Evolver Equity Ltd (”Evolver”) is an Alternative Investment Fund Manager that offers services to its customers.
In the course of our business, we register and use information about you (personal data), when you interact with us as an individual who is connected with a business or corporate customer of ours. You could be an authorised signatory, a beneficial owner, a director, an employee, a guarantor or a third party connected to our customer.
We may process your personal data for any of the following purposes, depending on the capacity in which you interact with us:
- Meeting our obligations and providing services and products to our customers
- Complying with applicable law, including anti‐money laundering legislation
- For administrative purposes, including to secure and maintain our internal systems, platforms and
other digital applications
- Upholding an adequate level of security when you visit our premises
- Carrying out controls to prevent fraud and financial crime
- Managing the customer relationship, including marketing of services and products.
We will only register and process your personal data if we have a legal basis to do so.
This means that we register and use personal data when:
- you have made or you are considering making an agreement with us, cf. GDPR art. 6.1(b)
- you have granted us consent to use your personal data for a specific purpose, cf. General Data
Protection Regulation (GDPR) art. 6.1(a)
- we have to comply with certain legal obligations in accordance with Finnish and/or EU legislation
- we or the business or corporate customer that you have a connection with pursue a legitimate interest.
This could be when we or the customer have a business or commercial reason, such as administrate the services and products that the customer has requested and to give you the necessary access to digital services, to use your personal data, need to prevent abuse and loss, need to strengthen IT and payment security or want to use it for marketing purposes. We will only do so if our interest clearly outweighs your interest in not having your personal data processed by us, cf. GDPR art. 6.1(f).
2. WHAT PERSONAL DATA DO WE REGISTER AND USE?
We typically process the following types of personal data:
- Basic personal information, for instance your name, address, occupation, contact information, country of residence, social security number and date of birth
- Identification documentation, for example a photocopy of your passport, driving licence, or other documentation required by law
- Information provided by you about preferences for various types of marketing events
- Information about your education, profession, work, knowledge and experience
- Information about your investment targets
- Digital information related to your use of our websites, platforms and digital applications, including,
traffic data, location data and other communication data
- Biometric data, such as facial image.
3. HOW LONG DO WE STORE PERSONAL DATA?
We keep your data only for as long as it is needed for the purpose for which your data were registered and used. Therefore, we keep your information as long as we are providing a financial service or product to you. When your business connection with us has terminated we normally keep your data for a further 7 years.
This is primarily due to our obligations under the Bookkeeping Act, the Anti-Money Laundering Act and requirements from the Financial Supervisory Authority. In certain circumstances we keep your information for a longer period of time. This is the case for example if the statute of limitation is 10 years then we may keep your data for up to 10 years.
4. 3rd PARTIES AND PERSONAL DATA
We register and use data from third parties, for instance publicly accessible sources and registers. We register and use the data they have about you to check that the data you have
provided to us is accurate.
5. WHICH 3rd PARTIES DO WE SHARE YOUR PERSONAL DATA WITH?
In some cases, we may share personal data with third parties outside Evolver:
- We disclose personal data to public authorities as required by law, to the Finnish tax authorities in accordance with applicable legislation for statistical and other purposes.
- Banks and credit institutions requiring information about Evolver’s co-investors for Anti-Money Laundering/KYC purposes.
- With your consent or if we are allowed by law, we may disclose data to external business partners.
6. YOUR RIGHTS TO INSIGHT INTO YOUR PERSONAL DATA
You can get insight into the personal data we have registered about you, how we use it and where it comes from. You can obtain information about how long we store your data and who receives data to the extent that we disclose data in Finland and abroad. Your right of access may be restricted by legislation, protection of other persons’ privacy and consideration for our business and practices. Our know-how, business secrets as well as internal assessments and material may also be exempt from the right of insight.
7. RIGHT TO RECTIFICATION OR ERASURE OF REGISTERED DATA
If the data we have registered about you is incorrect, incomplete or irrelevant, you are entitled to have the data corrected or erased subject to restrictions in existing legislation and our rights to process data. These rights of correction and erasure are known as the “right to rectification”, “right to erasure” and “right to be forgotten”.
8. RESTRICTION OF USE
If you believe that the data we have registered about you is incorrect or if you have objected to the use of the data, you may demand that we restrict the use of the data to storage until the correctness of the data can be verified or it can be checked whether our legitimate interests outweigh your interests.
In certain circumstances, you have the right to object to our processing of your personal information including when we rely on our legitimate interest to process your personal information. You also have the right to object to our use of your personal information for marketing purposes, including profiling that is related to such purpose.
If you are entitled to have your data erased, you may instead request us to restrict the use of the data to storage. If we need to use the data solely to assert a legal claim, you may also demand that any other use of this data be restricted to storage. We may, however, be entitled to other use of the data to assert a legal claim or if you have given your consent to this.
9. WITHDRAWAL OF CONSENT
You can withdraw a consent at any given time. Please note that if you withdraw a consent, we may not be able to offer you specific services or products. Note also that we will continue to use your personal data, for example if we are required to do so by law.
10. DATA PORTABILITY
If we use data based on your consent or because of an agreement and the data processing is automated, you have the right to receive a copy of the data you have provided in an electronic machine‐readable format.
11. CONTACT DETAILS AND HOW YOU MAY COMPLAIN
You are always welcome to contact us if you have any questions about your privacy rights and how we register and use personal data. You can contact our Data Protection Officer via email email@example.com.
If you are dissatisfied with how we register and use your personal data and your dialogue with the Data Protection Officer has not led to a satisfactory outcome, you can lodge a complaint with the Finnish Data Protection Ombudsman.