How we collect Information about you through the Site
We may collect Information about you through:
- Information provided directly to us by you, or another person on your behalf, through the Site via the ‘Contact Us’ feature; or
- the use of Internet “cookies” (an information collecting device from a web server), as described further below.
Why do we collect Information?
We may collect and use your Information for the purposes of evaluating typical usage of the Site, monitoring and analyzing user activities, and complying with applicable legal or regulatory requirements.
We will use one of the permitted grounds under the applicable law to process your Information. Such grounds include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a legal obligation, or where we, or a third party, determine that it is necessary for our legitimate interests to collect and use your Information.
The legitimate interests to collect your Information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your Information for such purpose.
Do we share your Information with third parties?
We may (to the extent relevant to the purpose for which we collect your information), share your personal data with third parties, such as:
- our affiliates or other entities that are part of our group or with our clients;
- any person to whom we have a right or obligation to disclose your Information, or where we determine that disclosure is necessary to protect or defend our rights or property, including with regulators, courts of law, governmental, regulatory or law enforcement agencies;
- our internet, IT, telecommunications and other service providers, including legal advisers, accountants, payroll administrators, insurance and employee benefits providers and administrators;
- service providers and trading counterparties to our clients, including placement agents or distributors, brokers, banks, trading venues, clearing houses, custodians, corporate services providers, administrators of our funds, and providers of customer relationship management tools;
- any person, as directed by you; or
- any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.
General Data Protection Regulation (2016/679)
Your Information generally will be processed in the United States and other countries outside the European Economic Area (“non-EEA Countries”), that may not offer the same level of data protection as that afforded by the EU General Data Protection Regulation (2016/679) (“GDPR”). We will process Information (or procure that it be processed) in non-EEA Countries in accordance with the requirements of applicable law, which may include having appropriate contractual undertakings in legal agreements with service providers who process Information on our behalf in such non-EEA Countries or in countries subject to the GDPR.
For how long do we keep your Information?
We will generally keep Information about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period if required under applicable law or necessary for the purposes of our other legitimate interests.
The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your Information from our systems. As a minimum, Information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of five years after the termination of any such relationship.
We will, from time to time, review the purpose for which we have collected Information about you and decide whether to retain it, update it, or securely delete it, if the Information is no longer required.
What are your rights?
If you are an individual located in the European Economic Area, you have certain rights under the GDPR in respect of the Information we hold about you and which you may exercise. These rights are:
- to request access to your Information;
- to request rectification of inaccurate or incomplete Information;
- to request erasure of your Information (a “right to be forgotten”);
- to restrict the processing of your Information in certain circumstances;
- to object to our use of your Information, such as where we have considered such use to be necessary for our legitimate interests (e.g. in the case of direct marketing activities);
- where relevant, to request the portability of your Information;
- where you have given consent to the processing of your Information, to withdraw your consent; and
- to lodge a complaint with the competent supervisory authority.
We may send text files (e.g., “cookies” or other cached files) or images to your web browser to store information on your computer. Such text files and images are used for technical convenience to store information on your computer. For instance, we may use a session cookie to store form information that you have entered so that you do not have to enter such information again. We may use information stored in such text files and images to customize your experience on this website and to monitor use of this website. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts of this website. You can disable cookies from your computer system by following the instructions on your browser.
How to Contact us