Welcome to Investor Profit Portfolio Ltd

Offices in UK & Gibraltar

UK 9:00 AM - 5:00 PM

Monday to Friday

Privacy Policy

PRIVACY NOTICE

DEFINITION

Investor Profit Portfolio LIMITED and subsidiaries companies will hereafter be referred to as “Investor Profit Portfolio LIMITED”

INTRODUCTION

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.

Investor Profit Portfolio LIMITED is pleased to provide the following Privacy Notice:

PERSONAL DATA

Investor Profit Portfolio LIMITED uses the information collected from you to provide quotations, make telephone contact and to email you marketing information which Investor Profit Portfolio LIMITED believes may be of interest to you and your business. In you making initial contact you consent to Investor Profit Portfolio LIMITED maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. Investor Profit Portfolio LIMITED also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, Investor Profit Portfolio LIMITED will be acting on the instruction of its client, and will work hard to ensure that the client is fully GDPR compliant.

Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. Investor Profit Portfolio LIMITED may from time to time use such information to identify its visitors. Investor Profit Portfolio LIMITED may also collect statistics about the behavior of visitors to its website.

Investor Profit Portfolio LIMITED website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Concrete 5 and the Investor Profit Portfolio LIMITED Portal uses cookies to help Investor Profit Portfolio LIMITED identify and track visitors and their website access preferences. Investor Profit Portfolio LIMITED website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Investor Profit Portfolio LIMITED website.

Any information Investor Profit Portfolio LIMITED holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtained about you from public sources and our own suppliers such as credit referencing agencies.

Investor Profit Portfolio LIMITED will only collect the information needed so that it can provide you with marketing and consulting services, this agency does not sell or broker your data, although coincidentally there may be times when your information could be contained in data that Investor Profit Portfolio LIMITED has purchased from a third-party list broker, on behalf of a client.

LEGAL BASIS FOR PROCESSING ANY PERSONAL DATA

To meet Investor Profit Portfolio LIMITED contractual obligations to clients and to also respond to marketing enquiries.

LEGITIMATE INTERESTS PURSUED BY Investor Profit Portfolio LIMITED AND/OR ITS CLIENTS

To promote the marketing and consulting services offered by Investor Profit Portfolio LIMITED and/or to market the services and/or products offered by Investor Profit Portfolio LIMITED’ existing clients.

CONSENT

Through agreeing to this privacy notice you are consenting to Investor Profit Portfolio LIMITED processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing admin@investorprofitportfolio.com or writing to us, see last section for full contact details.

DISCLOSURE

Investor Profit Portfolio LIMITED may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. Investor Profit Portfolio LIMITED requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR.

Investor Profit Portfolio LIMITED do not broker or pass on information gained from your engagement with the agency without your consent. However, Investor Profit Portfolio LIMITED may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The agency may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Investor Profit Portfolio LIMITED, its clients and/or the wider community.

RETENTION POLICY

Investor Profit Portfolio LIMITED will process personal data during the duration of any contract and will continue to store only the personal data needed for five years after the contract has expired to meet any legal obligations. After five years any personal data not needed will be deleted.

DATA STORAGE

Data is held in Gibraltar using multiple servers. Investor Profit Portfolio LIMITED does not store personal data outside the EEA.

YOUR RIGHTS AS A DATA SUBJECT

At any point whilst Investor Profit Portfolio LIMITED is in possession of or processing your personal data, all data subjects have the following rights:

  • Right of access– you have the right to request a copy of the information that we hold about you.
  • Right of rectification– you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten– in certain circumstances, you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing– where certain conditions apply you have a right to restrict the processing.
  • Right of portability– you have the right to have the data we hold about you transferred to another organisation.
  • Right to object– you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling– you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that Investor Profit Portfolio LIMITED refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

Investor Profit Portfolio LIMITED at your request can confirm what information it holds about you and how it is processed

YOU CAN REQUEST THE FOLLOWING INFORMATION:

  • Identity and the contact details of the person or organisation (Investor Profit Portfolio LIMITED) that has determined how and why to process your data.
  • Contact details of the Data Protection Officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Investor Profit Portfolio LIMITED or a third party such as one of its clients, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority (Data Protection Regulator).
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

TO ACCESS WHAT PERSONAL DATA IS HELD, IDENTIFICATION WILL BE REQUIRED

Investor Profit Portfolio LIMITED will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Investor Profit Portfolio LIMITED is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to admin@investorprofitportfolio.com or by phoning 02036088995  or writing to us at the address further below.

COMPLAINTS

In the event that you wish to make a compliant about how your personal data is being processed by Investor Profit Portfolio LIMITED or its partners, you have the right to complain to Investor Profit Portfolio LIMITED Head of Operations. If you do not get a response within 30 days you can complain to the Data Protection Regulator.

The details for each of these contacts are:

Investor Profit Portfolio LIMITED, attention of the Head of Operations

The Alcove, Office 1, 3rd Floor Montarik House, Gibraltar

Telephone 02036088995 or email admin@investorprofitportfolio.com

Data Protection Regulator Website: https://investorprofitportfolio.com

DATA PROTECTION POLICY

Investor Profit Portfolio LIMITED and subsidiaries companies will hereafter be referred to as “Investor Profit Portfolio LIMITED”

  1. PURPOSE

This policy establishes an effective, accountable and transparent framework for ensuring compliance with the requirements of the GDPR.

  1. SCOPE

This policy applies to all Investor Profit Portfolio LIMITED employees and all third parties responsible for the processing of persona data on behalf of Investor Profit Portfolio LIMITED services/entities.

  1. POLICY STATEMENT

Investor Profit Portfolio LIMITED is committed to conducting its business in accordance with all applicable data protection laws and regulations and in line with the highest standards of ethical conduct.

This policy sets forth the expected behaviours of Investor Profit Portfolio LIMITED employees and third parties in relation to the collection, use, retention, transfer, disclosure and destruction of any personal data belonging to an Investor Profit Portfolio LIMITED contact (i.e. the data subject).

Personal data is any information (including opinions and intentions) which relates to an identified or identifiable natural person. Personal data is subject to certain legal safeguards and other regulations, which impose restrictions on how organisations may process personal data. An organisation that handles personal data and makes decisions about its use is known as a Data Controller. Investor Profit Portfolio LIMITED, as a Data Controller, is responsible for ensuring compliance with the data protection requirements outlined in this policy. Non-compliance may expose Investor Profit Portfolio LIMITED to complaints, regulatory action, fines and/or reputational damage.

