Purpose and Scope
- or any software application made available by SIS for use on a computer, tablet, mobile phone or other mobile device
(together, the “Digital Services”)
collects and processes personal information about you, how this information is protected, and your rights in relation to it.
1. Changes to Privacy Statement
2. Collection of Information
Personal information We Collect Directly from You
We collect personal information from you when you use the Digital Services. The type of information that we collect from you depends on your particular interaction with the Digital Services. We require you to register with the Digital Services to access certain features. When we do, we may collect the following information from you during the registration process: your (i) name, (ii) country of residence, (iii) address, (iv) phone number, (v) job title, (vi) company, (vii) investor type, (viii) email address, (ix) your marketing and communications preferences and (x) password that you select.
If you choose to purchase a product or service through the Digital Services, we may collect your credit card information. If we process credit transactions, we may use a third party service provider to process credit card transactions on our behalf. The third party will collect from you your contact information (such as your name, address, and e-mail) and financial information (such as credit card number and expiration date).
Personal information We Collect Automatically
Personal Information We Collect From Third Parties
We also collect information about you from third party sources such as: suppliers that help us prevent money laundering and fraud; marketing agencies; identity verification services; and analytics providers.
The categories of information that we collect about you from other sources are:
- where permissible under applicable law, personal details (e.g., name, date of birth);
- contact details (e.g., phone number, email address, postal address or mobile number); and
- employer name.
Please note that we may be required by law to collect and use certain personal information about you. And we may need to collect and use personal information to enter into or fulfill a contract with you. Failure to provide this information may prevent or delay the fulfillment of our obligations in these circumstances.
3. Use of Your Information
We primarily use your personal information to provide our services to you and to respond to your inquiries. We also may use your personal information as follows:
- To communicate with you, including to respond to your comments or requests for information, to request feedback on our products and services, and to notify you about changes to your subscriptions or to the services and products you use.
- To help us understand our customers, to tailor and enhance our product and service offerings, anticipate and resolve problems with any products or services supplied to you, create products or services that may meet your needs.
- To provide access to restricted pages or contents of the Digital Services.
- To comply with legal and/or regulatory requirements and cooperate with regulators and law enforcement bodies.
- To facilitate your activity and to identify you when you log into your account on our Digital Services.
- To send you marketing communications and advertising in line with your communications preferences and where permitted by applicable law about products and services that we believe would be of interest to you, including products and services offered by third parties.
- To evaluate the success of our advertising campaigns, to improve our products and services, to assess patterns of use, and to plan and evaluate our marketing and business development programs.
- To protect our rights, your rights, and the rights of others, and to meet our own high standards of business practice.
Information For EU Users
Some of the processing we conduct will involve making decisions about you based on automated processing of your personal information. For example, we may conduct profiling activities to select personalized offers or recommendations for you based on your use of the Digital Services. If you are in the EU, where these decisions are based solely on our automated processing of your personal data (e.g., not subject to human review), these types of decisions will not have legal or similar effects on you, but you can still contact us for further information and to object to this use of your personal information.
Under EU privacy law, we must have a legal basis to process personal information. In most cases the legal bases for our processing, under EU law, will be one of the following:
- to fulfill our contractual obligations to you, for example to provide the Digital Services or to ensure that invoices are paid correctly;
- to comply with our legal and/or regulatory obligations, for example obtaining proof of your identity to enable us to meet our anti-money laundering obligations; and/or
- to meet our legitimate interests, for example to: understand how you use the Digital Services and to enable us to use this knowledge to improve our products and services and to develop new ones; to communicate with you about the products and services that you use or we offer; maintain our accounts and records; to assess patterns of use; and to plan and evaluate our marketing and business development programs. When we process personal information to meet our legitimate interests, we put in place, when needed, safeguards designed to protect your privacy interests, freedoms, and rights under applicable laws.
We may anonymize your personal information and use it for other purposes. For example, we may prepare aggregated reports about how users interact with the Digital Services for research.
4. Cookies and Other Tracking Technologies
5. Disclosures and Onward Transfers
We share your personal information with the following persons/entities and in the following circumstances:
Additional Sharing: From time to time we share your information with our attorneys, banks, auditors, securities brokers and other professional service providers and advisors in connection with the purposes described above.
Because we operate as a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the Digital Services). See the section on “International Transfers of Personal Information” below for more information.
6. Your Choices
If you wish to stop receiving marketing information concerning our services or products, or if you wish to withdraw any consents that you have provided, please contact us by email at firstname.lastname@example.org to notify us of your wishes.
7. International Transfers of Personal Information
We may transfer, process, and store your personal information outside of your home country, including in the United States and Canada, which may not have the same level of data protection as your home country. For the avoidance of doubt, if you are resident in the European Economic Area (“EEA“) this may include the transfer of your personal information from within the EEA to a country outside of the EEA.
8. Your Rights in relation to Your Personal Information
Subject to local law, you may have certain rights regarding your personal information. These may include, depending on the circumstances, the following rights to: access your personal information; rectify the personal information we hold about you; erase your personal information; restrict our use of your personal information; object to our use of your personal information; receive your personal information in a usable electronic format and transmit it to a third party (also known as the right of data portability); lodge a complaint with your local data protection authority; and withdraw any consent you have given to uses of your personal information. If you would like to discuss or exercise the rights you may have, feel free to contact us via email at email@example.com.
If you are a registered user of the Digital Services, you may access your personal account information online and make changes by logging into your account.
9. Security and Data Integrity
We have put in place certain safeguards to help prevent unauthorized access and maintain data security with respect to your personal information. Despite these protections, however, we cannot guarantee that your data will be 100% secure. You should take measures to protect your personal information.
We retain your personal information for as long as we have a relationship with you and for a period after the relationship has ended. When determining how long to keep your personal information after our relationship with you has ended, we take into account how long we need to retain the information to fulfil the purposes described above and to comply with our legal obligations, including regulatory obligations. We may also retain personal information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.
10. Your Security Obligations
Your online access to certain of your personal information may be protected with a password you select. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). You have an obligation to keep your user ID, password and personal information secure. As part of maintaining this obligation we recommend that you do the following:
- Keep your user ID and password confidential;
- Utilize a unique password and change it frequently;
- Make sure others are not watching you enter your user ID and/or password on your keyboard when using protected elements of the Digital Services; and
- Do not leave your computer unattended while logged onto protected elements of the Digital Services. After you finished accessing your information, exit the protected area.
12. Other Sites
14. Your California Privacy Rights
Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2008 will receive information regarding 2007 sharing activities).
To obtain this information, please send an email message to firstname.lastname@example.org with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response.
Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.