What data do we store and for how long
We provide portfolio management and investment advice and therefore collect information from our clients in order to provide these investment services. Information that we collect includes name, date of birth, occupation, place of residence, employer and information about financial conditions that form the basis of the suitability assessment that we are obliged by law to make.
Our operations are also covered by the Money Laundering Act's rules on KYC, which is why we also need to collect and store information that is required to carry out the controls that we are obliged to carry out.
As a general rule, we store your personal data as long as the agreement with you is valid. In some cases, we have legal obligations to store the data for a longer period than this, for example due to money laundering legislation or as long as a claim for damages due to the provision of the investment services can be made plus one year. This means that we store the information for eleven years after our agreement has ended.
Brock Milton Capital AB has appointed Coeli Asset Management AB as data protection officer. If you have questions about our personal data handling, contact our data protection officer via dataskyddsombud@coeli.se.
The purpose of the data collection
We collect information to make contact, establish and/or maintain a business relationship or inquiry. We also collect personal data in order to fulfill our obligations according to the laws that apply to our operations, e.g. the Money Laundering Act. The legal basis for the processing of the personal data is the execution of the agreement we have with you and our legal obligations in relation to the provision of our services and products. Sometimes we rely on the legal grounds of legitimate interest and consent, which applies primarily to the development of our services and products, etc. and marketing.
Change/deletion and right to information about personal data
You always have the possibility and the right to request access to the information we have stored. You also have the right to request changes or deletion of your data. To do this, contact our data protection officer via dataskyddsombud@coeli.se. When you are a customer with us, we always need your information to be able to complete our collaboration. We may also need to save your data for a longer period of time even after the customer relationship has ended, if this follows from mandatory legislation that applies to our business.
Your rights
In accordance with the Data Protection Regulation, you have a number of rights that you can use when we process your personal data. If you want to know whether or not we process your personal data, you also have the right to receive that information from us.
Below follows a description of your rights and how you should proceed to protect your rights.
The right of access (including the right to register extracts)
You have the right to receive confirmation of whether we are processing personal data about you and, in such cases, access to your data, as well as the right to receive a copy of your personal data that is being processed (so-called "register extract"). You have the right to receive a register extract that shows which personal data is registered about you, the purposes of the processing of your personal data and categories of personal data to which the processing applies completely free of charge.
If you wish to receive an extract from the register, please contact the Data Protection Ombudsman at dataskyddsombud@coeli.se.
The right to rectification
You have the right to request that any incorrect information about you be corrected and also demand that we limit our processing of your personal data during the time that we investigate your request for correction. You also have the right to request the completion of any incomplete information that we have about you.
If you wish to have information corrected, you can request this by contacting your contact person at Brock Milton Capital or alternatively contact the data protection officer through dataskyddsombud@coeli.se.
The right to erasure (“The right to be forgotten”)
In certain cases, you have the right to have the data we process about you deleted. This applies in the following situations:
- the personal data are no longer necessary for the purposes of the processing,
- you withdraw your consent on which the processing is based,
- if you have objected to the processing which is supported/is based on balancing of interests and we are not considered to have a legitimate interest in continued processing that outweighs your interest,
- if the processing takes place for direct marketing and you object to the data being processed,
– the personal data has been processed in an illegal manner, or
– if deletion is required to fulfill a legal obligation.
We cannot always accommodate a request for deletion. For example, there may be legal requirements that require us to retain the personal data or if we need the information to be able to fulfill an agreement with you.
If you wish to have data deleted, you can request this by contacting the data protection officer via dataskyddsombud@coeli.se.
The right to limitation
You have the right to request that our processing of your personal data be limited. A limitation can be made for several reasons, for example:
- If you dispute that the personal data that we process about you is correct, you can request limited processing during the time that we check whether the data is correct.
- If the processing is illegal and you object to the deletion of the personal data, you can instead request a limitation on the use of your personal data.
- If we, as the personal data controller, no longer need the personal data for the purposes of the processing but you need it to be able to establish, enforce or defend legal claims.
If a limitation occurs, we may only, in addition to storing the data, process the data to establish, assert or defend legal claims, to protect someone else's rights or because you have given your consent. If you have received a limitation on your personal data, we will inform you when the limitation ends.
If you wish to receive limited information, you can request this by contacting your contact person at us, alternatively contact the data protection officer through dataskyddsombud@coeli.se.
The right to object
You have the right to object at any time to our processing of your personal data which is supported on a balancing of interests as a legal basis (legitimate interest) including profiling. Only in these cases where we can demonstrate that our legitimate interest outweighs your interest can we continue with the processing. Otherwise, we may only process the data to establish, exercise or defend legal claims. You also have the right to object at any time to processing carried out for direct marketing, including profiling in cases where it has taken place in connection with direct marketing. If you have objected to processing for direct marketing, we may no longer process your data for such purposes. If you wish to object to our processing, please contact data protection ombudet@coeli.se.
The right to data portability
In certain situations, you have the right to have your personal data transferred in electronic format to another personal data controller (so-called "data portability"). This provided that the transfer is technically possible and can take place in an automated manner. The right to data portability applies to data which is supported by the fulfillment of an agreement or consent as a legal basis and may only be data that you have provided to us.
If you wish data portability of your data, contact the data protection officer at dataskyddsombud@coeli.se.