November 30, 2020
TYPES OF INFORMATION WE COLLECT
- Contact details, such as your full name, e-mail address, postal address and telephone number
- Educational, nationality and professional background information
- Usernames and passwords
- Payment information
- Comments, feedback, posts and other content submitted to staff
- Interests and communication preferences including marketing permissions where appropriate.
RESTRICTED USE REGARDING MINORS
This Site is not intended or designed to be used by children under the age of 13. We do not collect PII from any person we know to be under the age of 13 and instruct children under 13 not to send us any information.
PURPOSES FOR COLLECTING YOUR PII
- Contacting you or your designated representative by phone, email, fax, or mail
- Providing you or your representative with marketing communications
- Creating and managing your account with us
- Sharing information about our Services including investment research
- Facilitating financial transactions related to your account
- Fulfilling our legal and regulatory obligations
- The performance of obligations under any applicable agreements
- The administrative processes (and related communication) carried out between GHP in preparing its services
- Ongoing communication with you and/or your designated contacts
- The ongoing administrative, reporting and other processes and communication required to operate the business in accordance with the agreements and other applicable documentation between the parties
- To collect information for our recruiting process
- Any legal or regulatory requirement
- Any other purpose that has been notified, or has been agreed, in writing
DATA STORAGE AND RETENTION
Your PII will be retained only for as long as the information is needed to fulfill the purposes for which it was collected and processed. We reserve the right to retain and use your PII for as long as necessary to comply with our legal obligations and business requirements and/or to resolve ongoing disputes and enforce our agreements.
PROTECTION OF PERSONALLY IDENTIFIABLE INFORMATION
We maintain physical, electronic, and procedural security measures that comply with applicable legal and regulatory standards to safeguard your PII. Access to such information is restricted to those employees who are trained in the proper handling of client information and have a legitimate business need to access that information. We follow generally accepted standards to protect the PII you submit to us, whether that information is in transit or at rest. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
We use various technologies to collect other types of information, including PII, automatically. For example, in order to measure the usefulness and efficiency of our Sites, we automatically track certain information from all visitors to our Sites. The types of information we might track may include the Internet address that you just came from, which Internet address you go to, what browser you are using, your IP address, your internet service provider, date and timestamp information, or clickstream information.
For information on how to remove or manage cookie functions and adjust your privacy and security preferences, access the “help” menu on your internet browser, or visit http://www.aboutcookies.org/how-to-control-cookies.
We also use analytics providers, such as Google Analytics to help us evaluate the Sites. To opt out of the aggregation and analysis of data collected about you on the Sites by Google Analytics, visit https://tools.google.com/gaoptout and download and install the Google Analytics Opt-out Browser Add-on.
AUTOMATED DECISION MAKING
We do not use automated processing, including profiling, to make decisions that will have either legal or material effects on the individuals from whom we collect and process PII.
SHARING YOUR PII
Your PII may be combined with information we receive from other sources, or it may be provided to other GHPs we work with. This section details that sharing of your PII.
Receiving PII from Third Parties
We may receive information about you from other sources and combine that information with the PII we collect directly from you. For example, we may receive payment information from the GHP you use to pay us in order to correct our records. Additionally, to promote protection of your identity, we also may collect credit or identity information which we use to help prevent and detect fraud.
Sharing PII with Third Parties
We do not and will not sell your PII. If we share your PII with third parties performing services for us, or acting on our behalf, we will not allow them to use your information for other purposes, and we will contractually require them to protect your information.
We may share your PII with our affiliates, business partners, and other third parties. We may do so for the purposes of operating our business, delivering and improving the Services we provide to you, as well as for other legitimate purposes permitted by applicable law such as sending marketing and other communications related to our business.
We may share your PII with third parties for a variety of additional purposes including, but not limited to:
- Within GHP and our affiliates and subsidiaries for data processing or storage purposes
- With business partners and suppliers to provide Services and help facilitate transactions (including processing orders, event registrations, data storage, marketing communications and customer support)
- In response to a request from law enforcement, government authorities, or other third parties as necessary to comply with legal process or to meet national security requirements
TRANSFERS OF PII
Your PII may be transferred, processed and/or stored in a country other than the one in which your PII is collected. When transferring your PII to the US or other countries, we have implemented procedures to ensure that appropriate safeguards are in place to protect the PII regardless of where it is being transferred to.
