Safeguarding your personal data is important to SKAGEN AS ("SKAGEN"). You can rest assured that your personal data is in safe hands with us, irrespective of whether you are a client or whether you are visiting SKAGEN's website and various social media channels.
Personal data is any piece of information that may be associated with an individual. Examples include name, address, telephone number, email address and national identification number.
The General Data Protection Regulation and the new Data Protection Act enter into force on May 25 2018, and regulate SKAGEN's processing of personal data. In addition, the Market Practices Act and the act governing electronic communication legislation impose relevant regulations. The new data protection legislation is placing new and stricter requirements on SKAGEN, and gives data subject better protection and increased rights.
The processing of personal data requires a legal basis, and is typically based on legal obligation, agreements, justifiable interest or consent.
Clients' personal data
What does SKAGEN register and why?
In order for you to be a client with SKAGEN, we are legally obliged to collect and process certain types of personal information. This may be your name, national identification number, postal address, bank account number and information linked to your guardian status, right of disposal, tax reporting and anti-money laundering checks.
The main purpose of SKAGEN's processing of clients' personal data is to fulfil client agreements, which includes providing the best possible advice, follow-up and communication.
SKAGEN has a justifiable interest in sending marketing material by email to its clients. This may take the form of newsletters, information about relevant products and services as well as invitations to inspiration meetings and other relevant events. You may at any time opt out of receiving this information. All emails with this type of content come with an opt-out option which you may make use of. Alternatively, you may contact email@example.com
We track how you as a recipient handle our email deliveries. We see how often you open emails and which topics interest you. We do this in order to provide you with more relevant communication. You may opt out of this by contacting firstname.lastname@example.org
Where is the information gathered from?
As a rule, SKAGEN gathers information directly from you. In some cases, we gather information from other sources, which may be both public and private institutions. We inform you when we gather information about you, unless we are legally obliged to gather the information, if notification is impossible or disproportionately difficult, or if we know that you are already aware that we are gathering this information.
In SKAGEN, we sometimes use personal profiling to adapt our offer to you. This is a compilation of information that we have received from you, such as name, address, age, gender and other information that you have provided, in addition to information about which products and services you use, behavioural data and online traffic information. When we use profiling in our marketing, we inform you of this. You can opt out of profiling by contacting email@example.com
Recording of telephone conversations and storage of other client communication
When offering investment advice towards existing or potential clients, SKAGEN is obliged to make recordings of all telephone conversations and to document other client communication such as emails and chat. The conversations are stored for a period of five years.
We always inform you when telephone conversations are being recorded.
Distribution of personal data about clients
Internally in the Storebrand Group
SKAGEN is part of the Storebrand Group. Internally in the Storebrand Group, we have a joint client register which is available to all of the companies in the Group. The purpose of this Group-wide client register is to provide clients with the best possible service as well as information and offers relating to the products and services we provide.
In order that your personal data and other information associated with your contractual relationship with SKAGEN may be registered in the Group's joint client register, shared across the different parts of the Group, we require your consent. You may withdraw your consent at any time.
On suspicion of legal offence
SKAGEN is obliged to process personal data in order to prevent, uncover, detect and handle money laundering, terror financing, fraud and other legal offences. The information is gathered from and distributed to other banks and financial institutions, the police and other public authorities. SKAGEN is obliged to report suspicious information and transactions to the relevant national authorities).
Personal data about non-clients
SKAGEN processes the personal data, such as name and email address, of anyone who receives our newsletters, meeting invitations and other marketing deliveries. All such deliveries contain an easily accessible unsubscribe option and you may also unsubscribe by sending an email to firstname.lastname@example.org
SKAGEN tracks how you as a recipient handle our email deliveries. We see how often you open emails and which topics interest you. We do this in order to provide you with more relevant communication. You may opt out of this by contacting email@example.com
We also register personal data associated with visitors to SKAGEN's website and social media channels. You can find further information about this in the section on "What happens when you make a digital visit to SKAGEN?"
The data controller is the person who decides the purpose for processing personal data. In SKAGEN, the Operations Director is the data controller.
SKAGEN has entered into agreements with suppliers regarding data processing associated with fund management and ongoing operations. Individual data processing agreements regulate all personal data that is shared with our suppliers. Our suppliers may not use the data for any purpose other than the one for which it is gathered and they have entered into confidentiality agreements. SKAGEN does not use data processors outside of the EU/EEA.