Investor Profit Portfolio LIMITED leadership is fully committed to ensuring continued and effective implementation of this policy and expects all Investor Profit Portfolio LIMITED employees and third parties to share in this commitment. Any breach of this policy will be taken seriously and may result in disciplinary action or business sanction.

3.1 DATA PROTECTION PRINCIPLES

Investor Profit Portfolio LIMITED has adopted the following principles to govern its collection, use, retention, transfer, disclosure and destruction of personal data:

Principle 1: Lawfulness, Fairness and Transparency. Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject. This means, Investor Profit Portfolio LIMITED must tell the data subject what processing will occur (transparency), the processing must match the description given to the data subject (fairness), and it must be for one of the purposes specified in the applicable data protection regulation (lawfulness).

Principle 2: Purpose Limitation. Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. This means Investor Profit Portfolio LIMITED must specify exactly what the personal data collected will be used for and limit the processing of that personal data to only what is necessary to meet the specified purpose.

Principle 3: Data Minimisation. Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. This means Investor Profit Portfolio LIMITED must not store any personal data beyond what is strictly required.

Principle 4: Accuracy. Personal data shall be accurate and, kept up to date. This means Investor Profit Portfolio LIMITED must have in place processes for identifying and addressing out-of-date, incorrect and redundant personal data.

Principle 5: Storage Limitation. Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. This means Investor Profit Portfolio LIMITED must, wherever possible, store personal data in a way that limits or prevents identification of the data subject.

Principle 6: Integrity & Confidentiality. Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing, and against accidental loss, destruction or damage. Investor Profit Portfolio LIMITED must use appropriate technical and organisational measures to ensure the integrity and confidentiality of personal data is maintained at all times.

Principle 7: Accountability. The Data Controller shall be responsible for, and be able to demonstrate compliance. This means must demonstrate that the six data protection principles (outlined above) are met for all personal data for which it is responsible.

3.2 DATA COLLECTION

3.2.1. Data Sources

Personal data should be collected only from the data subject unless one of the following apply:

  • The nature of the business purpose necessitates collection of the personal data from other persons or bodies.
  • The collection must be carried out under emergency circumstances in order to protect the vital interests of the data subject or to prevent serious loss or injury to another person.
  • The data subject already has the information;
  • A legal exemption applies to the requirements for disclosure and/or consent. The disclosures may be given electronically or in writing. The associated receipt or form should be retained, along with a record of the facts, date, content, and method of disclosure.

If personal data is collected from someone other than the data subject, the data subject must be informed of the collection unless one of the following apply:

  • The data subject has received the required information by other means.
  • The information must remain confidential due to a professional secrecy obligation
  • A national law expressly provides for the collection, processing or transfer of the personal data.

Where it has been determined that notification to a data subject is required, notification should occur promptly, but in no case later than:

  • One calendar month from the first collection or recording of the personal data
  • At the time of first communication if used for communication with the data subject
  • At the time of disclosure if disclosed to another recipient.

3.2.2. DATA SUBJECT CONSENT

Each Investor Profit Portfolio LIMITED service/entity will obtain personal data only by lawful and fair means and, where appropriate with the knowledge and consent of the individual concerned. Where a need exists to request and receive the consent of an individual prior to the collection, use or disclosure of their personal data, Investor Profit Portfolio LIMITED is committed to seeking such consent. The Head of Operations, in cooperation with other relevant business representatives, shall establish a system for obtaining and documenting data subject consent for the collection, processing, and/or transfer of their personal data.

3.2.3. DATA SUBJECT NOTIFICATION

Each Investor Profit Portfolio LIMITED service/entity will, when required by applicable law, contract, or where it considers that it is reasonably appropriate to do so, provide data subjects with information as to the purpose of the processing of their personal data. When the data subject is asked to give consent to the processing of personal data and when any personal data is collected from the data subject, all appropriate disclosures will be made, in a manner that draws attention to them, unless one of the following apply:

3.2.4. EXTERNAL PRIVACY NOTICES

Each external website provided by Investor Profit Portfolio LIMITED will include an online ‘Privacy Notice’ and an online ‘Cookie Notice’ fulfilling the requirements of applicable law.

3.3 DATA USE

3.4.1. DATA PROCESSING

Investor Profit Portfolio LIMITED uses the personal data of its contacts for the following broad purposes:

  • The general running and business administration of Investor Profit Portfolio LIMITED services/entities.
  • To provide services to Investor Profit Portfolio LIMITED stakeholders.
  • The ongoing administration and management of customer services.

The use of a contact’s information should always be considered from their perspective and whether the use will be within their expectations or if they are likely to object. For example, it would clearly be within a contact’s expectations that their details will be used by Investor Profit Portfolio LIMITED to respond to a contact request for information about the products and services on offer. However, it will not be within their reasonable expectations that Investor Profit Portfolio LIMITED would then provide their details to third parties for marketing purposes.

Each Investor Profit Portfolio LIMITED service/entity will process personal data in accordance with all applicable laws and applicable contractual obligations. More specifically, Investor Profit Portfolio LIMITED will not process personal data unless at least one of the following requirements are met:

