We collect and process personal data for several different purposes. We utilise personal data to fulfil our legislated duties and our obligations defined in our customer agreements, and we also use personal data to make you offers and give you advice on our products and services.
The purpose of processing personal data is to:
In connection to our customer and marketing register, we will process the following personal data of customers or other data subjects:
Disclosing the personal information collected for the purpose of knowing the customer is a requirement for establishing a contract relationship and/or a customer relationship. Without the necessary personal data, we cannot provide investment services.
Data are primarily received from the data subject themselves.
Additionally, data can be disclosed within the group for group-level IT administration purposes, to manage customer relationships and for marketing purposes.
We have outsourced part of our IT administration to external service providers, and personal data will be stored on servers maintained and protected by them. These external service providers will act as personal data processors in their part, and an agreement required by the regulations will be signed with them concerning the methods of processing personal data.
We will disclose your personal data if it is necessary to perform our agreement obligations, for example in connection with performing a fund subscription. In such cases, we may also need to transfer your data outside the EU/EEA, in which case we will ensure the appropriate protective measures of this transfer (e.g. we will apply the EU-approved standard contract clauses). Data may be disclosed to authorities based on compelling regulations.
JAM maintains the confidentiality of personal data. Only the employees that are entitled to process personal data for the purposes of their work are authorised to access our customer data. Prohibition on the use and disclosure of confidential information applies to our entire personnel. Each user has their own login and password for the system. The data will be collected to databases that are protected with firewalls, passwords and other technical measures. Databases and their backups are located in locked facilities and only certain appointed persons have access to them.
We instruct the employees taking part in personal data processing in the appropriate processing of personal data and their confidentiality. JAM also continuously ensures the adequate expertise of its staff. In order to monitor and control the processing operations, JAM may occasionally review the log data with regard to the processed personal data of service users.
We will store personal data as long as necessary for their purpose of use, for example for the duration of the customer relationship’s validity or the minimum storage time required by the regulation.
We will assess the necessity of storing data regularly, taking into account the applicable laws. In addition to this, we implement reasonable measures to ensure that no incompatible, outdated or incorrect personal data with regard to their purpose of use will be stored in the database about the data subject. We will rectify or erase such data without delay.
As a data subject, you have the right to inspect the data concerning you that are saved in the register and claim the data to be rectified or erased. You also have the right to cancel your consent to collecting your data, amend it or object to the processing.
We ask you to take into account that we have a legislated duty to maintain some data with regard to providing investment services for a certain period of time.
You have the right to prohibit us from targeting marketing measures at you. You can submit this prohibition by email, by phone or by visiting our office. If you wish, you can also identify which communication tool we can use to send you marketing messages.
As a data subject, you have, in accordance with the General Data Protection Regulation, the right to object to or request restricting the processing of your data as well as submit a complaint about personal data processing to the supervisory authority.
For special personal reasons, you have the right to object to the processing measures targeted at your personal data when the basis for processing the data is the customer relationship between us. In connection to making the claim, you need to identify the special reason due to which you are objecting to the processing. We can refuse the claim only on legal grounds.
Head of Compliance & Risk Control Ludviginkatu 6, 00130 Helsinki
Tel. +358 50 4062254
This policy will be updated as our operations develop or regulations change. If these changes are significant, we will attempt to notify you of them also in other ways, such as by e-mail or by publishing a notification on our website. We recommend visiting our website regularly and reviewing the potential changes of the policy.
JAM advisors processes personal data in accordance with the Personal Data Act and legislation on the financial and investment service sector. JAM Advisors sees to the realisation of privacy and non-disclosure in the processing of personal data. Personal data is used for taking care of customer relationships, offering products and services, marketing and risk management.
JAM Advisors has several personal data files for the management of personal data, and a separate description of data file has been prepared for each one.
Other descriptions of JAM Advisors’ data files are found at JAM Advisors’ offices or requested by mail.
Information is obtained for the personal data files from the data subjects themselves, their representatives, public registers maintained by the authorities and the credit rating register. In addition, telephone conversations with JAM Advisors’ representatives may be recorded and messages stored to preserve the content of messages.
JAM Advisors will not disclose information in its possession to third parties unless they have the consent of the data subject or in cases required by law.
Every data subject has the right to review their information. The right of access is free of charge a maximum of one time per year (12 months). The request must be made in writing or in person at the registered office. In addition, every data subject has the right to demand the correction of incorrect information in the data file or to supplement any incomplete information. The data subject also has the right to refuse the use of their information for direct marketing. Requests for review, correction and supplementation should be addressed to: JAM Advisors, Pohjoisesplanadi 35 Aa, 00100 Helsinki. The data subject must verify their identity.
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