Data Protection Policy

American Prudential Capital

Definitions

1. Data protection principles
   American Prudential Capital is committed to processing data in accordance with its responsibilities under the GDPR.
   Article 5 of the GDPR requires that personal data shall be:
   1. Processed lawfully, fairly, and in a transparent manner in relation to individuals;
   2. Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes shall not be considered to be incompatible with the initial purposes;
   3. Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
   4. Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
   5. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
   6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.”
2. General provisions
   1. This policy applies to all personal data processed by American Prudential Capital.
   2. The Responsible Person shall take responsibility for American Prudential Capital’s ongoing compliance with this policy.
   3. This policy shall be reviewed at least annually.
   4. American Prudential Capital shall register with the Information Commissioner’s Office as an organization that processes personal data.
3. Lawful, fair, and transparent processing
   1. To ensure its processing of data is lawful, fair, and transparent, American Prudential Capital shall maintain a Register of Systems.
   2. The Register of Systems shall be reviewed at least annually.
   3. Individuals have the right to access their personal data and any such requests made to American Prudential Capital shall be dealt with in a timely manner.
4. Lawful purposes
   1. All data processed by American Prudential Capital must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task, or legitimate interests (see ICO guidance for more information).
   2. American Prudential Capital shall note the appropriate lawful basis in the Register of Systems.
   3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.In accordance of article 5 of the GDPR, we will send you notifications on the following:
      • The information that personally identifies you which we asked from you through American Prudential Capital Website, how the information will be utilized and the people or websites it may be shared
      • We will provide choices with respect to the use of your personal information
      • The security methods we use for protection from misuse of your personal information
      • The procedure of correcting any erroneous or inaccurate information you submitted to us
   4. In accordance with the provisions of articles 15 to 22 of the GDPR, you can contact us at your convenience through the email address or telephone number shown on American Prudential Capital Website on the following:
      • To verify what information we have about you, if any
      • To correct or change any information we have about you
      • To ask us to delete any information we have about you
      • To express any concern or issue about our use of your information
5. Data minimization
   1. American Prudential Capital shall ensure that personal data are adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
   2. American Prudential Capital is the exclusive owner of all the information gathered from American Prudential Capital Website. We can only gain access to or gather information that you freely and voluntarily provided us through email or other direct means of communication. American Prudential Capital guarantees that your information will not be rented or sold to other people. We will only use your information when responding for any reason or purpose that you contacted us. Neither will we share your information to any third party not within our organization, except when necessary per your request.
6. Accuracy
   1. American Prudential Capital shall take reasonable steps to ensure personal data is accurate.
   2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
7. Archiving / removal
   1. To ensure that personal data is kept for no longer than necessary, American Prudential Capital shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
   2. The archiving policy shall consider what data should/must be retained, for how long, and why.
8. Security
   1. American Prudential Capital shall ensure that personal data is stored securely using modern software that is kept up-to-date. Sensitive information that we collect, such as credit card data, is encoded and transferred to us in the most secured and safe way. You can verify this by the lock icon on the address bar. Check if the address of the web page starts with an “https.” We use encryption so we can protect sensitive information that are transmitted online and to protect your personal information even offline.
   2. Only the official staff of American Prudential Capital who need the information to do specific jobs for American Prudential Capital are allowed access to information that are personally identifiable. All our computers and web servers where we stock personally identifiable information are placed in a secured environment.
   3. When personal data is deleted, it should be done safely such that the data is irrecoverable.
   4. Appropriate back-up and disaster recovery solutions shall be in place.
9. Breach
   In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, American Prudential Capital shall promptly assess the risk to people’s rights and freedom and inform any relevant parties without undue delay.

END OF POLICY