Personal data is data which relates to you when you can be identified from that data or from that data when combined with other information which is in the possession of or is likely to come into the possession of FileTravel. The definition of personal data includes any expression of opinion about you and any indication of the intentions of FileTravel or any other person in respect of you.
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In order to become a client of ours, there is certain information and documentation that we are required to collect in order to comply with our legal and regulatory responsibilities. This includes information about you like your name, address etc, some understanding of the contract you are entering into and a copy of your picture identity document and address verification document. We will use this information for client take on procedures and for ongoing compliance monitoring purposes. This can include public source searching and searching against paid for databases.
We will use your contact information as well as any other information relevant to customer surveys and offers, to send you our Supply of Services Agreement and to keep in touch with you. This might include advising you of new products or services. We will also hold your bank account details in order to make payments to you.
Our policy is to only collect the personal data necessary for agreed purposes.
We may collect your name as well as contact information if you provide that information to us by way of our contact form or any other means. We use this information to respond to any enquiry in the most efficient manner possible. We also use it to send you information on new products or services which might be of interest to you.
You will always have the option of opting out of receiving marketing related contacts from us. We may also use your data to provide analysis of progress against business goals.
All of the data that we process about you is held in the Isle of Man office in paper form and/or electronically. You should be aware that some of this data may be accessible to our staff, when they have the correct permissions, from mobile or laptop devices.
Our client file may be selected by our Anti-Money Laundering & Countering the Financing of Terrorism oversight body for review as part of any checks that they are required to carry out in relation to our compliance with laws and regulations. We will ensure, however, that these parties only have access to the data that they are obliged to review.
We may also share your contact details with any bank with which you request an introduction in order for you to open an account.
Your data will only be available to those FileTravel staff who need to have access to it. Some data may be visible to our website provider.
We will maintain records and data to comply with our statutory, legal and regulatory responsibilities as well as what we deem to be reasonable practice where there is no record keeping period set down in law or other rules. We will destroy client data in line with these retention periods.
If you have engaged with us via the website or any other means and this does not proceed to a business relationship, we will destroy the data provided one year after the date of your enquiry unless you provide us with consent to hold your data for marketing purposes.
If you have specific queries in relation to retention periods, please email our Data Protection Officer at the contact details below.
If you wish to see the data processed about you by FileTravel, please contact our Data Protection Officer at the contact details below.
You have additional rights under the Data Protection Act 2018 or any legislation which replaces it such as the right to rectification of incomplete data and the right of erasure of data.
An important right that you have is the right to object to processing. This right applies where, after careful consideration, we have decided that it is in the legitimate interests of FileTravel to process data about you. We process data for our legitimate interests where we undertake searches against public sources and paid for databases to assist with our compliance obligations.
You have the right to receive the personal data you provide to us in a structured, commonly used and machine readable format and have the right to transmit this data to another controller, without hindrance from us.
If you wish to exercise those rights, please contact our Data Protection Officer at the contact details below.
If you wish to make a complaint about how we have processed your data, please contact our Data Protection Officer at Burleigh Manor, Peel Road, Douglas, Isle of Man, IM1 5EP. You can also contact the Information Commissioner on 01624 693260 or by emailing firstname.lastname@example.org.
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