In accordance with this Policy, CdR Capital may collect, use and process your personal data (including your sensitive personal data), together with other information, for the uses set out below. For the purposes of this policy “processing”, “transferring” “personal data” and “sensitive personal data” shall be interpreted in accordance with the laws of Switzerland.
Collection of information
Information may be collected from you in the course of your use of a CdR Capital website and/or in any communication between you and CdR Capital personnel. If you are a CdR Capital client, prospective client or a fund manager we may also collect information about you from company and trade registers, and other publicly available sources.
Sensitive personal data
To the extent that we have a business need to collect your sensitive personal data for the purposes set out above, and are permitted to do so by local laws, we may collect and use your sensitive personal data. If we do so, and are required by local laws, we will contact you to obtain your consent for this collection and use in advance.
Uses of personal data
CdR Capital may use your personal data for any of the following purposes:
- In the course of carrying out client due diligence and achieving a sufficient knowledge and understanding of a prospect or client and its business, management and employees.
- In the course of carrying out fund manager due diligence and achieving a sufficient knowledge and understanding of a fund manager and its business, management and employees.
- To provide investment advisory, due diligence and risk advisory services to its clients.
- To prevent fraud.
- In order to ensure the legitimacy of all requests for further information from CdR Capital Ltd.
- To check the identity of prospects and new clients and to prevent money laundering.
- To disclose it to its service providers, professional advisers and agents, where necessary.
- If you have registered for this purpose, to review whether you are a suitable candidate for any job opportunities within CdR Capital.
- Occasionally, to trace debtors.
- To record and monitor for internal CdR Capital purposes your use of CdR Capital websites. For internal administrative or training purposes.
- For responding to subpoenas, court orders or regulatory or legal requirements.
- For the marketing of CdR Capital’s investment advisory services. See more details below.
CdR Capital may contact you by mail, telephone, fax, e-mail or other electronic messaging service with offers of CdR Capital’s services, materials, news or training that may be of interest to you. CdR Capital will never pass your contact details on to a third party.
CdR Capital operates as a global business and may have a business need to transfer your personal data to countries outside the European Economic Area (EEA) which do not provide the same level of data protection as the EEA. This includes transfers the object of which is (i) to enable information to be accessed by CdR Capital personnel located outside the EEA who need to know the information in order to do their jobs; and/or (ii) to enable information to be accessed by CdR Capital clients located outside the EEA. By continuing to access this site, you hereby consent to us transferring data to other jurisdictions outside the EEA, with the proviso that, where necessary to do so under local laws, we will obtain your prior consent.
How We protect your Personal Information
People. We educate our employees to treat personal information and personal data with care. They are required to limit their access to information that they need to perform their jobs, such as to conduct our business, operate our websites, service your account or help you pursue your financial objectives. All our employees are required by contract and CdR Capital’s policies to keep all personal information secret, confidential and secure, and must take particular care not to disclose it to any other person (whether inside or outside CdR Capital) unless there is a legitimate CdR Capital business need and they are authorised to do so.
Procedures. In compliance with applicable laws and regulations, we maintain physical, electronic and procedural safeguards to protect your personal information
Security. We take such security measures as we deem appropriate and proportionate to keep all information (including personal data) confidential and secure against unlawful processing and to prevent loss, destruction or damage.
Amendments and queries
Under local laws, you may be entitled to ask for a copy of your personal data (for which we may charge a small fee) and to correct any inaccuracies.
For the personal data held by CdR Capital Ltd, you may request details which we hold about you under the Data Protection Act 1998. If you would like a copy of the information held on you please write to firstname.lastname@example.org or by post to CdR Capital Ltd, 11 Charles II Street, London SW1Y 4QU, United Kingdom. If you believe that any information CdR Capital Ltd is holding on you is incorrect or incomplete, please email us as soon as possible at the above address. CdR UK will promptly correct any information found to be incorrect.
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