Data Privacy Notice

This notice is designed to provide you with information about the processing of your personal data by New England Asset Management Limited and about your rights according to data protection law.

1 Controller of the processing – Who are we?

New England Asset Management Limited
The Oval – Block 3,
Ballsbridge,
D04 T8F2,
Dublin 4,
Ireland
Telephone: +353-1-673-8500

You can contact our Compliance Officer at the above address, marking your correspondence for the attention of the Compliance Officer, or by e-mail at dublin_compliance@neamgroup.com

2 For what purposes and on what legal basis do we process your data?

We process your personal data while complying with the EU General Data Protection Regulation (GDPR), the Irish Data Protection Acts and all other relevant laws.

2.1 Primary purposes

We obtain personal data for a variety of reasons, not limited to: ensuring compliance with all regulatory obligations, administration and the portfolio management of accounts and related services, accounting services, promotion and advertising, and direct marketing.

2.2 Further purposes

We also process your data in order to safeguard our further legitimate interests and those of third parties. Specifically, this may be necessary for the following purposes:

  • To prevent and detect criminal offences; in particular, we use data analysis in order to identify indications that may suggest fraud. If necessary, to this end, we will also use information available from publicly accessible sources. Provided that it is necessary for the purposes stated herein that we process specific categories of personal data.
  • To ensure IT security and IT operations.

In addition, we process your personal data in order to meet statutory requirements such as supervisory law requirements and retention duties under commercial and other laws. The legal basis for processing in this case is the applicable statutory provisions.

3 Categories of recipients of personal data

3.1 Data processing within the New England Asset Management group of companies

If we have received and processed personal data from you for the above-mentioned purposes, this data is in part also processed by associated companies of New England Asset Management Limited: This happens as part of

  • general IT services provided by the Group
  • internal auditing

3.2 External service providers

In some cases, we use external service providers in the following categories in order to meet some of our contractual and statutory obligations:

  • Data management service providers for the storage and destruction of files
  • IT service providers for the maintenance, operation and securing of systems and applications, data recovery and data destruction
  • Service providers to support application and inventory processing
  • Audit service providers to perform internal audits and IT security audits

4 What rights do you have in relation to your data?

4.1 Right of access

You have the right to request access to the personal data we process about you.

4.2 Right to rectification

You have the right to rectification of inaccurate personal data concerning you.

4.3 Right to erasure

Under certain circumstances, you have the right to erasure of the personal data concerning you.

4.4 Right to restriction

Under certain circumstances, you have the right to restrict the processing of personal data concerning you.

4.5 Right to data portability

You have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format. You have the right to transmit this personal data to a third party without hindrance from us, if technically possible.

4.6 Right to object

If we process your data in order to safeguard legitimate interests you have the right to object to such processing if you have reasons to disagree with the processing of data as a result of your particular situation.

4.7 Right to withdraw from consent

If processing of your personal data is based on your consent, you may withdraw your consent at any time by unsubscribing from an email or sending us an email. Please note that this does not affect the processing of your personal data prior to the withdrawal of your consent.

4.8 Right to lodge a complaint

You have the option to lodge a complaint with the above-mentioned Compliance Officer or a data protection agency of your choice, especially in the EU member state of your residence or the place where the infringement is alleged to have occurred. For details on contacting the Data Protection Commission in Ireland, please refer to the website dataprotection.ie.

4.9 Exercising your rights

If you want to exercise any of your rights as described above or have any question to that, please contact us by sending an email to dublin_compliance@neamgroup.com.

5 Data transmission via a third country

Should we transmit personal data to recipients outside the European Economic Area (EEA), transmission will take place only if the EU Commission has confirmed that the third country has an appropriate level of data protection or that other appropriate data protection guarantees (e.g. binding company-internal data protection provisions or EU standard contract clauses) are in place. Detailed information on this and on the data protection level of recipients in third countries can be requested from the above-mentioned contacts in section 1.

6 Data storage period

We will delete your personal data as soon as it is no longer required for the above-mentioned purposes. However, we may store your personal data for additional periods if we are legally obliged to do so.