This policy sets out how Pacesetter Limited, as a data controller, treats any data it holds in relation to you either as an applicant for business or an existing client.
Pacesetter Limited has an obligation to only hold information that is
In entering into a contract for services with Pacesetter Limited you are agreeing to the legitimate use of your personal data by us. If you do not consent you must inform us immediately.
The policy will cover:
In order to establish a client relationship with you we are obliged under various Isle of Man Legislation and guidance to verify your identity. We will do this by asking you to provide documents such as an application form (for pension management services) a copy of your passport or identity card, proof of your address and tax status and the source of your investment funds and general wealth. We may also refer to specific online data bases or websites to assist us in verifying the information you have provided. When you telephone Pacesetter Limited please note that your call may be recorded.
The information will be provided by you direct or via an agent acting on your behalf. Normally this will be by post, however, more recently emailed and scanned documents have been deemed acceptable in certain circumstances.
We will use the data to establish an account in your name and to manage that account going forward, including providing updates or information in relation to your account, our services, the investment markets or changes to our terms and conditions. You have the option on your application form to confirm how you wish us to contact you and can update these preferences at any time by contacting us.
Isle of Man Regulations state that information must be retained for at least 6 years from the end of your relationship with Pacesetter Ltd. If appropriate after that time, it will be destroyed so that it is not retained for longer than necessary.
We may disclose your personal information to our agents, nominees, investment and banking concerns for the purposes of managing your schedules with us. We will not share your information with any other third party unless obliged to do so by law.
Pacesetter Ltd has safeguards in place to ensure all personal information held electronically is retained securely and tests that these safeguards are sufficiently robust on a regular basis. All paper based personal information is held in locked cabinets. Only authorised staff, our auditors and / or our regulators are able to view your information.
You have the following rights in relation to the personal information we hold about you.
Should you wish to exercise any of your rights please contact our Data Protection Officer, ideally in writing (including electronic formats) with details. Equally Pacesetter Ltd has the right under the Regulations to refuse a request from you where it is deemed excessive or unmerited; if this is the case we will respond to you in writing justifying our decision.