Privacy policy

It explains how JMA Prime Estate processes personal data, people whose personal data the company processes should understand how and why their personal data is processed in JMA Prime Estate's operations and what rights they have in relation to the company.

It is important to JMA Prime Estate that customer-related information, including personal data, as well as information about the company's employees, is treated securely and confidentially and that applicable regulations are complied with.

The following describes how JMA Prime Estate handles personal data in central parts of its operations. JMA Prime Estate carries out assignments within the framework of the business both as a data controller and as a data processor. JMA Prime Estate is the data controller for the processing of personal data that the company carries out for its own purposes, including checks regarding the existence of conflicts of interest and independence.

Information on the processing of personal data for the acceptance and management of clients and assignments

Background

When processing personal data, the controller has an obligation to provide certain information to data subjects. For the purposes of the assignment, personal data will be processed by JMA Prime Estate. For this reason, the following information is provided.

JMA Prime Estates' processing of personal data

JMA Prime Estate will process personal data in accordance with applicable law. The personal data that will be processed is obtained from the client, its group companies (if applicable), or other, e.g. authorities, municipalities or publicly available sources and relates to authorised representatives and other persons whose personal data is needed to manage the client relationship as well as the beneficial owner. The personal data are processed prior to the acceptance of clients and/or assignments and for the performance of the assignment in order to:

• carry out independent checks,
• carry out quality controls; and
• to document the actions taken.

Such processing is necessary for the performance of the legal obligations of JMA Prime Estate evaluating the possibility or having undertaken the assignment and is necessary for the legitimate interest of JMA Prime Estate to fulfil its professional obligation. JMA Prime Estate may also process personal data for other risk management purposes (such as insurance matters). This processing is necessary for the legitimate interest of JMA Prime Estate to manage risks and possible claims.

JMA Prime Estate may also process personal data to inform about seminars and other events organised by JMA Prime Estate and to send out newsletters and other marketing. Processing for these purposes is necessary for JMA Prime Estate's legitimate interest in being able to reach out to employees of clients who may be interested in events, marketing and news in areas relevant to these persons' positions.

The personal data in the engagement will be processed for the performance of the agreed services under the Engagement Letter. The legal basis for this processing is either legitimate interest, consent or agreement with the data subject.

Categories of personal data

The categories of personal data that may be processed for the above purposes include.

• contact details such as name, address, social security number/coordination number, telephone number, email address
• details of employment such as departmental affiliation and job title
• other data necessary to evaluate and manage the customer relationship.

In connection with the registration of the client, JMA Prime Estate may also process copies of the identity documents of the persons representing the client within the framework of the customer due diligence measures to be taken in accordance with the Money Laundering Act.

Transfers to third countries

Personal data may be processed by JMA Prime Estate's network agencies and others engaged by JMA Prime Estate for the purpose of carrying out the above-mentioned activities on behalf of JMA Prime Estate; they may be based both within and outside the EU/EEA. In the event of a transfer of personal data for processing in a country outside the EU/EEA, which does not ensure an adequate level of protection, JMA Prime Estate is responsible for ensuring that the personal data is subject to appropriate safeguards and on condition that statutory data subject rights and effective legal remedies for data subjects are available or, where this is not the case, that further supplementary safeguards have been implemented which would ensure that the transferred data receive a level of protection in the third country essentially equivalent to that guaranteed within the EU.

Recipients of the information

JMA Prime Estate is obliged to ensure that the information processed in connection with the assignment is not made available to unauthorised persons, which means that personal data will be treated confidentially. JMA Prime Estate may disclose personal data to network agencies or others engaged by JMA Prime Estate for the purpose of checking and maintaining impartiality and independence, to perform quality controls and take other risk management measures and to send out invitations to events and other marketing material. JMA Prime Estate may also disclose personal data to insurance companies or legal advisors in connection with legal proceedings to the extent necessary to protect its legitimate interests or to other recipients if such obligation exists under applicable laws and regulations, professional obligation or government decision.

Storage of personal data

Personal data will not be processed for longer than is necessary for the purposes for which the personal data are processed. Most of the data related to the performance of the assignment will be kept for ten years after the assignment has ended

Rights as a registered person

In some cases, data subjects have the right to obtain, on request, information as to whether or not personal data relating to the data subject are being processed and, if so, the right to access the personal data in the form of a so-called 'extract from the register'. Data subjects also often have the right to have inaccurate personal data concerning them rectified. Furthermore, data subjects may have the right to have their personal data erased, the right to request the restriction of processing of personal data concerning them or the right to object to such processing. Data subjects also have the right to lodge a complaint with a supervisory authority about the processing.

The information and data that the Contractor receives within the framework of the assignment is subject to a duty of confidentiality, which means that the Contractor may not normally disclose such information. As regards personal data processed in connection with the acceptance of clients and assignments and as a result of the assignment, the Contractor is obliged to retain the documentation in this respect for at least ten years. This means that the deletion of personal data contained in such documentation is not authorised before that time, and sometimes the rectification of the data is not allowed either. For the aforementioned reasons, in such cases it is not possible for the Contractor to restrict or limit the processing of personal data at the request of a data subject. However, in the case of the Contractor's processing of personal data for marketing purposes, data subjects have the right to request erasure, rectification, restriction and to object to the processing of their personal data for such purposes.