1. What information is covered by this Privacy Notice?
This Privacy Notice governs the processing of personal data that you provide to us, that we collect or receive from you or that we receive about you when you visit our website. Personal data is any information relating to an identified or identifiable natural person.
2. What information do we collect from you?
We may collect information about you from the following sources:
• Information you provide via the website contact form
• Information gathered through the website cookies
• How you interact with the emails or website
2.1 Information we receive from you
We may collect personal data that you provide to us when you visit our website and/or engage with us to provide you with access to our website and its features. This includes your name, postal and email address, telephone number and other identification details. For example, you may provide us with personal data when you:
• Elect to subscribe to email newsletters
• Correspond with us via the links available on our website or by email
• Complete forms on our website
2.2 Information we collect about you
In addition to personal data you provide to us, we may receive information about you that you authorise third parties to provide to us, such as a third party acting on your behalf (e.g. a professional advisor) or from publically available sources or registers where necessary.
We also may obtain personal data from third-party service providers in order to verify your identity, to prevent fraud, or to help us identify products and services that may be of interest to you.
• Technical information, including your IP address, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times, and download errors;
• Information about your visit, including the websites you visit before and after our website and products you viewed or searched for;
• Length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers) and methods used to browse away from the page; and
• Similar information for additional content that can be accessed from website pages, such as opening or printing documents or which videos are played and for how long.
3. How do we use your personal data?
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Comply with legal or regulatory requirements and exercise or defend legal claims.
We may need to process personal data to comply with legal and regulatory requirements to which we are subject and/or to defend such claims or exercise our legal rights.
Legal Basis: Processing personal data in this way is necessary to ensure compliance with our legal and regulatory obligations. It is also necessary for our legitimate interests to process personal data for the purposes of exercising and defending such claims.
To provide you with information about our products and services.
We use your personal data (such as your email address or other contact details) to send you information about our services and other information which may be of interest to you, including events, surveys, updates and other relevant information.
Legal Basis: Where we are permitted to send you such messages under applicable law, our legal basis for processing your personal data is that it is necessary for our legitimate interests to promote our services and provide you with other information which may be of interest to you. We will not send such messages to you if you have opted out of receiving these (please see "What are your rights?" section below for further information).
For our records, administration and managing our relationship with you.
We will keep records of your personal data, such as your name, address, account details and marketing preferences, in order to administer our website and keep our records up to date.
Legal Basis: We use your personal data in this way as it is necessary for our legitimate interest to keep records of your personal details and update these when necessary. It is also in our legitimate interests to keep records of any correspondence with you. Our clients are important to us and so we need to keep track of your details and preferences.
The provision of your personal data is necessary when personal data is needed for the purposes of entering into or servicing a contract that you, or a company you are associated with, has with us or to receive the products or services or information you or your company request, or to comply with applicable law and regulations. Refusal to provide your information may make it impossible for us to provide the products, services or information requested or to fulfil our contractual obligations.
4. Do we use your personal data for direct marketing?
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5. With which third parties do we share your personal data?
Your personal data is intended for Platinum but may be shared with third parties in the following circumstances:
We may share your personal data among other offices, affiliates and locations within our firm to administer our website, send you information about products and services that may be of interest to you, and conduct the other activities described in this Privacy Notice.
Our service providers.
We use other companies, agents or contractors to perform services on our behalf or to assist us with the provision of our website, services and products to you. We may share your personal data with the following categories of service provider:
• Infrastructure and IT service providers (including for email archiving)
• Marketing, advertising, analysis, research and communications agencies
• External auditors and professional advisers (such as accounts, lawyers or other consultants)
We will only provide our service providers with personal data which is necessary for them to perform their services to us or assist us with the provision of our website, and we require them not to use your information for any other purpose. We will use reasonable commercial efforts to ensure that all our service providers keep your personal data secure.
Third parties permitted by law.
In certain circumstances, we may be required to disclose or share your personal data in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal data to the police, regulators, government agencies or to judicial or administrative authorities).
We may also disclose your personal data to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our contracts or protect your rights or those of the public.
Third parties connected with business transfers. We may transfer your personal data to third parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal data in a manner consistent with this Privacy Notice.
6. Do we transfer personal data outside the EEA?
Your personal data may be transferred to and processed by us, our affiliates and our service providers which may be located in countries outside the European Union and/or European Economic Area ("EEA"). In particular, if you are located in the EEA we will transfer the personal data we collect about you to the USA. We will take all steps that are reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Notice as well as applicable data protection laws, including, where relevant, by entering into EU standard contractual clauses (or equivalent measures) with the recipient outside the EEA.
7. What are your rights?
To the extent provided by the law of your jurisdiction, you may request access to the personal data we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal data, and we will apply your preferences going forward.
You can make a request to exercise any of these rights in relation to your personal data by
You also have the right to make a complaint at any time with your national data protection authority or other public authority governing the protection of your personal data.
7.1 EEA Residents.
If you are a resident in the EEA, you have the following rights in respect of your personal information (if applicable):
• Access. You have the right to request a copy of the personal data we are processing about you. For your own privacy and security, at our discretion we may require you to prove your identity before providing the requested information.
• Correction. You have the right to have incomplete or inaccurate personal data that we process about you corrected.
• Deletion. You have the right to request that we delete personal data that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal or regulatory obligation or to establish, exercise or defend such claims.
• Restriction. You have the right to restrict our processing of your personal data where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
• Portability. You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal data which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you.
• Objection. Where the legal justification for our processing of your personal data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
• Withdrawing Consent. If you have consented to our processing of your personal data, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from marketing messages that you receive from us.
California Residents. If you are a California resident and have an established business relationship with us, you may request a notice disclosing the categories of personal information we have shared with third parties, for the third parties’ direct marketing purposes, during the preceding calendar year. To make a request, please send us an email to the email address listed below. Indicate in your email that you are making a "Data Sharing" inquiry.
8. How do we protect your personal data?
We have implemented technical and organisational security measures to safeguard the personal data in our custody and control. Such measures include, for example, limiting access to personal data only to employees and authorised service providers who need to know such information for (a) the purposes described in this Privacy Notice; and (b) in order to perform their jobs, such as providing you with information you request, or notifying you of new products and services. We also maintain certain reasonable physical, electronic, and procedural safeguards to protect the personal information in our possession from loss, misuse, and unauthorised access, disclosure, alteration and destruction, and we review and adjust these safeguards regularly in response to advances in technology.
While we endeavour to protect our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.
9. How long do we keep your personal data?
We will only retain your personal data for as long as necessary for the purpose for which that data was collected and to the extent permitted by applicable law.
10. How do we respond to “Do Not Track” signals?
California Law requires that we disclose how we respond to Do Not Track (“DNT”) signals. Some browsers give individuals the ability to communicate that they wish not to be tracked while browsing the Internet. The DNT feature of these browsers sends a signal that inform operators of services online that they do not want certain information about their online activities collected over time and across websites or online services. Currently, we do not recognize or respond to DNT signals.
11. Links to other Websites
Please note our website may, from time to time, contain links to and from other websites, such as the website of companies in the Platinum portfolio. If you follow a link to any other websites from our website, please note that these websites have their own privacy policies and that we have no control over how they may use your personal data. You should check the privacy policies of third party websites before you submit any personal data to them.
12. How can you contact us?
If there are any questions or concerns regarding this Privacy Notice, please contact us by
13. Changes to this Privacy Notice
We reserve the right to change this Privacy Notice at any time and as permitted by law, you agree to be bound by such changes. We will notify you of material changes to this Privacy Notice by posting the updated Privacy Notice on our website or as otherwise required by law.
Last updated: August 22, 2019