The Engine Ltd. is a ‘Data Controller’ and is registered with the Information Commissioner in the Isle of Man.
We are committed to ensuring lawful, fair and transparent processing of your personal data and will only use the information you provide to us to administer the product or services we are providing to you.
Information on our data processing activities and the rights that are provided to you under Data Protection legislation are as follow.
The Engine processes your personal data only where:
- We have a legitimate interest to do so; or
- A contract has been entered into that allows us to; or
- It is in the vital interests of you as the data subject; or
- You have given your explicit consent; or
- We are required to by our Regulators; or
- We have received a court order.
We will not process personal data unless one of the above conditions apply.
WHAT DATA DO WE COLLECT?
We will only collect personal data that is essential to administer the product or services that you have asked us to provide and to comply with regulatory and statutory requirements.
The data that we collect will be dependent on the product or service that you wish us to provide. This data may include:
- Full name, date of birth, age, national insurance number and/or other governmental identification numbers;
- Personal and/or business contact details, including address, telephone numbers and email addresses;
- Details of your preferred contact person in case of emergency;
- Financial information (including bank account details);
Please note that certain categories of data are classed as sensitive personal information and this includes details about your physical and mental health. We will only collect information you wish to share with us about your health that you think we should know about in case of emergency.
We also have CCTV for security purposes and keycard security access which also fall under the data protection legislation and this has been notified to the Information Commissioner.
WHY IS YOUR DATA PROCESSED?
We collect the above personal data for the purpose of:
- Creation and ongoing administration of the product or structure relevant to your requirements;
- Dealing with any queries and/or complaints;
- Compliance with legal, regulatory and good governance obligations;
- Public Safety and crime prevention and detection.
WHERE WE PROCESS AND STORE YOUR DATA
Your data will be processed and held securely in physical or electronic format within the offices and servers of The Engine Ltd. in the Isle of Man.
We may also make your personal data available to other parties (individuals or group companies) who are providing relevant services for one of the above data processing purposes, such as professional or legal advisors, investment administrators or managers, banking institutions or for the preparation of accounts or other financial information, etc.
We are located in the Isle of Man; however you should be aware that we may, on occasion, be required to share your data with external providers outside of the Isle of Man or European Economic Area (“EEA”). In territories outside the Isle of Man or EEA, laws and practices relating to the protection of personal data may be weaker than those within the Isle of Man or EEA. We will take all reasonable steps to ensure that your personal data receives the same level of protection as it would had it stayed in the Isle of Man or EEA.
Your personal data may also be released to other external parties if authorised by you, or as required or permitted by law, or to comply with a judicial proceeding, court order, request from a regulator or any other legal process served on The Engine Ltd.
OUR BASIS FOR PROCESSING YOUR DATA
The processing of your personal data is necessary in order for us to administer the services that we provide to you.
We will proceed on the basis that, for the purposes set out above, you expressly consent to the processing (including the disclosures and transfers described above) of your personal data by the Directors, or related third parties as set out above.
We will only retain your personal information during the lifetime of our business relationship with you plus any statutory retention period required.
All personal data held past the statutory retention period will be destroyed.
As detailed within Data Protection Legislation, each Data Subject is afforded a number of rights. In accordance with these rights we will, upon request:
- Provide you with all of the data we hold about you, in a machine-readable format;
- Provide you with access to any or all the data that we hold about you, and provide you with details about why we have the data;
- Correct any information about you if you advise us that it is incorrect;
- Unless we are required to continue doing so by legislation, stop, or where applicable, restrict the processing of data about you;
- Remove all records about you from our systems, providing that there is not a legal reason to retain it. If there is a legal reason we will inform you of it, and provide you with details about how much longer we are required to retain your data for.
You can exercise these rights by contacting the Data Protection Officer at firstname.lastname@example.org.
Please notify us as soon as possible if there has been a change in your details (e.g. if your personal circumstances, home address, etc. change).
The Engine will only contact individuals who have consented to receiving marketing information, or requested direct communication for marketing purposes, and only in relation to our products and/or services.
Should you no longer wish to receive marketing communications from us:
- an unsubscribe facility is available within the marketing email to allow you to request that no further marketing contact is received by you from The Engine; or
- you can reply to the individual who has contacted you requesting that no further marketing contact is made.
After either of these has occurred, we will not directly contact you in this regard again unless you provide a subsequent request to start receiving marketing material from us.