PERSONAL DATA USAGE POLICY
Communication Information of Exante Data LLC and Exante Advisors LLC regarding the Usage of Personal Data
Exante Data LLC and Exante Advisors LLC (together “Exante” or the “Organization”) is obliged to protect the privacy of its friends, business and cooperation partners as well as other contact persons when processing their personal data. From May 2018 onwards, following the coming into force of the EU General Data Protection Regulation (“GDPR”), new measures for data protection within the European Union will be stipulated. Although Exante is regulated by the laws and practices of the United States of America, we take your privacy very serious and wish to comply with the highest standards.
The purpose of this email is to inform you about the processing of personal data by Exante. Exante feels obliged to do so according to the GDPR.
We continue to handle and safeguard your data as before. No measures are necessary at this time on your part should you not wish to remove yourself from our databases.
I. Responsibility and Contact Details
The responsibility for your personal data lies with:
Exante Data LLC and Exante Advisors LLC 79 Madison Avenue New York, NY, 10016, USA E-Mail: support [at] exantedata [dot] com
The contact details of the Data Protection Officer are:
Exante Data LLC and Exante Advisors LLC Data Protection Officer Dr. Wouter P.F. Schmit Jongbloed LL.M. 79 Madison Avenue, New York, NY, 10016, USA E-Mail: wouter.jongbloed [at] exantedata [dot] com
II. Usage of your Personal Data
The processing of your personal data takes place as long as it is necessary for the legitimate interests pursued by Exante Data LLC and Exante Advisors LLC (Art. 6 para. 1 lit. fGDPR) and it includes: – invitations to events organized or carried out by the Exante; – sending of business updates and/or other commercial communications; – conclusion or implementation of contracts and other business relations, in particular for the preparation of or replies to inquiries and the determination of the terms of the contractual relationships; – transfer of your personal data within Exante for internal administrative purposes (e.g. for the accounting purposes); – ensuring IT Security and IT Operations; – engagement of service providers, in particular internal and external IT service providers who support the business processes of Exante; – carrying out of compliance investigations; – ensuring the security of the building and premises (this also includes a video surveillance as far as it is necessary for the protection of our premises).
In addition, the processing of personal data takes place for the purpose of the performance of contracts with individuals (natural persons) and corporations with whom Exante has business relations.
Further, Exante is subject to compliance with various legal obligations which necessitates the processing of your personal data. These legal obligations may for example be based on laws and regulations relating to tax, international trade or sanctions.
III. Recipients of Your Personal Data
Within the Organisation, only authorised employees of Exante with the appropriate responsibilities have access to your personal data.
We are authorised to instruct third parties for the provision of particular services, for example IT services. Further, we engage legal advisors, management consultants and examiners etc. Such third parties provide their services to us under our supervision and in accordance to our instructions and may have access to personal data, provided it is necessary for the performance of their services.
In addition, we are entitled, as long as legally permitted for the purpose of complying with legal obligations or in the interest of the Organisation to transfer your personal data to authorities (e.g. social security institutions, tax authorities or law enforcement authorities) and courts of law within the country and abroad.
IV. Transfer of Data
For the purposes mentioned under Point II, your personal data can also be transferred to third parties and their service providers within and outside the European Economic Area (EEA).
It is probable that in countries outside the EEA, data protection regulations which are different from those in your country of residence are applicable. In such a case where your personal data is transferred to another country, we will take appropriate measures to secure the appropriate protection of your personal data in these countries.
You can find the current EU Standard Contractual Clauses at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010D0087&from=EN
V. Your Rights
Pursuant to European legal requirements, which application shall be examined in individual cases, you have the right to receive information regarding your personal data and request for the amendment or deletion of your personal data or the restriction on its processing as well as to raise objections to any form of processing of your personal data as stated under Point II and to receive your personal data in a structured, current and machine-readable format (transferability of data).
In addition, you have the right to submit a complaint to a supervisory authority.
VI. Confidentiality and Storage of Data
Every employee of Exante and all employees of external service providers who have access to personal data and/or who processes such data are obliged to treat the data confidentially. ALL DATA SHALL BE TREATED WITH STRICT CONFIDENCE AND STORED IN COMPLAINCE WITH THE VALID LEGAL REGULATIONS OF THE RELEVANT COUNTRY WHERE THE DATA IS STORED FOR THE APPLICABLE PERIOD OF TIME.
This document is only for the purpose of your information. You do not need to take any measures. Should you have any questions, comments or suggestions to this document or to our handling of data protection, please contact firstname.lastname@example.org or the Data Protection Officer.