Our company also provides various online services to customers, end users, job applicants and other interested parties. In providing these services, we process privacy-sensitive data, also known as personal data. In some cases we do so together with other organizations or companies.
We consider it extremely important that personal data are handled with care. We therefore process and protect personal data with the greatest possible care, in compliance with applicable privacy legislation. This means, for example, that:
we clearly describe the purposes for which we process personal data; we do so in this privacy statement;
we only collect personal data that are required for the purposes for which they are processed;
we will first ask you to give your express consent for the processing of your personal data in cases where your consent is required;
we will not transfer your data to third parties, except if this is necessary to provide the service requested, if you have given your consent or if we are required by law to do so;
if we share your data, we make arrangements with third parties to ensure, inter alia, that your data are not used for other purposes;
we will take appropriate security measures to protect your personal data and also require parties processing personal data on our behalf to do the same;
we respect your right to request access to or rectification or erasure of your personal data.
If you have any questions or comments about this privacy statement, please contact us:
by telephone: +31 70 219 00 00 (during office hours)
by email: firstname.lastname@example.org
SIGNATURE Agri Investments
Monarch Tower, 7th Floor
Pr. Beatrixlaan 5
2595 AK The Hague
This Privacy Notice explains how we obtain, use and disclose your personal information and aims to inform you of your rights and how to exercise them.
This Privacy Notice sets out:
Who we are
What personal information we collect and where we collect it from
The purposes for which we use your personal information
To whom we disclose your personal information
How we safeguard your personal information
Your rights to access, correct and delete your personal information
How to contact us
The Information Regulator’s contact details
WHO WE ARE
In this Privacy Notice, “SIGNATURE”, or “we” refers SIGNATURE Agri Investments Proprietary Limited and its affiliates. “Old Mutual Group” refers to Old Mutual Limited and its subsidiaries.
THE INFORMATION WE COLLECT
We collect and process your personal information mainly to provide the investment management services as contemplated in our agreement(s) with you (and any services ancillary thereto, including as part of our onboarding processes), to grant you access to our services and financial products, to help us improve our offerings to you and for certain other purposes explained below. In order for us to do this, it is incumbent upon you to provide us with the personal information that we request, failing which we cannot enter into a relationship with you, assist you or fully comply with our contractual obligations to you.
When you provide us with information about third parties (for example your clients, service providers or parties related to you), we will process their personal information in order to give effect to our agreement and in order to pursue your and our legitimate interests. We will furthermore process personal information for the purposes set out in this Privacy Notice. You warrant that, when you give us personal information about third parties, this information is accurate and correct and you have received their permission or, in respect of a person under 18 years of age, you confirm that a competent person consented, to the sharing of their personal information with us for the purposes set out in this Privacy Notice or any other related purposes.
The type of information we collect will depend on the purpose for which it is collected and used as set out herein. We will only collect information that we need for that purpose.
We collect information directly from you where you provide us with your personal details, for example when you apply for a product or services from us or when you submit enquiries to us or contact us.
We also collect information, including criminal information, about you and/or your related parties from other sources, such as:
Third parties for the purposes listed below, for example credit reference, anti-money laundering and fraud prevention and law enforcement agencies.
Other companies in the Old Mutual Group for the purposes listed below, or when we believe it will enhance the services and financial products we can offer to you, but only where you have not objected to such sharing. This includes supplementing the information that you provide to us with information we receive from other member companies in the Old Mutual Group in order to offer you a more consistent and personalized experience in your interactions with SIGNATURE Agri Investments, and to ensure that we have updated information about you.
We have a duty to take all reasonably practicable steps to ensure your personal information is complete, accurate, not misleading and that it is updated on a regular basis. To enable this, we will always try to obtain personal information from you directly, and we will appreciate it if you would similarly ensure that your personal information processed by us, is up to date and accurate. You can do so by engaging your SIGNATURE Agri Investments relationship manager or stakeholder whenever your details change or by contacting us at email@example.com
Where we are unable to obtain personal information from you directly, we will make use of verifiable independent third party data sources.
