Effective Date of Current Policy: May 24, 2018
Personal Information We May Collect About You
When you contact us using the Subscribe button on the website, any personal information submitted (e.g. your name, residential address, telephone number, company name or email address) will be collected and processed by us.
In addition, we may automatically collect basic technical information from all visitors to the website. We collect technical information during your visit to the website through our automatic data collection tools, which may include cookies and other commonly used technologies (e.g. web beacons). Please see the Section on Cookies below for further information.
We may also collect personal information from you via subscription documents or other related forms, through transactions you may have with us, or through sign-up sheets or business cards obtained at events we host or attend.
How We Use Your Personal Information
We maintain physical, electronic and procedural protections that comply with US federal standards to safeguard nonpublic personal information and which we believe are adequate to prevent unauthorized disclosure of such information. The provision of personal information by you may be necessary where we have a legitimate interest to carry out the following purposes: (i) to provide investment advisory services; (ii) to contact you and respond to your enquiry or provide you access to specific information or offers; (iii) to support our relationship with you; (iv) to understand how we can improve our products and services; (v) to personalize your visit to the website and to assist you while you use the website; (vi) to send marketing communications to you; (vii) to improve the website by helping us understand who uses the website; and (viii) to comply with applicable laws, regulations or codes of practice.
Please note that you have a right to object to the processing of your personal information where that processing is carried out for our legitimate interest or for direct marketing.
Sharing Your Personal Information
The servers used in the operation of the website automatically identify a computer by its IP address. If we, in good faith, determine that you have or are attempting to misuse or harm the website, we may investigate and cooperate with appropriate law enforcement agencies to protect our rights or property.
Similarly, we may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer your personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganization or otherwise.
E-Mail Communications and Marketing
Occasionally, we may send you e-mail communications with information that may be useful to you, including information about our products and services, its subsidiaries and other third parties with whom we have a commercial relationship. We will include instructions on how to unsubscribe and inform us of your preferences if you decide you do not want to receive any future marketing or promotional e-mails from us. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. If you wish to stop receiving marketing or market research communications from us, or would like to stop processing your personal information in any other way, you can contact us as described below to let us know what types of communications you wish to stop receiving. However, if you are a customer, supplier or otherwise have a commercial relationship with us, to ensure that you receive important information, you agree that we may send you non-marketing related information when necessary. We do not disclose, sell or otherwise market your personal information to third parties, unless we are required to do so by law.
For Residents of the European Economic Area (the “EEA”)
Given the global nature of our activities, where you are located in the EEA, personal information collected from you, including via the website, may be transferred to affiliated entities in countries located outside the EEA, including the U.S., which are not considered by the European Commission to provide an adequate level of data protection.
We have entered into EU standard contractual clauses (“Model Contracts”) for intra-group transfers of personal information. You can request a copy of these Model Contracts by submitting your request via email to: firstname.lastname@example.org.
Rights of European Residents
Individuals in Europe have certain data subject rights which may be subject to limitations and/or restrictions. These rights may include: (i) the right to request access to and rectification or erasure of their personal information; (ii) the right to obtain restriction of processing or to object to processing of their personal information; and (iii) the right to ask for a copy of your personal information to be provided to you, or to a third party, in a digital format. If you are based in the EEA and would like to exercise one of the abovementioned rights, please send us your request via email to: email@example.com. Individuals in the EEA also have the right to lodge a complaint about the processing of their personal information with their local data protection authority.
Links to Other Websites
We use various methods to ensure the protection of your personal information against accidental or unlawful destruction, loss or alteration and against unauthorized disclosure or access. While these methods are considered to be effective, we do not guarantee the protection of your personal information as no data transmission over the Internet can be guaranteed to be completely confidential or 100% secure. You use our website and provide all such personal information at your own risk. We retain personal information for as long as necessary to fulfil the purposes for which such personal information was collected or to comply with its legal obligations, resolve disputes or enforce agreements. The criteria used to determine the retention periods include: (i) how long the personal information is needed to provide the services and operate the business; (ii) the type of personal information collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).
Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.
When you visit the website, we may place a “cookie” or other online tracking device (e.g. web beacons) in order to improve your experience by recognising you when you visit the website, such as by assigning a session ID and to deliver content specific to your interests. The cookies we place may also collect information about your IP address, or click stream data within our website (i.e. the actions taken in connection with the website). This information helps us improve the functionality of the website.
Questions and Comments