  • The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Processing is necessary for compliance with a legal obligation to which the Data Controller is subject.
  • Processing is necessary in order to protect the vital interests of the data subject or of another natural person.
  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.
  • Processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, in particular where the data subject is a child).
  • In any circumstance where consent has not been gained for the specific processing in question, Investor Profit Portfolio LIMITED will address the following additional conditions to determine the fairness and transparency of any processing beyond the original purpose for which the personal data was collected: Any link between the purpose for which the personal data was collected and the reasons for intended further processing.
  • The context in which the personal data has been collected, in particular regarding the relationship between data subject and the Data Controller.
  • The nature of the personal data, in particular whether special categories of data are being processed, or whether personal data related to criminal convictions and offences are being processed.
  • The possible consequences of the intended further processing for the data subject.
  • The existence of appropriate safeguards pertaining to further processing, which may include encryption, anonymisation or pseudonymisation.
  • Correcting personal data known to be incorrect, inaccurate, incomplete, ambiguous, misleading or outdated, even if the data subject does not request rectification.
  • Keeping personal data only for the period necessary to satisfy the permitted uses or applicable statutory retention period.
  • The removal of personal data if in violation of any of the data protection principles or if the personal data is no longer required.
  • Restriction, rather than deletion of personal data, insofar as:
    • a law prohibits erasure.
    • erasure would impair legitimate interests of the data subject.
    • the data subject disputes that their personal data is correct and it cannot be clearly ascertained whether their information is correct or incorrect.
  • The prevention or detection of crime.
  • The apprehension or prosecution of offenders.
  • The assessment or collection of a tax or duty.
  • By the order of a court or by any rule of law.
  • The data subject has given Consent to the proposed transfer.
  • The transfer is necessary for the performance of a contract with the data subject
  • The transfer is necessary for the implementation of pre-contractual measures taken in response to the data subject’s request.
  • The transfer is necessary for the conclusion or performance of a contract concluded with a third party in the interest of the data subject.
  • The transfer is legally required on important public interest grounds.
  • The transfer is necessary for the establishment, exercise or defence of legal claims.
  • The transfer is necessary in order to protect the vital interests of the data subject

There are some circumstances in which personal data may be further processed for purposes that go beyond the original purpose for which the personal data was collected. When making a determination as to the compatibility of the new reason for processing, guidance and approval will be obtained from Board of Directors before any such processing may commence.

3.4.2 SPECIAL CATEGORIES OF DATA

Investor Profit Portfolio LIMITED does not currently possess, store or process special categories of data (also known as sensitive data).

In any situation where special categories of data are to be processed, prior approval must be obtained from the Head of Operations, and the basis for the processing clearly recorded with the personal data in question. Where special categories of data are being processed, Investor Profit Portfolio LIMITED will adopt additional protection measures.

3.4.3 CHILDREN’S DATA

Persons/Children under the age of 16 are not permitted to access the Investor Profit Portfolio LIMITED systems and services or have access to customer data.

3.4.4 DATA QUALITY

Each Investor Profit Portfolio LIMITED service/entity will adopt all necessary measures to ensure that the personal data it collects and processes is complete and accurate in the first instance, and is updated to reflect the current situation of the data subject. The measures adopted by Investor Profit Portfolio LIMITED to ensure data quality include:

3.4.5. PROFILING & AUTOMATED DECISION MAKING

Investor Profit Portfolio LIMITED will only engage in profiling and automated decision-making where it is necessary to enter into, or to perform, a contract with the data subject or where it is authorised by law. Where a Investor Profit Portfolio LIMITED service/entity utilises profiling and automated decision-making, this will be disclosed to the relevant data subjects. In such cases the data subject will be given the opportunity to:

  • Express their point of view.
  • Obtain an explanation for the automated decision.
  • Review the logic used by the automated system.
  • Supplement the automated system with additional data.
  • Have a human carry out a review of the automated decision.
  • Contest the automated decision.
  • Prevent unauthorised persons from gaining access to data processing systems in which personal data are processed.
  • Prevent persons entitled to use a data processing system from accessing personal data beyond their needs and authorisations.
  • Ensure that personal data in the course of electronic transmission during transport cannot be read, copied, modified or removed without authorisation.
  • Ensure that access logs are in place to establish whether, and by whom, the personal data was entered into, modified on or removed from a data processing system.
  • Ensure that in the case where processing is carried out by a Data Processor, the data can be processed only in accordance with the instructions of the Data Controller.
  • Ensure that personal data is protected against undesired destruction or loss.
  • Ensure that personal data collected for different purposes can and is processed separately.
  • Ensure that personal data is not kept longer than necessary
  • Information access.
  • Objection to processing.
  • Objection to automated decision-making and profiling.
  • Restriction of processing.
  • Data portability.
  • Data rectification.
  • Data erasure. If an individual makes a request relating to any of the rights listed above

Object to the automated decision-making being carried out. Each Investor Profit Portfolio LIMITED service/entity must also ensure that all profiling and automated decision-making relating to a data subject is based on accurate data.

3.4.6 DIGITAL MARKETING

As a general rule Investor Profit Portfolio LIMITED will not send promotional or direct marketing material to a Investor Profit Portfolio LIMITED Contact through digital channels such as mobile phones, email and the Internet, without first obtaining their consent. Any Investor Profit Portfolio LIMITED service/entity wishing to carry out a digital marketing campaign without obtaining prior Consent from the data subject must first have it approved by the Head of Operations. Where personal data processing is approved for digital marketing purposes, the data subject must be informed at the point of first contact that they have the right to object, at any stage, to having their data processed for such purposes. If the data subject puts forward an objection, digital marketing related processing of their personal data must cease immediately, and their details should be kept on a suppression list with a record of their opt-out decision, rather than being completely deleted. It should be noted that where digital marketing is carried out in a ‘business to business’ context, there is no legal requirement to obtain an indication of Consent to carry out digital marketing to individuals provided that they are given the opportunity to opt-out.

3.4 DATA RETENTION

To ensure fair processing, personal data will not be retained by Investor Profit Portfolio LIMITED for longer than necessary in relation to the purposes for which it was originally collected, or for which it was further processed. The length of time for which Investor Profit Portfolio LIMITED services/entities need to retain personal data is set out in Investor Profit Portfolio LIMITED ‘Data Retention Policy’. This takes into account the legal and contractual requirements, both minimum and maximum, that influence the retention periods set forth in the schedule. All personal data should be deleted or destroyed as soon as possible where it has been confirmed that there is no longer a need to retain it.

3.5 DATA PROTECTION

Each Investor Profit Portfolio LIMITED service/entity will adopt physical, technical, and organisational measures to ensure the security of personal data. This includes the prevention of loss or damage, unauthorised alteration, access or processing, and other risks to which it may be exposed by virtue of human action or the physical or natural environment. A summary of the personal data related security measures is provided below:

3.6 DATA SUBJECT REQUESTS

Investor Profit Portfolio LIMITED will establish a system to enable and facilitate the exercise of data subject rights related to:

Investor Profit Portfolio LIMITED will consider each such request in accordance with all applicable data protection laws and regulations. No administration fee will be charged for considering and/or complying with such a request unless the request is deemed to be unnecessary or excessive in nature. data subjects are entitled to obtain, based upon a request made in writing/email to: admin@investorprofitportfolio.com

It should be noted that situations may arise where providing the information requested by a data subject would disclose personal data about another individual. In such cases, information must be redacted or withheld as may be necessary or appropriate to protect that person’s rights. Detailed guidance for dealing with requests from data subjects can be found in Investor Profit Portfolio LIMITED ‘Data Subject Access Rights Policy and Procedure’ document.

