Privacy and personal information are very important to EQUIAM, and we take it seriously.
We collect Personal Information from and about you to:
We collect information by asking you to enter information (including Personal Information) into forms, by observing your account activity and usage of the Services, by logging your access and activity on the Site, by your uploading of documents, and via third party information providers that, among other things, provide background checks to verify your identity, creditworthiness, and your eligibility and suitability to participate in transactions. Third party information providers include, among others: credit reporting agencies, social media sites, our affiliated entities, fund administration partners, advertising platforms, data brokers and other data sources, and compliance service providers.
If you register or use the Services through a third-party site or application such as Facebook or LinkedIn, or link your EQUIAM account to those sites and applications, we may collect Personal Information from them. We may also collect Personal Information by direct communication with you and others by telephone, in person, and by online or electronic messaging means both on-Site and through off-Site services.
We generally do not collect Personal Information about your race, ethnicity, religious or philosophical beliefs, sexual orientation, health information, trade union memberships, etc., and will not do so without asking for your further, explicit consent.
Like any company, we may share Personal Information that we have collected with our affiliates and third parties (whether located within or outside your jurisdiction) for the purposes described above. This includes:
Although we sometimes refer to affiliates as “we” or part of the Services, please be aware that some of these entities are not under common ownership with, or controlled by, EQUIAM.
Under certain circumstances, you have the right to do the following:
California’s “Shine the Light” law (Civil Code Section 1798.83) permits users of the Site and Services that are California residents to request certain information regarding our disclosure of Personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or mail your written request to John Zic, Partner, at 1700 Montgomery Street, Suite 108, San Francisco, CA 94111, USA.
Effective from January 1, 2020, the California Consumer Privacy Act of 2018 (the “CCPA”) grants California residents certain rights with respect to Personal Information collected by businesses. If you are a California resident, you may exercise the following rights, subject to certain exceptions and limitations:
California residents who wish to exercise any of their CCPA rights should complete and submit the required verifying information via email at email@example.com. We may need to request additional information from you to verify your identity or understand the scope of your request. You may designate an authorized agent to make a request on your behalf by providing us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
Requests are processed within 45 days of receipt. If we are unable to verify your identity, request processing may be extended by an additional 45 days. You may make a free request two times in any 12-month period.
When you access the Site or Services, we and certain information providers may place cookies, pixel tags, web beacons, page tags, or other data-gathering and transmitting tools or files on your device. These help us recognize you as a user, customize and personalize the Services, study and improve our offerings, collect information about your device and software in order to improve Site performance or prevent fraud. Most Internet browsers and our consent management tool are able to disable or remove these cookies, and will contain instructions on how to do so, but doing so could affect your ability to use the Site and Services. We use the following cookies:
Some web browsers provide a Do Not Track feature that sends signals to the websites you visit to indicate that you do not want your online activities tracked. There is currently no industry agreed-upon response to a Do Not Track signal. At this time, we do not support the Do Not Track browser option.
We may retain or delete your Personal Information according to our internal data retention policies as permitted by applicable laws and regulations, even after you no longer use the Site and Services or terminate or deactivate your account or your relationship with EQUIAM, among other things for backup, archival, contract enforcement and dispute resolution, auditing, and regulatory compliance purposes. Note, also, that securities law and regulations, among other things, may require that we keep an archival / recordkeeping copy of some or all of your Personal Information, that we provide such information to regulatory authorities, and that removing, deleting, erasing, suspending processing of, or withdrawing consent with respect to your Personal Information may result in our no longer being able to provide you the Services.
The Site and Services are directed at and intended solely for adults according to the age of majority and other laws of their jurisdiction. We do not knowingly collect any information from anyone under the age of 18 or allow them to use the Site or Services. If you learn that we may have inadvertently collected any such information, please contact us immediately for a resolution.
EQUIAM is committed to maintaining the confidentiality, accuracy, and security of the EQUIAM community’s Personal Information, to honor our clients’ integrity, respect the trust the EQUIAM community places in us, and for purposes of compliance.
We protect Personal Information by using software, physical safeguards, and internal procedures, in compliance with applicable laws and regulations. This includes using secure servers, encryption, and locked facilities as applicable. We maintain access policies designed to limit access to Personal Information to those who need to know as part of the Services, and education and training for employees on the importance of confidentiality. We have a policy of requiring companies that work with us to protect Personal Information as well.
We ask you to help by taking reasonable precautions to protect your own files, use secure passwords, and generally exercise due care with any sensitive information about yourself or other people.
No security system is completely without risk. If there is a security or data breach affecting your Personal Information, we will attempt to investigate and as appropriate, notify you and take other applicable legal steps. Further, if you become aware that any Personal Information we have appears to be inaccurate, and you are unable to correct it yourself from your user account, you may contact us as described below. You may also contact us anytime if you have questions regarding your Personal Information, the Services, or any other matter.
You may contact John Zic, Partner, at 1700 Montgomery Street, Suite 108, San Francisco, CA 94111 USA, or firstname.lastname@example.org.
Individuals in the European Economic Area who wish to exercise any of their GDPR rights should complete and submit the required verifying information via email at email@example.com.