All registered persons have legal rights associated with their personal data. This includes the right to information, access, correction, deletion, data portability and restricted processing, as well as the right to oppose processing and to deny automated individual decision-making, including profiling. Any such enquiries should be sent to firstname.lastname@example.org, which SKAGEN is obliged to answer within one month.
Information about your most important rights are provided below.
You have the right to information about, amongst other things, which of your personal data we process, what the purpose of the processing is, where we have gathered the information from, how long we expect the data to be stored for and what your rights and complaint options are.
It is important that the information we have about you is correct. You may demand that we correct or supplement information about you if it is incorrect or insufficient.
SKAGEN deletes personal data when it is no longer needed for us to fulfil the purpose for which it has been gathered. For clients this means that as long as you have an agreement with us, we store the necessary information about you. When the contractual relationship comes to an end, we store the data until the legal storage period expires.
You may also demand that data be deleted, for example if you withdraw your consent.
You have the right to demand restricted processing of your personal data. In certain situations you may have the right to object to the processing of your personal data. You may also object to the use of automated individual decision-making related to you, such as profiling.
You have the right to request that the personal data we have registered about you is transferred to another data controller in a machine-readable format. SKAGEN may have a legal requirement to continue to store this personal data for a certain time period.
What happens when you make a digital visit to SKAGEN?
When you visit our website www.skagenfunds.com or when you go into SKAGEN's profiles on social media channels such as Facebook, Instagram, Twitter and LinkedIn, you leave a digital trace.
- The external social media channels have their own regulations for processing your personal data, which you accept when you accept their user conditions. SKAGEN has no influence over this.
What are cookies?
Cookies are small data files which store information about how you use a website. The information is stored in your browser, i.e. by you.
What information is registered?
At www.skagenfunds.com, we register the following information about you:
- your location, using the IP address, location data or similar
- your electronic footprint, such as which pages you visit and which products you order
- technical information about your browser and operating system
- Optimise the website's technical functionality, user experience and contents
- Make it easy for clients to log in and remain logged in to our client portal
- Recognise visits from returning users
- Analyse and learn from your behaviour, so that we can adapt content and make it as relevant as possible for you
- Allow you to carry out tasks more quickly
The information we gather related to your use of our website may in certain cases be combined with information from your client relationship. You may read more about this in the section on "Client profiles".
How to avoid cookies
On SKAGEN's website, the setting "allow all cookies" is switched on. If you do not wish to allow the storage of cookies on your computer, you may switch off the setting in the browser. Please note that you may lose some functionality on both SKAGEN's and other websites.
You may delete cookies by following the instructions for deleting cookies in your browser. To find out more about cookies, visit www.aboutcookies.org or www.allaboutcookies.org.
If you wish to allow cookies, but at the same time remain informed about what SKAGEN stores, there are features in your browser which enable you to do this in a relatively simple way. Examples:
Use of analytical tools
SKAGEN uses Google Analytics to analyse traffic to our own and other websites. To opt out of being tracked by Google Analytics, visit http://tools.google.com/dlpage/gaoptout.
SKAGEN uses Apsis to track how you handle email communication from SKAGEN. You may opt out of this by unsubscribing via the link in the email or sending an email to email@example.com
Personal data ombudsman
SKAGEN has appointed a personal data ombudsman to provide help to you as a client, amongst other things. If you have any questions about how we process your personal data or wish to exercise your rights as a person registered with SKAGEN, you may contact the personal data ombudsman by sending an email to firstname.lastname@example.org
Data Protection Authority
The data protection authorities supervises how SKAGEN processes personal data and handles complaints from registered persons who believe that they have been exposed to a data breach.
Please note that the General Data Protection Regulation and the new Personal Data Act comes into force in Norway on 1 July 2018, and the Norwegian Data Protection Authority will then be the lead supervisory authority for SKAGEN's data processing activities across the EU and EEA. You may read more about which requirements are imposed for the processing of personal data and how you can file a complaint on the Norwegian Data Protection Authority's website.
Between 25 May and 1 July 2018 SKAGEN is under the supervision of the various national data protection authorities in each country where data processing takes place, such as the UK Information Commissioner's Office and the Dutch Data Protection Authority.
Published 24 May 2018