3.7 LAW ENFORCEMENT REQUESTS & DISCLOSURES

In certain circumstances, it is permitted that personal data be shared without the knowledge or consent of a data subject. This is the case where the disclosure of the personal data is necessary for any of the following purposes:

If a Investor Profit Portfolio LIMITED service/entity processes personal data for one of these purposes, then it may apply an exception to the processing rules outlined in this policy but only to the extent that not doing so would be likely to prejudice the case in question. If any Investor Profit Portfolio LIMITED service/entity receives a request from a court or any regulatory or law enforcement authority for information relating to a Investor Profit Portfolio LIMITED contact, you must immediately notify the Head of Operations who will provide comprehensive guidance and assistance.

3.8 DATA PROTECTION TRAINING

All Investor Profit Portfolio LIMITED employees that have access to personal data will have their responsibilities under this policy outlined to them as part of their staff induction training. In addition, each Investor Profit Portfolio LIMITED service/entity will provide regular Data Protection training and procedural guidance for their staff.

3.9 DATA TRANSFERS

Investor Profit Portfolio LIMITED services/entities may transfer personal data to internal or third-party recipients located in another country where that country is recognised as having an adequate level of legal protection for the rights and freedoms of the relevant data subjects. Where transfers need to be made to countries lacking an adequate level of legal protection (i.e. third countries), they must be made in compliance with an approved transfer mechanism. Investor Profit Portfolio LIMITED services/entities may only transfer personal data where one of the transfer scenarios list below applies:

3.10 COMPLAINTS HANDLING

Data subjects with a complaint about the processing of their personal data, should put forward the matter in writing admin@investorprofitportfolio.com. An investigation of the complaint will be carried out to the extent that is appropriate based on the merits of the specific case. The Head of Operations will inform the data subject of the progress and the outcome of the complaint within a reasonable period. If the issue cannot be resolved through consultation between the data subject and Investor Profit Portfolio LIMITED, then the data subject may, at their option, seek redress through mediation, binding arbitration, litigation, or via complaint to the Data Protection Authority within the applicable jurisdiction.

3.11 BREACH REPORTING

Any individual who suspects that a personal data breach has occurred due to the theft or exposure of personal data must immediately notify admin@investorprofitportfolio.com providing a description of what occurred. Investor Profit Portfolio LIMITED will investigate all reported incidents to confirm whether or not a personal data breach has occurred. If a personal data breach is confirmed, Investor Profit Portfolio LIMITED will follow the relevant authorised procedure based on the criticality and quantity of the personal data involved. For severe personal data breaches, Investor Profit Portfolio LIMITED Executive Team will initiate and chair an emergency response team to coordinate and manage the personal data breach response.

4 ROLES AND RESPONSIBILITIES

4.1 IMPLEMENTATION

The management team of each Investor Profit Portfolio LIMITED service/entity must ensure that all Investor Profit Portfolio LIMITED employees responsible for the processing of personal data are aware of and comply with the contents of this policy. In addition, each Investor Profit Portfolio LIMITED service/entity will make sure all third parties engaged to process personal data on their behalf (i.e. their data processors) are aware of and comply with the contents of this policy. Assurance of such compliance must be obtained from all third parties, whether companies or individuals, prior to granting them access to personal data controlled by Investor Profit Portfolio LIMITED.

5 REVIEW

This policy will be reviewed by the Head of Operations every three years, unless there are any changes to regulations or legislation that would enable a review earlier.

6 RECORDS MANAGEMENT

Staff must maintain all records relevant to administering this policy and procedure in electronic form in a recognised Investor Profit Portfolio LIMITED recordkeeping system.

All records relevant to administering this policy and procedure will be maintained for a period of 5 years.

7 TERMS AND DEFINITIONS

General Data Protection Regulation (GDPR): the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a regulation by which the European Parliament, the Council of the European Union and the European Commission intend to strengthen and unify data protection for all individuals within the European Union (EU). It also addresses the export of personal data outside the EU.

Data Controller: the entity that determines the purposes, conditions and means of the processing of personal data.

Data Processor: the entity that processes data on behalf of the Data Controller.

Data Protection Authority: national authorities tasked with the protection of data and privacy as well as monitoring and enforcement of the data protection regulations within the Union.

Data Protection Officer (DPO): an expert on data privacy who works independently to ensure that an entity is adhering to the policies and procedures set forth in the GDPR.

Data subject: a natural person whose personal data is processed by a controller or processor.

personal data: any information related to a natural person or ‘data subject’, that can be used to directly or indirectly identify the person.

Privacy Impact Assessment: a tool used to identify and reduce the privacy risks of entities by analysing the personal data that are processed and the policies in place to protect the data.

Processing: any operation performed on personal data, whether or not by automated means, including collection, use, recording, etc.

Profiling: any automated processing of personal data intended to evaluate, analyse, or predict data subject behaviour.

Regulation: a binding legislative act that must be applied in its entirety across the Union.

Subject Access Right: also known as the Right to Access, it entitles the data subject to have access to and information about the personal data that a controller has concerning them.

8 RELATED LEGISLATION AND DOCUMENTS

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)

9 FOR MORE INFORMATION

Contact our Data Protection Officers by emailing: admin@investorprofitportfolio.com

10 APPROVAL AND REVIEW DETAILS

Approval and Review Details
Approval Authority Head of Operations
Next Review Date 25/05/2019
Approval and Amendment History Details
Original Approval Authority and Date Head of Operations 25/05/2018

DATA SECURITY POLICY

DEFINITION

Investor Profit Portfolio LIMITED and subsidiaries companies will hereafter be referred to as “Investor Profit Portfolio LIMITED”

1 PURPOSE

This policy establishes an effective, accountable and transparent framework for ensuring high standards of data security at Investor Profit Portfolio LIMITED.

