fee’ which will be decided on a case by case basis. In certain circumstances we may even refuse to respond to such requests.
You also have the following rights (unless exemptions apply), which can be exercised by contacting us using the details provided below.
- Right to information for personal data collected from data subject
- Right of access
- Right to object to processing for direct marketing purposes
- Right to object to processing on grounds of public interest
- Right to object to processing for historical or scientific purposes
- Right to rectification
- Right to erasure
- Right to restriction of processing
- Right not to be subject to decisions based on automated processing
- Right to data portability
If you wish to submit a request or have any questions about our use of your personal data, please contact the Data Protection Officer by email at info@nexus-npml.com or in writing (see details below).
Contact details Data Protection Officer
The Data Protection Officer, Nexus Portfolio Management Limited, PO Box 488 Anson Court, La Route des Camps St Martin, Guernsey GY1 6BR . T +44 (0)1481 661980 E info@nexus-npml.com
Should you wish to make a complaint
Nexus Portfolio Management Limited is registered with the Office of the Data Protection Authority under registration number DPA2085.
If at any time you are concerned with the information held, the way in which we hold it or are unhappy with any response from us in relation to information held or with any other element relating to your personal information, you may lodge a complaint directly with the Office of the Data Protection Commissioner, Office of the Data Protection Authority, Block A, Lefebvre Court, Lefebvre Street, St. Peter Port, Guernsey, GY1 2JP. The ODPA can be contacted at info@odpa.gg. Details of the complaints and appeals processes are available on their website at www.odpa.gg.
Changes to this policy
This privacy policy may be updated from time to time in accordance with the Data Protection (Bailiwick of Guernsey) Law, 2017.