GDPR

This privacy policy describes how Pensum Asset Management processes information about our customers, visitors to the website pensumgroup.no and inquiries Pensum Asset Management receives by post, telephone, and e-mail.

Pensum Asset Management depends on the trust of customers, business partners and others, and we are concerned with safeguarding your privacy. Your information must be safe with us, and we will therefore inform you about what information we collect and how we safeguard your privacy.

1. What personal data do we collect?
Personal data is information that is directly or indirectly linked to a natural person. Personal data is information that is directly or indirectly linked to a natural person. Pensum Asset Management provides investment services to private and corporate clients, as well as sending out newsletters and other marketing material. The personal data that is collected depends on the type of product or service that you as a customer are offered.

Identification information:
We collect social security number, name, and ID (passport, driving license etc.) if we are obliged to do so by law.

Contact information:
We collect contact information to the extent that it is necessary for the customer relationship, e.g. address, telephone number, e-mail or other.

Financial information:
Customer and product agreements, transaction data.

Statutory information:
Pensum Asset Management collects statutory information such as e.g. check against the EU sanctions lists, tax information if it is necessary for the customer relationship and basic information that is required in connection with Pensum Asset Management providing investment services.

Special information:
Pensum Asset Management is required by law to make audio recordings of telephone conversations about investment services.

2. Where do we obtain the information from?

We collect information from:

• The customer
• Owner or company representatives at the customer
• Third parties
• Recording of telephone conversations and other electronic communications

3. For what purposes is the information used?
The information Pensum Asset Management collects will be used for:

• Customer administration
• Fulfillment of the agreement between the customer and Pensum
• Asset Management
• Customer register
• Risk classification
• Prevention and detection of criminal offences
• Marketing (with consent)
• Fulfillment of regulatory requirements

4. Disclosure of information
Pensum Asset Management discloses necessary information to third parties in order to fulfill the company’s obligations towards customers, e.g. to custodian bank.
Pensum Asset Management discloses information to authorities when ordered or required by law.
Pensum Asset Management has entered into Data Processing Agreements with suppliers regarding data processing, and our suppliers cannot use the information for anything other than the purpose for which it was obtained.
We do not send the information to countries outside the EU/EEA without the customer’s consent.

5. Legal basis
Pensum Asset Management must have a processing reason in order to be able to process personal data, and the company’s basis for collection is:

• Necessary collection in connection with fulfilling the assignment for the customer, e.g email address and telephone number
• Statutory requirements, i.e The Securities Trading Act
• Consent

6. Your rights as a customer
You have access to the information we hold about you and the right to data portability.
You have the right to demand the deletion of the information (within the legal framework on requirements for storage).
You have the right to correct incorrect information about yourself.

7. Data controller
Data controller Pensum Asset Management regards itself as data controller as the company has an independent purpose for collecting the information.

8. Contact
Contact compliance@pensumgroup.no if you have any questions.