Last Updated: April 2023
Personal Information We Collect
Personal information you provide:
- Contact information, such as your name, email address, personal address, and phone number.
- Professional information, such as your position, job title, professional history, place of work and professional contact details.
- Identification information, such as your date of birth, passport number, photo, driving license number, national identification number, tax identification number, marital status and signature.
- Financial information, such as income, assets, bank details, investment history, and other financial information.
- Preferences, such as your subscription to newsletters or other communications, and details about your engagement with those communications.
- Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us, including your contact information, call recordings, and the content of your communications.
Information we obtain from other sources:
- Public sources and other third parties. In limited circumstances, and where allowed by law, we may obtain information from public sources and third parties, such as credit reference agencies, including information about criminal convictions and offences, when legally required; dietary requirements if we are arranging catering; disability so that we can make reasonable accommodations for you in our buildings; sexual orientation if you provide details of your spouse or partner; and political affiliations to determine whether you are a politically exposed person.
Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Site and our communications with you, such as:
- Device data, such as your computer’s or mobile device’s operating system, manufacturer and model, browser type, IP address, unique identifiers, language settings, mobile device carrier, and general location information such as city, state or geographic area; and
- Online activity and usage data: When you access and use the Services, we receive and store information about such interactions such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.
How We Use Personal Information
We use your personal information for the following purposes:
Managing our relationship with you, including opening an account or entering into a relationship at your request, and performing anti-money laundering, anti-terrorism, sanctions, fraud and other background checks in accordance with our legal obligations and to further our legitimate interests. The personal information we process for this includes your contact information, professional information, identification information, and information from public sources.
Responding to your requests and providing support, including providing you relevant information in response to your inquiries and sending you announcements, updates, security alerts, and support and administrative messages. It is in our legitimate interests to use personal information to respond and resolve your queries, facilitate support and to send you service related updates. The personal information we process when doing so includes your correspondence with us, your contact details and to the extent applicable other personal information processed about you when you use the Site, including device and usage information.
Improve or monitor usage of our Site and to protect, investigate and deter against fraudulent, harmful, unauthorized or illegal activity. It is in our legitimate interests to improve and keep our Site safe for our users, which includes conducting troubleshooting, testing and research and to keep the Site secure. When doing so we may use personal information that we automatically collect about you such as usage and device information.
To monitor and analyze trends and use of our Site. It is in our legitimate interests to analyze the use of our Site. When doing so, we will process personal information that we automatically collect about you or that is generated about you when you use the Site.
To customize communications with you. It is in our legitimate interests to provide you with a tailored service. The personal information we process to do so includes your preferences and contact details.
Marketing and advertising, including for:
- Events and seminars. Except where consent is required, it is in our legitimate interests to use your personal information to invite you to take part in events, seminars or other similar events, and to manage your participation in them.
- Direct marketing. Except where consent is required, it is in our legitimate interests to use your personal information, as permitted by law, to send you direct marketing messages, including, but not limited to, sending newsletters and other relevant information via postal mail, email, telephone, and other means.
For aggregation and anonymization. It is in our legitimate interests to aggregate or anonymize personal information in a form that does not allow users to be personally identified and use the resulting information for statistical analysis regarding the use of the Site, such as to better understand visitors to our Site, or for other purposes.
We will only process personal information on the basis of our legitimate interests where such interests are not overridden by your interests or your fundamental rights and freedoms.
How We Share Personal Information
We do not sell personal information. We may share your personal information with:
Service providers. We share personal information with third parties that provide services on our behalf or help us operate our Site or our business (such as hosting, information technology, customer support, email delivery, and website analytics services), and third parties that assist us with sanctions, anti-money laundering, and credit reference checks.
Professional advisors. We share personal information with professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. We may share personal information with law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate.
Business transferees. We may share personal information in connection with a corporate transaction (or potential transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
Personal information requests. Depending on your location (such as if you reside in the European Union, United Kingdom, or other jurisdictions that offer the privacy rights below), we may offer you choices that affect how we handle personal information. You may request the following in relation to your personal information:
- Information about how we have collected and used your personal information.
- Access to a copy of the personal information that we have hold about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
- Correction of personal information that is inaccurate or out of date.
- Deletion of personal information that we no longer need for lawful purposes.
- Additional rights, such as to object to and request that we restrict our use of your personal information, and where applicable.
- Withdraw any consent you previously provided to us regarding the processing of your personal information at any time. We will apply your preferences going forward. This will not affect the lawfulness of the processing before you withdrew your consent.
To make a request, please email us as provided in the “Contact Us” section below. We may ask for specific information from you to help us confirm your identity. California residents can empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.
Limits on your choices. Your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “Contact Us” section below.
Advertising and marketing. We allow you to control the advertising and marketing you receive as follows:
- Unsubscribe from direct marketing communications. You may opt out of marketing-related communications by following the opt out or unsubscribe instructions contained in the marketing communication we send you or by contacting us using the details in the “Contact Us” section below.
- Online tracking opt-out. You can opt out of interest-based advertising as described in our Cookies Policy.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
International data transfers
If you provide us with your personal information when using the Site from the European Economic Area (“EEA”), Switzerland or the UK or other regions of the world with laws governing data collection and use of personal information, then please note that your personal information will be processed in the United States or other countries that do not have equivalent privacy and data protection laws.
If we transfer your personal information internationally, these countries may not provide the same protections as the data protection laws where you are based. We will ensure that relevant safeguards are in place to afford adequate protection for your personal information, and we will comply with applicable data protection laws. In particular, if you reside in the EEA, Switzerland or UK, we rely on an EU Commission or UK government adequacy decision, on contractual protections for the transfer of your personal information or a derogation if available. For more information about how we transfer personal information internationally, please contact us as set out in the “Contact Us” section below.
Our Site is not intended for use by children. If we learn that we have collected personal information through the Site from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it. If you are a parent or guardian and you are aware that your child has provided us with personal information through the Site, please contact us as set out in the “Contact Us” section below.
Retention of personal information
We retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our policies and with applicable laws, based on factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, and the purposes for which we use personal information.
We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.
Links to Other Sites
Personal Data Complaints
If you wish to lodge a complaint about how we process your personal information, please contact us at email@example.com. We will endeavor to respond to your complaint as soon as possible. If you are based in certain jurisdictions, you may also lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place. For example, if you are based in the UK, you may choose to lodge a complaint with the Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/.
You can reach us by email at firstname.lastname@example.org or at the following mailing address:
520 Madison Avenue, 26th Floor, New York, NY 10022