It is important that you read this Policy together with any other policies we provide when we are collecting or processing your personal data to ensure you understand how and why we use your information. By obtaining services from us and/or voluntarily providing personal data to us, you acknowledge that you have read and understand this Policy.
As used in this Policy, the term “Company” shall include the following entities:
The Company reserves the sole discretion to change this policy by updating this page. You should review this page periodically to ensure that you are comfortable with any changes.
The information we collect varies depending on your activity and use of the services or products offered by the Company. This Policy describes our practices with respect to personal data we receive in relation to our provision of services, including compliance administration services (“Services”) and applies to you if you are a client of the Company or an employee, access person, or investor of a client or otherwise use the Services directly or indirectly (collectively, “Clients and Related Parties”). Our company websites may have separate policies, which you can find on the applicable website.
Categories of Personal Information
We collect the following categories of personal information from Clients and Related Parties:
When you provide the information above, it is received by the Company and / or applicable entity to which you send such information and may also be received by such entity’s affiliated entities (“Affiliates”) and their employees. Further, your personal information may be provided to regulatory authorities pursuant to a legal or regulatory request, including but not limited to a subpoena or SEC request. Additionally, in providing Services, the Company may provide your name and contact information as part of a regulatory filing. See “Information Sharing and Disclosure” below for additional information.
When asked to provide information, you may decline to do so. However, if you choose not to provide information that is necessary for us to collect by law or to perform a contractual duty, we may not be able to enter into or perform such contract or perform other obligations with respect to you and / or your employer or an entity for which you are an access person. If you provide us with information about another person, you must ensure that you have the right to provide that information and that they understand how we will use their information.
Data Retention and Protection
Your personal data is generally stored until we receive a request to remove it or as otherwise required by internal policies and procedures, applicable law and / or contractual terms. Data we collect is generally stored in the United States and is subject to our Network Security Policy, except when data is submitted to Company outside of the United States or sent through a third-party platform, in which case its storage will be governed by such third-party platform’s terms. If data is submitted to Company outside of the United States, then the data storage and processing may vary depending on the sender’s location and method of submission. The Company uses reasonable physical and technical measures to prevent unauthorized access or loss, and / or unlawful processing. Usage of this Website is not permitted outside of the United States.
We do not use your personal data for automated decision-making or profiling, which have a legal or similarly significant effect on users.
Purpose for Processing
We use personal data of Clients and Related Parties for the following purposes:
Any information provided to us by you and / or your employer and / or an entity for which you are an access person will only be used for the purposes for which it was provided and any reasonably related purposes including providing you with the information that you request from us. We may also use your contact information to communicate regulatory updates. However, in the event you wish to stop receiving such communication, you may opt out by selecting an “unsubscribe” or by contacting our legal department at email@example.com.
Legal Bases for Processing
We process data for one or more of the following legal bases:
Your personal information may be shared with:
This Policy does not create rights enforceable by third parties.
The Company reserves the sole discretion to change this policy by updating this page. We will use reasonable efforts to notify you of any material changes to this policy, such as by sending you the revised policy by email or posting a notice on our website. This policy is effective from November 7, 2023.
Please report any system issues and / or incidents promptly upon identification to firstname.lastname@example.org.