2 SCOPE

This policy applies across all entities or subsidiaries owned, controlled, or operated by Investor Profit Portfolio LIMITED and to all employees, including part-time, temporary, or contract employees.

3 POLICY STATEMENT

PHYSICAL SECURITY

The Investor Profit Portfolio LIMITED office is under 24×7 security protection, at both premises level and floor level to ensure only authorised individuals have access to the building and the Investor Profit Portfolio LIMITED office. At the floor level, smartcard readers are present to authorise individuals before entry. Employees are granted access to the office only after authorisation using smart cards. Critical locations in the office are accessible only to authorized individuals.

Important documents are stored in cabinets that can only be accessed by pre-authorised individuals. Fire alarms are in place to detect and mitigate damage in the unlikely event of a fire. Regular fire drills are also conducted by the premises management team to educate employees about emergency evacuation procedures. A policy has been implemented to approve and regulate visitor access to the building.

Investor Profit Portfolio LIMITED hosts its application and data in Vtiger Systems India Private Limited, whose data centres have been thoroughly tested for security, availability and business continuity.

APPLICATION SECURITY

All of Investor Profit Portfolio LIMITED applications are hosted in Vtiger Systems India Private Limited. The infrastructure for databases and application servers is managed and maintained by Vtiger Systems India Private Limited.

At Investor Profit Portfolio LIMITED, we take a multifaceted approach to application security, to ensure everything from engineering to deployment, including architecture and quality assurance processes complies with our highest standards of security.

APPLICATION ARCHITECTURE

The application is initially protected by Vtiger Systems India Private Limited firewall which is equipped to counter regular DDoS attacks and other network related intrusions. The second layer of protection is Investor Profit Portfolio LIMITED own application firewall which monitors against offending IPs, users and spam. While the application can be accessed only by users with valid credentials, it should be noted that security in cloud-based products is a shared responsibility between the company and the businesses who own those accounts on the cloud. In addition to making it easy for administrators to enforce industry-standard password policies on users, our applications also incorporate features aimed at securing business data on the cloud:

Investor Profit Portfolio LIMITED uses a multi-tenant data model to host all its applications. Each application is serviced from an individual virtual private cloud and each customer is uniquely identified by a tenant ID. The application is engineered and verified to ensure that it always fetches data only for the logged-in tenant. Per this design, no customer has access to another customer’s data. Access to the application by the Investor Profit Portfolio LIMITED development team is also controlled, managed and audited. Access to the application and the infrastructure are logged for subsequent audits.

The in-line email attachment URLs for the product are public by design, to enable us to embed links within the email for end-user ease. This can be made private on customer request.

APPLICATION ENGINEERING AND DEVELOPMENT

Our engineers are trained in industry-leading secure coding standards and guidelines to ensure our products are developed with security considerations from the ground-up. A security review is a mandatory part of application engineering process at Investor Profit Portfolio LIMITED. The security review leverages static code analysis tools, in addition to manual reviews, to ensure adherence to our highest standards.

QUALITY ASSURANCE

Besides functional validation and verification, the quality assurance process at Investor Profit Portfolio LIMITED also subjects application updates to a thorough security validation. The validation process is performed by a dedicated testers who attempt to ethically hack the application to discover and demonstrate vulnerabilities in the application. An update to the application does not get the stamp of approval from the quality assurance team if vulnerabilities (that can compromise either the application or data) are identified.

DATA SECURITY

Investor Profit Portfolio LIMITED takes the protection and security of its customers’ data very seriously. Investor Profit Portfolio LIMITED manages the security of its application and customers’ data. However, provisioning and access management of individual accounts is at the discretion of individual business owners.

The Investor Profit Portfolio LIMITED development team have limited access to data on production servers. Changes to the application, infrastructure, web content and deployment processes are documented extensively as part of an internal change control process.

Our products collect limited information about customers – name, birthdate, nationality, email address and phone – which are retained for account creation. Postal address is requested and retained by Investor Profit Portfolio LIMITED PCI compliant payment processor for billing, along with the date of expiry of credit card and CVV when wallet accounts are used.

Investor Profit Portfolio LIMITED takes the integrity and protection of customers’ data very seriously. We maintain history of two kinds of data: application logs from the system, and application and customers’ data. All data is stored in Cloud Services’ state of the art cloud computing platform. Data is stored in multiple locations on mirrored cloud databases.

Application logs are maintained for a duration of 90 days. Customers’ data is backed up in two ways:

  • A continuous backup is maintained in different datacenters to support a system failover if it were to occur in the primary datacenter. Should an unlikely catastrophe occur in one of the datacenters, businesses would lose only five minutes of data.
  • Databases are synced.

Different environments are in use for development and testing purposes, access to systems are strictly managed, based on the principles of need to do/know basis appropriate to the information classification, with Segregation of Duties built in, and reviewed on a quarterly basis.

DATA DELETION

When an account is requested to be to deleted, all personal data associated with the account will be deleted within 30 business days. Personal data cannot be deleted from an account that has an outstanding balance. Investor Profit Portfolio LIMITED products also offer data export options which businesses can use if they want a backup of their data before deletion.

OPERATIONAL SECURITY

Investor Profit Portfolio LIMITED understands that formal procedures, controls and well-defined responsibilities need to be in place to ensure continued data security and integrity. The company has clear change management processes, logging and monitoring procedures, and fall back mechanisms which have been set up as part of its operational security directives.

Operational security starts right from recruiting an engineer to training and auditing their work products. The recruitment process includes standard background verification checks (including verification of academic records) on all new recruits. All employees are provided with adequate training about the information security policies of the company and are required to sign that they have read and understood the company’s security-related policies. Confidential information about the company is available for access only to select authorised Investor Profit Portfolio LIMITED employees.

Employees are required to report any observed suspicious activities or threats. The human resources team takes appropriate disciplinary action against employees who violate organizational security policies. Security incidents (breaches and potential vulnerabilities) can be reported by customers through our portal at worldoptions.com or via email: admin@investorprofitportfolio.com

Investor Profit Portfolio LIMITED maintains an inventory of all information systems used by employees for development purpose. Only authorized and licensed software products are installed by employees. All employee information systems are authorized by the management before they are installed or put to use.

The company has a Data Protection Policy, approved by the Head of Operations.

NETWORK SECURITY

Network security is discussed in detail in this section from the perspective of the development centre, and the network where the application is hosted.

