Privacy Policy
Collection of information
The collection and processing of personal information are necessary in order to carry out the duties of Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) prevention before establishing a business relationship. The absence of this information may prevent or delay the conclusion of the contractual relationship.
We may also collect additional information about you, directly or indirectly, through official public information sources or private databases specialised in AML/CTF matters, in order to validate or update existing data, or in order to verify your information and your risk profile.
How we use your personal information and what the legal bases are:
The personal data collected and processed by the Management Company will be used:
a) For the purpose of managing the contractual relationship on the basis of performance of the contract;
b) For the purpose of assessing credit risk and the proper recovery of amounts due under the contract on the basis of the pursuit of legitimate interests;
c) In order to assess and manage the risk of money laundering and terrorist financing and to carry out the necessary mandatory communications to the respective official bodies where necessary, on the basis of compliance with legal obligations;
d) Insula does not use automated decision-making in the internal analysis of personal data.
Your rights in relation to your personal data
You may request access to your personal data and ask for it to be rectified, which the Management Company will do as soon as possible. Under Articles 17 to 21 of the GDPR, you may object to the processing of your personal data, restrict its use, request its erasure or ask us to share such data with other organisations in a structured, commonly used and machine-readable format. To exercise the rights set out above, please contact us using the details provided in point 8. Insula is committed to working to find the best and fairest solutions to any complaints regarding the processing of personal data that you may have submitted. If you consider that the Management Company has not been able to resolve the complaints submitted, you have the right to lodge a complaint with the competent supervisory authority – the National Data Protection Commission (CNPD).
Sharing of information
As a rule, Insula does not transfer or share with third parties (other than service providers acting under our guidance and responsibility) data relating to personal information, unless this is required by legal and regulatory requirements. Insula may subcontract service providers for situations where there is such a need or which it considers to be of added value (for example, companies that carry out the Identification and Due Diligence procedure (in whole or in part) under the AML/CFT prevention law). This prerogative implies the need to share information relating to personal data. Insula will take all necessary measures to ensure that service providers offer all guarantees of safeguard, security and confidentiality of the shared personal data and that they act exclusively in accordance with the instructions addressed to them by this Management Company.
Security of personal data
Insula ensures the use of appropriate technical, organisational and security measures to protect personal information, preventing its loss, misuse, alteration or destruction, and ensuring its integrity, availability and confidentiality. To this end, all employees are required to keep personal data confidential. Only authorised personnel bound by the duty of secrecy and confidentiality should have access to this information.
Retention of personal data
Your data will be retained for the period strictly necessary for the purposes of its processing or as required by law or regulation. During the retention period, the integrity and access to the data are guaranteed.
Transfer of information
Insula’s main information support systems are hosted on servers located in Portugal, with no transfer of data outside the country.
Our contacts
For any questions related to the processing of your personal data, please contact us:
Address: Largo Jean Monnet 1, 1250-130 Lisboa, Portugal
Mobile: +351 211 390 606
Email: protecaodados@insulacapital.pt
Changes to the privacy notice
You may always request a copy of this privacy notice using the contact details above. Insula may modify the privacy notice.