GHP may disclose PII, where permitted by law, to other service providers, prospective or current investors in applicable funds, employees, agents, contractors, consultants, professional advisers, lenders, data processors and persons employed and/or retained by them in order to fulfill the purposes described in this Privacy Notice. In addition, GHP may share PII with regulatory bodies having competent jurisdiction over them, as well as with tax authorities, auditors and tax advisors (where necessary or required by law, rule or regulation).
GHP may transfer PII to a non-equivalent country (a country or territory other than (i) a member state of the EEA; or (ii) a country or territory which has at the relevant time been decided by the European Commission in accordance with EU law to ensure an adequate level of protection for PII), in order to fulfill the purposes described in this Privacy Notice and in accordance with applicable law, rule or regulation, including where such transfer is a matter of contractual necessity to enter into, perform and administer agreements, and to implement requested pre-contractual measures. For information on the safeguards applied to such transfers, please contact firstname.lastname@example.org.
YOUR EU DATA SUBJECT RIGHTS
The European Union’s General Data Protection Regulation (“GDPR”) is a sweeping piece of legislation that grants EU residents increased control over their PII. The GDPR allows consumers to access their PII and find out details of how that data is processed, to rectify inaccurate PII, to have their data erased (when certain conditions are met), to restrict processing of their data, and more. It requires affected companies to create processes to comply with and facilitate consumer data requests, to update their privacy policies, and to ensure that PII is secured.
Specifically, the GDPR and other national privacy laws provide data subjects with certain rights regarding their PII. If you are an individual who resides in the EU and whose PII is collected and processed by GHP, you have the right to:
- Request access to your data
- Rectify your data
- Take your data (in a readable, “portable” format) to another service provider
- Erase your PII
- Restrict or object to the processing of your PII
- Lodge a complaint with a Member State Supervisory Authority
- Withdraw previously given consent to collect and process PII (which will not impact PII processed before the withdrawal)
PII RIGHTS FOR CALIFORNIA RESIDENTS
The California Consumer Privacy Act (“CCPA”) requires us to make certain additional disclosures and provides California residents with the ability to request additional information about their PII. If you are a California resident and it is determined that the CCPA applies to you, this section details those rights, how you may exercise them, and what GHP will do in response.
Please note that the rights under the CCPA do not apply to PII collected, processed, sold or disclosed pursuant to Gramm-Leach-Bliley Act (Public Law 106-102) and Fair Credit Reporting Act (12 CFR 1022).
If you are an individual who resides in California and whose PII is collected and processed by GHP, you may have the right to:
- Request that we disclose, free of charge, the categories and specifics of the PII we collect about California residents, the sources from which the PII was collected (and/or, if applicable, sell or otherwise disclose to a third party), and the business purpose for collecting PII
- Choose to opt-out of the sale of PII. Currently, however, GHP does not sell PII
- Request that we delete the PII we have collected. Following our verification of the request, we will comply with the request and delete any or all the PII in our possession that we collected from the California resident and/or any or all such PII in the possession of our service providers, unless otherwise restricted by law or regulation.
Non-Discrimination for Exercising Your PII Rights
QUESTIONS OR CONCERNS AND EXERCISING YOUR DATA SUBJECT RIGHTS
Verifying Your Identity
If you choose to contact us with a request, you will need to provide us with identifying information that matches the PII we currently have about you.
You have the right to appoint an authorized agent to exercise your rights on your behalf. If you would like to do so, please contact email@example.com.
For consumers with disabilities who need to access this policy in an alternative format, please contact: firstname.lastname@example.org.
CHANGES TO THIS PRIVACY NOTICE
From time to time we may update this privacy notice. If revisions are made to the privacy notice, we will update the statement with a new revision date.
This privacy notice was last revised and posted on November 30, 2020