The Investor Profit Portfolio LIMITED office network where updates are tested, monitored and managed is secured by industry-grade firewalls and antivirus software, to protect internal information systems from intrusion and to provide active alerts in the event of a threat or an incident. Firewall logs are stored and reviewed periodically. Access to the production environment is via SSH and remote access is possible only via the office network.

All Investor Profit Portfolio LIMITED products are hosted by IHUCI LIMITED, with security managed by IHUCI LIMITED. Our team monitors the infrastructure 24×7 for stability, intrusions and spam using a dedicated alert system. The Investor Profit Portfolio LIMITED application has an in-built spam protection system for businesses that use it, while our team monitors and blocks individual accounts and IP addresses which attempt to access the Investor Profit Portfolio LIMITED applications.

4 RESPONSIBILITIES

REGULATORY COMPLIANCE

All formal processes and security standards at Investor Profit Portfolio LIMITED are designed to meet regulations at the industry, state and European Union levels.

Use of our service by customers in the European Economic Area (“EEA”), will include the processing of information relating to their customers. In providing our service, we do not own, control or direct the use of the information stored or processed on our platform at the direction of our customers, and in fact we are largely unaware of what information is being stored on our platform and only access such information as reasonably necessary to provide the service (including to respond to support requests), as otherwise authorised by our customers or as required by law. We are Data Processors for our end customers, but Data Controllers for the customers from whom we collect data on our platform for purposes of the European Union (“EU”) on our platform for purposes of the European Union (“EU”) General Data Protection Regulation (GDPR). Our EEA based customers, who control their customer data and send it to Investor Profit Portfolio LIMITED for processing, are the “Controllers” of that data and are responsible for compliance with the GDPR. In particular, Investor Profit Portfolio LIMITED customers are responsible for complying with the GDPR and relevant data protection legislation in the relevant EEA member state before sending personal information to Investor Profit Portfolio LIMITED for processing.

As the processors of personal information on behalf of our customers, we follow their instructions with respect to the information they control to the extent consistent with the functionality of our service. In doing so, we implement industry standard security, technical, physical and administrative measures against unauthorized processing of such information and against loss, destruction of, or damage to, personal information as more fully described in Investor Profit Portfolio LIMITED Data Protection Policy.

We work with our customers to help them provide notice to their customers concerning the purpose for which personal information is collected and sign Standard Data Processor Agreement (for data processors) with them to legitimize transfers of personal data from EU to processors established in third countries as may be required under the GDPR.

REPORTING ISSUES AND THREATS

If you have found any issues or flaws impacting the data security or privacy of Investor Profit Portfolio LIMITED users, please write to admin@investorprofitportfolio.com with the relevant information so we can get working on it right away.

Your request will be looked into immediately. We might ask for your guidance in identifying or replicating the issue and understanding any means to resolving the threat right away. Please be clear and specific about any information you give us. We deeply appreciate your help in detecting and fixing flaws in Investor Profit Portfolio LIMITED and will acknowledge your contribution to the world once the threat is resolved.

RECORDS MANAGEMENT

Staff must maintain all records relevant to administering this policy and procedure in electronic form in a recognised Investor Profit Portfolio LIMITED recordkeeping system.

All records relevant to administering this policy and procedure will be maintained for a period of 5 years.

5 TERMS AND DEFINITIONS

General Data Protection Regulation (GDPR)the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a regulation by which the European Parliament, the Council of the European Union and the European Commission intend to strengthen and unify data protection for all individuals within the European Union (EU). It also addresses the export of personal data outside the EU.

Data Controller: the entity that determines the purposes, conditions and means of the processing of personal data

Data Processor: the entity that processes data on behalf of the Data Controller

Data Protection Authority: national authorities tasked with the protection of data and privacy as well as monitoring and enforcement of the data protection regulations within the Union

Data Protection Officer (DPO): an expert on data privacy who works independently to ensure that an entity is adhering to the policies and procedures set forth in the GDPR

Data Subject: a natural person whose personal data is processed by a controller or processor

Personal Data: any information related to a natural person or ‘Data Subject’, that can be used to directly or indirectly identify the person

Privacy Impact Assessment: a tool used to identify and reduce the privacy risks of entities by analysing the personal data that are processed and the policies in place to protect the data

Processing: any operation performed on personal data, whether or not by automated means, including collection, use, recording, etc.

Profiling: any automated processing of personal data intended to evaluate, analyse, or predict data subject behaviour

Regulation: a binding legislative act that must be applied in its entirety across the Union

Subject Access Right: also known as the Right to Access, it entitles the data subject to have access to and information about the personal data that a controller has concerning them

6 RELATED LEGISLATION AND DOCUMENTS

7 FOR MORE INFORMATION

Contact our Data Protection Officers by emailing: admin@investorprofitportfolio.com

7 APPROVAL AND REVIEW DETAILS

Approval and Review Details
Approval Authority Head of Operations
Next Review Date 25/05/2019
Approval and Amendment History Details
Original Approval Authority and Date  Head of Operations 25/05/2018
Amendment Authority and Date

DATA RETENTION POLICY

DEFINITION

Investor Profit Portfolio LIMITED and subsidiaries companies will hereafter be referred to as “Investor Profit Portfolio LIMITED”

1 PURPOSE

The purpose of this policy is to specify Investor Profit Portfolio LIMITED guidelines for retaining different types of personal data.

2 SCOPE

The scope of this policy covers all Investor Profit Portfolio LIMITED personal data stored on company-owned, company-leased, and otherwise company-provided systems and media, regardless of location. These records may be created, received or maintained in hard copy or electronically.

3 POLICY STATEMENT

The need to retain personal data varies widely with the type of data. Some personal data can be immediately deleted and some must be retained until reasonable potential for future need no longer exists. This Data Retention Policy provides guidelines to ensure that all applicable regulations and Investor Profit Portfolio LIMITED rules on personal data retention are consistently applied throughout the organisation.

