- THE PRODUCTS AND SERVICES WE PROVIDE
- THE TYPES OF PERSONAL DATA WE COLLECT
- HOW WE USE YOUR INFORMATION
- DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
- INTERNATIONAL TRANSFERS OF PERSONAL DATA
- HOW WE SAFEGUARD YOUR INFORMATION
- HOW LONG WE KEEP YOUR PERSONAL DATA
- YOUR RIGHTS
- QUESTIONS AND CONCERNS
1.1 Chenavari Financial Group Ltd and Chenavari Credit Partners LLP with their registered offices at 80 Victoria Street, London SW1E 5JL and other companies in the Chenavari group (“Chenavari Investment Managers”) collect and use certain Personal Data. Chenavari Investment Managers is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.
“Chenavari Investment Managers”, “we or “us” means Chenavari Financial Group Ltd, Chenavari Credit Partners LLP and other companies in the Chenavari Investment Managers group.
“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Chenavari Investment Managers (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Chenavari Investment Managers or any other person in respect of an individual.
2. THE PRODUCTS AND SERVICES WE PROVIDE
(A) Information we receive through our websites (“Chenavari Investment Managers Websites”);
(B) Information we receive through our products (“Chenavari Investment Managers Products”);
(C) Information we receive through our support, mobile security solution or cloud-based services (“Chenavari Investment Managers Services”).
3. THE TYPES OF PERSONAL DATA WE COLLECT
3.1 Many of the services offered by Chenavari Investment Managers require us to obtain Personal Data about you in order to perform the services we have been engaged to provide. In relation to each of the services described at paragraph 2.1 above, we will collect and process the following Personal Data about you:
• Information that you provide to Chenavari Investment Managers. This includes information about you that you provide to us. The nature of the services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):
– basic Personal Data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country);
– any information that you choose to share on Chenavari Investment Managers internet forums which may be considered Personal Data. (Please note that Chenavari Investment Managers does not collate information included on Chenavari Investment Managers internet forums together with Personal Data from your User Center account or profile);
• Information that we collect or generate about you. This includes (by way of non-exhaustive list):
– a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you;
– through our cloud security services, traffic and security reports that include information on the internet usage of the organisation’s computer users (e.g. what websites were visited by each user, any documents downloaded, security incidents, prevention measures taken by the gateway, etc.); and
– activity data relating to the use of protected documents, such as altering a document’s permissions and information regarding the individual that performed the activity.
• Information we obtain from other sources.
– When you visit Chenavari Investment Managers Websites, cookies are used to collect technical information about the services that you use, and how you use them.
• Anonymized data
– In addition to the categories of Personal Data described above, Chenavari Investment Managers will also process further anonymized information and data that is not processed by reference to a specific individual.
4. HOW WE USE YOUR INFORMATION
4.1 Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
• for ongoing review and improvement of the information provided on Chenavari Investment Managers Websites to ensure they are user friendly and to prevent any potential disruptions or cyber attacks;
• to allow you to use and access the functionality provided by the Chenavari Investment Managers Products;
• to assess your application for Chenavari Investment Managers Products, where applicable;
• to set up customers to use Chenavari Investment Managers Products;
• to set up users to use the User Center;
• to conduct analysis required to detect malicious data and understand how this may affect your IT system;
• for statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
• to understand feedback on Chenavari Investment Managers Products and to help provide more information on the use of those products and services quickly and easily;
• to communicate with you in order to provide you with services or information about Chenavari Investment Managers and Chenavari Investment Managers Products;
• for in-depth threat analysis;
• to understand your needs and interests;
• for the management and administration of our business;
• in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
• for the administration and maintenance of databases storing Personal Data.
4.2 However we use Personal Data we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons. These include:
• we need to do so in order to perform its contractual obligations with its customers;
• we have obtained your consent;
• we have legal and regulatory obligations that we have to discharge;
• we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
• the use of your Personal Data as described is necessary for our legitimate business interests, such as:
– allowing us to effectively and efficiently manage and administer the operation of our business;
– maintaining compliance with internal policies and procedures;
– monitoring the use of our copyrighted materials;
– enabling quick and easy access to information on Chenavari Investment Managers Products;
– offering optimal, up-to-date security solutions for mobile devices and IT systems; and
– obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market.
5. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
5.1 We may share your Personal Data within the Chenavari Investment Managers group of companies for the purposes described above:
5.2 We may also share your Personal Data outside of the Chenavari Investment Managers group for the following purposes:
• with our business partners. For example, this could include our partners from whom you or your company or your organisation purchased the Chenavari Investment Managers product(s). Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
• to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;
• if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
• if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer.
6. INTERNATIONAL TRANSFERS OF PERSONAL DATA
6.1 Chenavari Investment Managers is a global business. Our customers and our operations are spread around the world. As a result we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your country.
6.2 Where we transfer your Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways:
• the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data (Israel is an approved country);
• the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
• where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
• in other circumstances the law may permit us to otherwise transfer your Personal Data outside Europe.
6.3 You can obtain more details of the protection given to your Personal Data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described in paragraph 11 below.
7. HOW WE SAFEGUARD YOUR INFORMATION
7.1 We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.
7.2 As a condition of employment, Chenavari Investment Managers employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by a Chenavari Investment Managers employee is prohibited and may result in disciplinary measures.
7.3 When you contact a Chenavari Investment Managers employee about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.
8. HOW LONG WE KEEP YOUR PERSONAL DATA
8.1 How long we will hold your Personal Data for will vary and will be determined by the following criteria:
• the purpose for which we are using it – Chenavari Investment Managers will need to keep the data for as long as is necessary for that purpose; and
• legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
9. YOUR RIGHTS
9.1 In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
• the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
• in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Chenavari Investment Managers;
• the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
• the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
• the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
• the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
9.2 You can exercise your rights by contacting us using the details listed in paragraph 11 below.
10. QUESTIONS AND CONCERNS
10.1 If you have any questions or concerns about Chenavari Investment Managers’ handling of your Personal Data, or about this Policy, please contact us using the following contact information:
Address: 80 Victoria Street, London SW1E 5JL
Email Address: firstname.lastname@example.org
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from us, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, Chenavari Investment Managers will provide you with the contact information for that regulator.