GDPR Rights

You rights as a data subject

Right of confirmation
Each data subject has the right to obtain from the controller the confirmation as to whether personal data concerning him or her are being processed. If a data subject wishes that his data is no longer processed they may contact the company at any time.

Right of access
Each data subject shall have the right to obtain free information about his or her personal data stored at any time as well as a copy of this information, the purpose of processing, with whom this data has been disclosed if any, the length of time the data will be retained, the existence of the right to request erasure of personal data, the existence of the right to lodge a complaint with the Data Protection authority. Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to third parties and have the right to be informed of the appropriate safeguards relating to the transfer.

Right to rectification
Each data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning them. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact the company.

Right to erasure (Right to be forgotten)
Each data subject shall have the right to request the erasure of personal data concerning them without undue delay. The controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent.
  • The data subject objects to the processing and there are no overriding legitimate grounds for the processing.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with other legal obligations.
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the above reasons applies, and a data subject wishes to request the erasure of personal data stored by Phoenix Group Ltd, he or she may, at any time, contact any employee of the company who shall promptly ensure that the erasure request is complied with immediately.

Right of restriction of processing
Each data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful, and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the above conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Phoenix Group Ltd, he or she may at any time contact any employee of the company who will arrange the restriction of the processing.

Right to data portability
Each data subject shall have the right to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit this data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent.

Furthermore, in exercising his or her right to data portability the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, the data subject may at any time contact any employee of Phoenix Group Ltd

Right to object
Each data subject shall have the right to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her. Phoenix Group Ltd shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If Phoenix Group Ltd processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Phoenix Group Ltd to the processing for direct marketing purposes, then Phoenix Group Ltd will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Phoenix Group Ltd  for scientific or historical research purposes, or for statistical purposes, unless the processing is necessary for the performance of a task carried out for reasons of public interest. In order to exercise the right to object, the data subject may contact any employee of the Phoenix Group Ltd

Automated individual decision-making, including profiling
Each data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, Phoenix Group Ltd shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision. If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the Phoenix Group Ltd

Right to withdraw data protection consent
Each data subject shall have the right to withdraw his or her consent to processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of Phoenix Group Ltd

Data protection for applications and the application procedures
The data controller shall collect and process the personal data of applicants for the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller.

Last revison 18th May 2018

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