Reasons for data retention

Some personal data must be retained in order to protect the company’s interests, comply with regulatory requirements, preserve evidence, and generally conform to good business practices. Personal data may be retained for one or several of the following reasons:

  • Business requirements
  • Regulatory requirements
  • Possible litigation
  • Accident investigation
  • Security incident investigation
  • Intellectual property preservation

RETENTION PERIODS

Different types of data will be retained for different periods of time:

  • Personal customer data: Personal data will be held for as long as the individual is a customer of the company plus 7 years.
  • Personal employee data: General employee data will be held for the duration of employment and then for 7 years after the last day of contractual employment. Employee contracts will be held for 7 years after last day of contractual employment.
  • Personal tax payments will be held for 4 years.
  • Records of leave will be held for 7 years.
  • Recruitment details: Interview notes of unsuccessful applicants will be held for 6 months after interview. This personal data will then be destroyed.
  • Health and Safety: 40 years for records of major accidents and dangerous occurrences.
  • Operational data: Most company data will fall in this category. Operational data will be retained for 6+ years.
  • Critical data including Tax and VAT: Critical data must be retained for 7 years.

For more details, please refer to Appendix 1 – Data Retention Schedule

RETENTION OF ENCRYPTED DATA

If any information retained under this policy is stored in an encrypted format, considerations must be taken for secure storage of the encryption keys. Encryption keys must be retained as long as the data that the keys decrypt is retained.

DATA DUPLICATION

When identifying and classifying Investor Profit Portfolio LIMITED personal data, it is important to also understand where that data may be stored, particularly for duplicate copies, so that this policy may be applied to all duplicates of the information.

DATA DESTRUCTION

When the retention timeframe expires, Investor Profit Portfolio LIMITED will actively destroy the data covered by this policy. If a user feels that certain data should not be destroyed, he or she should identify the data to his or her supervisor so that an exception to the policy can be considered. Since this decision has long-term legal implications, exceptions will be approved only by a member or members of Investor Profit Portfolio LIMITED’s senior management team.

The company specifically directs users not to destroy data in violation of this policy. Destroying data that a user may feel is harmful to himself or herself or destroying data in an attempt to cover up a violation of law or company policy is particularly forbidden.

4 RESPONSIBILITIES

Compliance, monitoring and review

The overall responsibility for ensuring compliance with the requirements of the related legislation in relation to performing all operational activities at Investor Profit Portfolio LIMITED rests with the Head of Operations.

All operating units’ staff that deals with personal data is responsible for processing this data in full compliance with the relevant Investor Profit Portfolio LIMITED policies and procedures.

Reporting in case of a data breach

In the case of possible data breach, the staff member(s) who first identifies the breach or incident, must immediately report all details of the incident to the Head of Operations.

The Head of Operations is required to report a personal data breach to the competent Data Protection Authority not later than 72 hours after becoming aware of it. The notification must include at least:

  • a description of the nature of the breach, including, where possible, the categories and approximate number of data subjects and personal data records concerned;
  • the name and contact details of the the Data Protection Officer as a contact point;
  • the likely consequences of the data breach; and
  • measures taken or proposed by the controller to address the breach and/or mitigate its effects.

Where a personal data breach is likely to result in a high risk to the rights and freedoms of a data subject, the Head of Operations must communicate the breach to the data subject(s) without undue delay. The communication must describe in clear and plain language, the nature of the breach and at least:

  • the name and contact details of the Data Protection Officer as a contact point;
  • the likely consequences of the data breach; and
  • measures taken or proposed by the controller to address the breach and/or mitigate its effects.

Records management

Staff must maintain all records relevant to administering this policy and procedure in electronic form in a recognised Investor Profit Portfolio LIMITED record keeping system.

All records relevant to administering this policy and procedure will be maintained for a period of 5 years.

5 TERMS AND DEFINITIONS

  • General Data Protection Regulation (GDPR): the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a regulation by which the European Parliament, the Council of the European Union and the European Commission intend to strengthen and unify data protection for all individuals within the European Union (EU). It also addresses the export of personal data outside the EU.
  • Data Controller: the entity that determines the purposes, conditions and means of the processing of personal data
  • Data Processor: the entity that processes data on behalf of the Data Controller
  • Data Protection Authority: national authorities tasked with the protection of data and privacy as well as monitoring and enforcement of the data protection regulations within the Union
  • Data Protection Officer (DPO): an expert on data privacy who works independently to ensure that an entity is adhering to the policies and procedures set forth in the GDPR
  • Data Subject: a natural person whose personal data is processed by a controller or processor
  • Personal Data: any information related to a natural person or ‘Data Subject’, that can be used to directly or indirectly identify the person
  • Processing: any operation performed on personal data, whether or not by automated means, including collection, use, recording, etc.
  • Data Backup: data copied to a second location, solely for the purpose of safe keeping of that data
  • Data Encryption: the process of encoding data with an algorithm so that it is unintelligible and secure without the key. Used to protect data during transmission or while stored
  • Data Encryption Key: an alphanumeric series of characters that enables data to be encrypted and decrypted
  • Regulation: a binding legislative act that must be applied in its entirety across the Union
  • Subject Access Right: also known as the Right to Access, it entitles the data subject to have access to and information about the personal data that a controller has concerning them

6 RELATED LEGISLATION AND DOCUMENTS

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
  • Investor Profit Portfolio LIMITED Data Protection Policy

7 FOR MORE INFORMATION

You can contact our Data Protection Officer by emailing: admin@investorprofitportfolio.com

8 APPROVAL AND REVIEW DETAILS

Approval and Review Details
Approval Authority Head of Operations
Next Review Date 25/05/2019
Approval and Amendment History Details
Original Approval Authority and Date  Head of Operations 25/05/2018

DATA TRANSFERS POLICY

DEFINITION

Investor Profit Portfolio LIMITED and subsidiaries companies will hereafter be referred to as “Investor Profit Portfolio LIMITED”

1 PURPOSE

This policy and procedure establishes an effective, accountable and transparent framework for ensuring compliance with the requirements for data transfers by the GDPR.

2 SCOPE

This policy and procedure applies across all entities or subsidiaries owned, controlled, or operated by Investor Profit Portfolio LIMITED and to all employees, including part-time, temporary, or contract employees, that handle personal data and/or personal data transfers.