PURPOSES FOR WHICH WE USE YOUR INFORMATION
We will use your personal information only for the following purposes:
to conclude a legal agreement with you and to perform the obligations required in terms of such agreement which includes, investment management services such as managing your portfolio, reporting to you, and to keep you apprised on developments pertaining to your portfolio(s).
to pursue our legitimate business interests, which includes:
(i) compiling relevant reports;
(ii) complying with requests from any internal or external auditor, or any regulatory or supervisory body,
(iii) compliance with any regulatory requirements and/or industry codes applicable to the financial services industry;
(iv) corresponding with you;
(v) confirming and verifying our identity, address and banking details and maintaining the accuracy thereof;
(vi) conducting the requisite client identification and verification processes as required in terms of the Financial Intelligence Centre Act;
(vii) to conduct sanction screening against all mandatory and non-mandatory sanctions lists (in this instance, we may communicate such personal information to local and international regulatory bodies as well as to other entities in the Old Mutual Group (if you are matched to one of these sanctions lists);
(viii) detecting and preventing fraud, crime and money-laundering (or any other malpractice);
(ix) Offering financial products and/or services to you;
(x) Maintaining our business relationship with you
(xi) Conducting market and/or client satisfaction research for statistical analysis;
(xii) Protecting our and/or your interest(s) in legal proceedings;
(xiii) processing your marketing preferences (and, where you have unsubscribed from certain direct marketing communications, keeping a record of your information and request to ensure that we do not send such direct marketing to you again); and
(xiv) Resolving any complaint.
DISCLOSURE OF INFORMATION
We may disclose your personal information to our service providers who are involved in the delivery of the financial products and/or services to you. We have agreements in place to ensure that they comply with these privacy terms.
We may share your personal information with:
Third parties for the purposes listed above, for example fraud prevention agencies, law enforcement agencies.
Other companies / entities in the Old Mutual Group for the purposes listed above, or when we believe it will enhance the services and financial products we can offer to you, but only where you have not objected to such sharing.
Other third parties from whom you have chosen to receive marketing information.
We may also disclose your personal information:
Where we have a duty or a right to disclose in terms of law or industry codes; or
Where we believe it is necessary to protect our rights.
We are legally obliged to provide adequate protection for the personal information we hold and to stop the unauthorised access and use thereof. We will, on an ongoing basis, continue to review our security controls and related processes to ensure that your personal information is secure.
Our security policies and procedures cover:
Computer and network security;
Access to personal information
Security in contracting out activities or functions
Retention and disposal of personal information
Acceptable usage of personal information
Governance and regulatory aspects
Monitoring access and usage of personal information
Investigating and reacting to security incidents
When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information that we remain responsible for, is kept secure.
We may wish to transfer your personal information to another country for processing or storage. We will ensure that anyone to whom we pass your personal information agrees to treat your personal information with the same level of protection as we are obliged to.
We will take all reasonable steps to confirm your identity when you exercise your rights.
Access to information
You have the right to request a copy of the personal information we hold about you. You can engage your SIGNATURE Agri Investments relationship manager or stakeholder directly to review your personal information or contact us at firstname.lastname@example.org and specify what information you would like.
Please note that any such access request may be subject to a payment of a legally permissible fee.
Objection to processing
In certain cases, you have the right to object to the processing of your personal information. If you want to object, please engage your SIGNATURE Agri Investments relationship manager or stakeholder directly or contact us at email@example.com
Correction of your personal information
You have the right to ask us to update or correct your personal information. You may do this by engaging your SIGNATURE Agri Investments relationship manager or stakeholder directly to review and change your personal information or by contacting us at firstname.lastname@example.org
Deletion of your personal information
You agree that we may keep your personal information until we destroy your information based on SIGNATURE’s Agri Investments destruction standards. You have the right to ask for deletion or destruction of your personal information – we will do that unless the law requires us to keep it or if we require retention for legitimate business purposes, in which event we will continue to protect such information as detailed above. You may do this by engaging your SIGNATURE Agri Investments relationship manager or stakeholder directly or contacting us at email@example.com
Automated decision making
You agree that we may process your personal information by using automated means (without human intervention in the decision making process) to make a decision about you or your application for any product(s) and/ or service. You may query the decision made about you.
Third party websites
This privacy statement does not apply to third party websites to which our website links as we cannot guarantee that those websites handle your personal data in a secure and careful manner. We encourage you to read the privacy statements on those other websites for more information on how they deal with your data before making use of those websites.
If you are 16 years or younger, you may use our website only under the supervision of your parents or legal representatives.
Changes to this privacy statement
We may review this privacy statement from time to time. Any changes will be notified to you by posting an updated version on our website. We never use your data for other purposes without your consent.
We therefore advise you to revisit this privacy statement on a regular basis to ensure you are familiar with its terms and any changes made.
HOW TO CONTACT US
If you have questions about this Privacy Notice or believe we have not adhered to it, or need further information about our privacy practices, please engage your SIGNATURE Agri Investments relationship manager or stakeholder directly or contact us at firstname.lastname@example.org
Dutch Data Protection Authority
If you have any complaints about our processing of your personal data, we will do all we can to resolve the matter. If we are unable to settle the matter to our mutual satisfaction, you have the right under applicable data protection laws to submit your complaint to the supervisory authority, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
Effective date - The effective date of this privacy statement is 13th December 2021