GDPR Compliance | First Command

This Addendum to the First Command Privacy Notice applies while you are based in Europe to give you more details about the processing of information about you and also to explain additional rights you may have under European data protection law. First Command Europe Ltd is the data controller of information about you collected while you are based in Europe. For the avoidance of doubt, that information will benefit from the same protections described in the First Command Privacy Notice while you are based in Europe.

As an additional contact point while you are based in Europe, please write to us at: First Command Europe Ltd. ATTN: District Advisor, 1A Gregory Road, Mildenhall Suffolk, IP28 7DF, United Kingdom.

A. PROCESSING AND TRANSFER OF YOUR INFORMATION

We process the following information about you to enter into or perform a contract with you such as an investment product: your name, address, names of family members, marital status, Social Security Number, employment information and financial situation; your account balances, holdings, and history (bank, mutual fund, annuity, etc.); insurance coverages, limits, rates, beneficiaries and claims history; and to your creditworthiness, your credit score, credit usage, and claims history.

We also have a legitimate interest in processing information we hold about you in order to manage our relationship with you and to pursue the commercial objectives of our business.

Please note that information about you will need to be transferred to the systems in the US operated by the First Command Family of Companies. We have put in place appropriate contractual measures to ensure your information is protected in accordance with the standards of EU data protection law.

We have a policy to delete information about clients when no longer needed for the relationship and any follow up issues or concerns such as access by authorities which regulate our business.

B. YOUR CHOICES AND YOUR RIGHTS

In addition to your options described in the First Command Privacy Notice, you have the following rights in connection with our processing of your information while you are based in Europe.

Your right to access the information we hold about you: You may request access to the information we hold about you. The information will usually be made available within 30 days, although sometimes we may not be able to give you access to the information (for example, we may not be able to give you access if it would unreasonably affect someone else's). Please note that we may apply a reasonable administrative charge for providing access to your information in certain circumstances. We will advise you of the charge and obtain your approval before providing you with access to your information.

Please note that if you request a copy of your data using electronic means (such as email), then we will provide a copy of your information in electronic form unless you ask us to do otherwise. You can make access or certain adjustments to your account directly through your online account, or you can contact us with your request.

Your right to have your information corrected or deleted: If you have an account with us, you can log into that account to update your information. If you have problems updating the information on your account or if you would like us to delete your information, please email your request to us and we will action it as soon as possible.

Your right to object to processing of information about you: You have the right to ask us to stop processing your information, even where that processing is necessary for our legitimate interests, including profiling. We do not make decisions based on profiling where there may be a legal or similarly significant effect. All financial companies need to share customers’ information to run their everyday business as permitted by United States law.

Your right to withdraw consent to processing: If you have consented to us processing your personal data for a particular purpose, you have the right to withdraw your consent at any time, free of charge, by contacting us. If you withdraw your consent to processing, we may still contact you in connection with your account, relationship, activities, transactions and communications with us. We may also continue to process your information to enter into or perform a contract with you or if we are processing based on our legitimate interests.

Your right to withdraw consent to direct marketing: If you consented to receiving promotional emails from us and would like to opt out, please follow the unsubscribe instructions in each email. If you opt out of receiving promotional correspondence from us, we may still contact you in connection with your account and the relationship, activities, transactions and communications with us.

Your right to have an electronic copy of your personal information transmitted: Where we hold personal information about you with your consent or to enter into or perform a contract with you, you have the right to ask us to provide you with the information we hold about you in a structured, commonly used and machine-readable format and, where technically feasible, to transmit that information to another organisation.

Your right to lodge a complaint with the local data protection authority: You have the right to lodge a complaint with a data protection authority if you believe that we have not complied with applicable data protection laws. You can access a list of local data protection authorities at the following link:
http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm