Last updated: 23 May 2018.

Introduction
The purpose of this privacy policy is to provide you with information on our use of your personal data in accordance with the EU data protection regime introduced by the General Data Protection Regulation (Regulation 2016/679, the "Data Protection Legislation"). The policy may be amended from time to time and the last updated version will be available on Sector’s website.

Who this affects
This affects individual persons.

Your personal data
Personal data includes information such as;

 - name
 - residential address
 - email address
 - other contact details
 - corporate contact information
 - signature
 - nationality, place and date of birth
 - personal identification (personal no., tax no., passport, etc)
 - correspondence records (such as telephone recording, emails, meeting minutes)
 - bank account details
 - details relating to your investment activity in funds manged by any company within Sector

We only collect personal information that is reasonably necessary for us to provide you with our services. The information we collect will depend upon the nature of our relationship.

How we may use your personal data
Sector, as the data controller, may collect, store and use your personal data for lawful purposes:

(i) for legal requirements including, but not limited to;
 - to fulfil anti-money laundering obligations of verifying the identity of our customers/ beneficial owners  
 - for prevention of fraud
 - to fulfil the Know Your Client (KYC) obligations
 - in response to requests from regulatory authorities

(ii) to fulfil obligations in agreements with customers

(iii) for direct marketing purposes

(iv) for quality control, business and statistical analysis; for customer service, training and related purposes.

Personal data are only stored and processed when a legitimate interest exists and such legitimate interest is not overridden by your personal interests, fundamental rights or freedom. We will be acting in a fair, transparent and accountable manner and taking appropriate steps to prevent activities having any unwarranted impact on you, and noting your right to object to such storage.

Should we have a need to use your personal data for other specific purposes, we will contact you.

Cookies
To make our website work properly, we may place small text files called cookies on your device. A cookie is saved by a website on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time.

To improve user experience on the website, we use Google Analytics to measure how users interact with website content. For more information, please visit Google Analytics’ website here.

We use MailChimp as our marketing automation platform to send emails with information, news and insights on our products and services. MailChimp provides Sector with information on what you open and which links you click on. The purpose of this is to provide our customers with the best possible service, support and communication. The information transferred to MailChimp will be processed in accordance with their privacy policy and terms.

Similarly, ProFundCom may also be used as a marketing automation platform. The information transferred to ProFundCom will be processed in accordance with their privacy policy and terms.

Why we may transfer your personal data
We may share your personal data within Sector (the investment manager, the back and middle office, the marketing and investor relations service providers), to fulfill delegates between each separate Sector company.

In addition, your personal data may be shared with fund administrators or vendors (e.g. IT support) that Sector has entered into non-disclosure agreements with.

Registered personal data will be reported to public authorities if there is a statutory duty of providing information.

The data protection measures we take
Any transfer of personal data by us shall be subject to appropriate safeguards being in place in accordance with the conditions in the Data Protection Legislation. We and our duly authorised delegates shall apply appropriate information security measures designed to protect data in our possession from unauthorised access by third parties or any form of computer corruption.

We shall notify you of any personal data breach affecting you that is likely to result in a high risk to your rights and freedoms.

For any additional information on the appropriate safeguards, please see "Getting in touch" below.

Your data protection rights
You have certain rights regarding our use of your personal data such as:

 - the right to access your data (in an easily readable form);
 - the right to examine and correct your data;
 - the right to data portability;
 - the right to restrict the use of your data;
 - the right to withdraw any consent given to the processing of your data (where applicable);
 - the right to receive information regarding any entities we disclose your data to;
 - the right to lodge a complaint with the Norwegian Data Protection Authority (“Datatilsynet”).

You also have the right to object to the processing of your data where we have considered this to be necessary for the purposes of our legitimate interests.

Please note that the right for your data to be erased (the "right to be forgotten") that applies in some contexts will not be applicable to all of the personal data we hold, given some of the purposes for which we use the data, as described above.

Our retention of your personal data
We or our duly authorised delegates may retain your personal data for a period of up to seven years from the point where your business relationship with us has ceased. Thereafter, we and our duly authorised delegates will refrain from collecting any further personal data on you and shall take appropriate steps to dispose of any records containing your personal data, to the extent this is operationally feasible and proportionate.

Getting in touch
Should you have any queries or wish to discuss your data protection rights with us, please contact our Compliance team at compliance@sector.no or +47 23012900.