3 POLICY STATEMENT

The Investor Profit Portfolio LIMITED services/entities may transfer personal data to internal or third-party recipients located in another country where that country is recognised as having an adequate level of legal protection for the rights and freedoms of the relevant data subjects. Where transfers need to be made to countries lacking an adequate level of legal protection (i.e. third countries), they must be made in compliance with an approved transfer mechanism. The Investor Profit Portfolio LIMITED services/entities may only transfer personal data where one of the transfer scenarios list below applies:

  • The data subject has given consent to the proposed transfer.
  • The transfer is necessary for the performance of a contract with the data subject
  • The transfer is necessary for the implementation of pre-contractual measures taken in response to the data subject’s request.
  • The transfer is necessary for the conclusion or performance of a contract concluded with a third party in the interest of the data subject.
  • The transfer is legally required on important public interest grounds.
  • The transfer is necessary for the establishment, exercise or defence of legal claims.
  • The transfer is necessary in order to protect the vital interests of the data subject

TRANSFERS BETWEEN Investor Profit Portfolio LIMITED SERVICES/ENTITIES

In order for Investor Profit Portfolio LIMITED to carry out its operations effectively across its various services/entities, there may be occasions when it is necessary to transfer personal data internally from one Entity to another, or to allow access to the personal data from an overseas location. Should this occur, the Investor Profit Portfolio LIMITED service/entity sending the personal data remains responsible for ensuring protection for that personal data.

Investor Profit Portfolio LIMITED handles the transfer of personal data between Investor Profit Portfolio LIMITED services/entities, where the location of the recipient entity is a third country, using the binding corporate rules transfer mechanism. Binding corporate rules provide legally binding, enforceable rights on data subjects with regard to the processing of their personal data and must be enforced by each approved Investor Profit Portfolio LIMITED service/entity, including their employees. Only transfer the minimum amount of personal data necessary for the particular purpose of the transfer (for example, to fulfil a transaction or carry out a particular service). Ensure adequate security measures are used to protect the personal data during the transfer (including password-protection and encryption, where necessary).

TRANSFERS TO THIRD PARTIES

Each Investor Profit Portfolio LIMITED service/entity will only transfer personal data to, or allow access by, third parties when it is assured that the information will be processed legitimately and protected appropriately by the recipient. Where third party processing takes place, each Investor Profit Portfolio LIMITED service/entity will first identify if, under applicable law, the third party is considered a data controller, or a data processor of the personal data being transferred.

Where the third party is deemed to be a data controller, the Investor Profit Portfolio LIMITED service/entity will enter into, in cooperation with the Head of Operations, an appropriate agreement with the controller to clarify each party’s responsibilities in respect to the personal data transferred. Where the third party is deemed to be a data processor, the Investor Profit Portfolio LIMITED service/entity will enter into, in cooperation with the Head of Operations, an adequate processing agreement with the data processor. The agreement must require the data processor to protect the personal data from further disclosure and to only process personal data in compliance with the Investor Profit Portfolio LIMITED instructions. In addition, the agreement will require the data processor to implement appropriate technical and organisational measures to protect the personal data as well as procedures for providing notification of personal data breaches.

The Investor Profit Portfolio LIMITED has a ‘Standard Data Processing Agreement’ document that should be used as a baseline template. When an Investor Profit Portfolio LIMITED service/entity is outsourcing services to a third party (including cloud computing services), they will identify whether the third party will process personal data on its behalf and whether the outsourcing will entail any third country transfers of personal data. In either case, it will make sure to include, in cooperation with the Investor Profit Portfolio LIMITED Head of Operations, adequate provisions in the outsourcing agreement for such processing and third country transfers.

RESPONSIBILITIES

Compliance, monitoring and review

The overall responsibility for ensuring compliance with the requirements of the related legislation in relation to performing data transfers activities at Investor Profit Portfolio LIMITED rests with the Head of Operations.

All operating units’ staff that deal with personal data are responsible for processing this data in full compliance with the relevant Investor Profit Portfolio LIMITED policies and procedures.

Records management

Staff must maintain all records relevant to administering this policy and procedure in electronic form in a recognised Investor Profit Portfolio LIMITED recordkeeping system.

All records relevant to administering this policy and procedure will be maintained for a period of 5 years.

5 TERMS AND DEFINITIONS

General Data Protection Regulation (GDPR)the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a regulation by which the European Parliament, the Council of the European Union and the European Commission intend to strengthen and unify data protection for all individuals within the European Union (EU). It also addresses the export of personal data outside the EU.

Data Controller: the entity that determines the purposes, conditions and means of the processing of personal data

Data Processor: the entity that processes data on behalf of the Data Controller

Data Protection Authority: national authorities tasked with the protection of data and privacy as well as monitoring and enforcement of the data protection regulations within the Union

Data Protection Officer (DPO): an expert on data privacy who works independently to ensure that an entity is adhering to the policies and procedures set forth in the GDPR

Data Subject: a natural person whose personal data is processed by a controller or processor

Personal Data: any information related to a natural person or ‘Data Subject’, that can be used to directly or indirectly identify the person

Privacy Impact Assessment: a tool used to identify and reduce the privacy risks of entities by analysing the personal data that are processed and the policies in place to protect the data

Processing: any operation performed on personal data, whether or not by automated means, including collection, use, recording, etc.

Profiling: any automated processing of personal data intended to evaluate, analyse, or predict data subject behaviour

Regulation: a binding legislative act that must be applied in its entirety across the Union

Subject Access Right: also known as the Right to Access, it entitles the data subject to have access to and information about the personal data that a controller has concerning them

6 RELATED LEGISLATION AND DOCUMENTS

7 FOR MORE INFORMATION

Contact our Data Protection Officers by emailing: admin@investorprofitportfolio.com

8 APPROVAL AND REVIEW DETAILS

Approval and Review Details
Approval Authority Head of Operations
Next Review Date 25/05/2019
Approval and Amendment History Details
Original Approval Authority and Date  Head of Operations 25/05/2018
Amendment Authority and Date

SUBJECT ACCESS REQUEST

REQUESTING YOUR DATA

If you want us to supply you with a copy of any personal data we hold about you, please complete the form provided in the link below and email it to the address below.

You are currently entitled to receive this information under the EU General Data Protection Regulation (GDPR). We will also provide you with information about any processing of your personal data that is being carried out, the retention periods which apply to your personal data, and any rights to rectification, erasure, or restriction of processing that may exist.

The information you supply in this form will only be used for the purposes of identifying the personal data you are requesting and responding to your request.

Please send your completed form and proof of identity to: admin@investorprofitportfolio.com