Affinity Management Services Limited (AMSL) and Affinity Management Services (Malta) Limited (AMSML) (together “Affinity”) is committed to keeping your personal information secure and to adhering to the principles laid down in the General Data Protection Regulations (“GDPR”) which came into force on 25th May 2018.
Why do we need your information?
AMSL is regulated in the Isle of Man by the Isle of Man Financial Services Authority to undertake the following classes of Regulated Activity:-
AMSML is regulated in Malta with the Malta Financial Services Authority to undertake the following classes of Regulated Activity:-
AMSML is also an
Affinity is obliged to operate in accordance with the framework of the laws and licensing regime in place in their applicable jurisdictions and applicable international laws. Such laws and regulations include (but are not limited to) legislation covering financial services, anti-money laundering and countering of terrorism and taxation (“the applicable legislation”).
What information do we need?
Affinity will collect personal information about you at the beginning of our relationship and may also collect further information from you from time to time during the course of our relationship to ensure our continued adherence with the applicable legislation.
We will only collect personal data that is absolutely necessary for us to comply with our requirements under the applicable legislation.
We do not collect any personal information that is deemed to be of a “Special Category” under GDPR (eg. information pertaining to race; ethnic origin; political beliefs, religious beliefs, trade union membership, genetics, biometrics, health, sex life or sexual orientation).
What we do with it
All of the personal data we collect is processed by our staff and is used in line with the services we are providing to you. This may include:
As the services we provide are so varied the way we use your information will be determined by what those services are. A specific list based on our agreed relationship can be provided, please contact our Data Protection Officer for further information.
How we store your information
We store all electronic personal information received within secure software which is stored and maintained on servers located within the Isle of Man and maintained by a third party cloud processor which is resident in the Isle of Man. The Isle of Man is recognised by the EU as a jurisdiction that provides an adequate level of data protection.
We store all non-electronic personal information received within files located in our secure offices or within a secure archive facility which is operated by providers who are GDPR compliant.
Sharing your information
We may share your information within our group of companies or with other bodies where lawful circumstances provide us to do so. These include:
We do not sell, distribute or lease your personal information to third parties, unless we have your express consent to do so or are required to by law.
Transferring your information to other countries
Affinity may have to share your information with an organisation in another jurisdiction, when these circumstances arise we will make sure that information remains secure and that there is a GDPR compliant data processor agreement in place where required.
The EU has deemed certain countries to have equivalent safeguards in terms of GDPR. Those countries as well as those within the EEA are considered to be secure and offer the same protection for your personal information.
In circumstances where information needs to be transferred to a jurisdiction that is not considered to be equivalent Affinity will put in place a GDPR compliant data sharing agreement which will ensure that the required additional safeguards are in place.
How we keep your information accurate
Article 5 of GDPR requires Affinity to ensure the personal data that we hold for you is accurate and up to date.
Affinity has adopted policies to ensure that they take every reasonable step to ensure that it keeps in regular contact with its clients and customers with a view to ensuring that the information that we hold for you remains up to date and accurate at all times.
What we do with your information when we don’t need it anymore
Affinity will only maintain your personal information for the minimum amount of time it is required to do so by law after which time it will be securely destroyed.
How you can access the information we hold
You have a right to request a copy of the information that we hold about you.
If you would like a copy of some or all of your personal information that we hold, please contact the Data Protection Officer at the respective office, whose details are listed below.
You may ask us to correct or remove information that you feel is inaccurate although our legal and regulatory obligations must always be adhered to.
A Data Subject request is provided free of charge, however we will reserve the right to charge for any Data Subject request which we may feel is excessive.
Affinity’s role as a Data Controller
AMSL is registered as a “Data Controller” with the Isle of Man Information Commissioner’s Office.
AMSML is registered as a “Data Controller” with the Malta Office of the Information and Data Protection Commissioner
Data Protection Officer
AMSL and AMSML have appointed Data Protection Officers in each of their respective offices, who are responsible for the handling of Data Subject Requests and acting as a point of contact with the relevant authorities in each jurisdiction .
Second Floor Level 2
14 Athol Street Progetta House
Douglas Tower Street
Isle of Man Birkirkara
IM1 1JA BKR 4012
British Isles Malta
Tel: +44 1624 670583 +356 2010 4700
Links to Other Websites
Further information pertaining to the operations of Affinity can be found on our website at the following address. http://www.affinity.co.im/.
We will only send you information about our products and services with your express consent which you may opt out of at anytime.
If you wish to raise a complaint on how we have handled your personal data, you can contact the Data Protection Officer in the relevant office who will investigate the matter.
If you are not satisfied with our response or believe we are processing your personal
data in contravention of the law you can complain direct to the applicable Data Protection and Information Commissioner’s Office (as below).
Isle of Man
Isle of Man Information Commissioner’s Office
Office of the Information and Data Protection Commissioner