This Policy covers the following areas:
- Information we collect about you
- How we use your personal information
- How we protect your personal information
- Contacting us & your rights to prevent marketing and to access and update your personal information
- How changes to this Policy will be made
Information we collect about you
We will collect and process all or some of the following personal information about you:
Information Voluntarily Provided by You:
In the course of using this Site, you may choose to provide us with information to help us serve your needs. For example, you may provide us your e-mail address to request information, or you may send us your mailing address so we may send you the material you have requested. You may also choose to apply for a job at the Company and submit a job application via our careers site. Any personal information you send us will be used only for the purpose indicated on the careers site or in this notice.
If you contact us, we will typically keep a record of that correspondence.
If we ask you to complete surveys that we use for research purposes, we shall collect the information provided in the completed survey.
Website and communication usage
Details of your visits to the website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources you access.
How we use your personal information
This section sets out the purposes for which we use personal information that we collect and, in compliance with our obligations under applicable data protection laws of the European Economic Area (“EEA”) and United Kingdom (“UK”), identify the “legal grounds” on which we rely to process the information.
EEA and UK Data Protection Laws allows companies to process personal information only when the processing is permitted by the specific “legal grounds” set out in the law.
Please note that in addition to the disclosures we have identified below, in some circumstances we will also disclose personal information to service providers, contractors, agents and affiliates of the Company that perform activities described in this notice on our behalf.
To communicate effectively with you and conduct our business
To conduct our business, including to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you and us, which in some circumstances may include sharing your data with third parties such as agents or contractors or with our advisors (e.g. legal, financial, business or other advisors) or with other companies in Wisterm’s corporate group (“Wisterm Affiliates”).
Use justification: contract performance and legitimate interests (to enable us to perform our obligations and provide our services to you)
To provide you with marketing material
To provide you with updates and offers, where you have chosen to receive these. We may use your personal information to provide you with information about products or services which we think would be of interest to you. We may also share your personal information with Wisterm Affiliates so that they can provide you with information about their products and services. These may be sent by email, SMS, phone, fax or post.
Within Wisterm, we operate under a number of brands and you may receive such communications from our different trading names, such as, Wisterm, RMC Brokers, and others.
We take care to ensure that our marketing activities comply with all applicable EEA and UK legal requirements. In some cases, this may mean that we ask for your consent in advance of us or Wisterm Affiliates sending you marketing materials.
In all cases, you can always opt out of receiving marketing communications from us or Wisterm Affiliates, at any time. We will always provide an option to unsubscribe or opt-out of further communication on any electronic marketing communications sent to you or you may opt out by contacting us as set out below.
Please note that, even if you opt out of receiving marketing messages, we may still send you communications in connection with the services we provide to you.
Use justification: consent and legitimate interest (to keep you updated with news in relation to our products and services)
For research and development purposes
To analyse your personal information together with information from other clients for data analytics purposes, including to create insights, reports and other analytics to better understand and improve the quality of and market Wisterm’s advice, products, and services. The output of such analytics does not identify particular clients or individuals.
Use justification: legitimate interests (to allow us to improve our services)
To monitor certain activities
To monitor queries and transactions to ensure service quality, compliance with procedures and to combat fraud.
Use justification: legal obligations, legal claims and legitimate interests (to ensure the quality and legality of our services)
To inform you of changes
To notify you about changes to our services and products.
Use justification: legitimate interests (to notify you about changes to our services)
To ensure website content is relevant
To ensure that content from our websites is presented in the most effective manner for you and for your device, which may include passing your data to Wisterm Affiliates, business partners, suppliers and/or service providers.
Use justification: contract performance, legitimate interests (to allow us to provide you with content and services on the websites)
To reorganise or make changes to our business
If we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your personal information to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this notice.
Use justification: legitimate interests (in order to allow us to change our business)
In connection with legal or regulatory obligations
We process your personal information to comply with our regulatory requirements or as part of dialogue with our regulators as applicable which may include disclosing your personal information to third parties, the court service, regulators and/or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
Use justification: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities)
For Fraud, Anti-Money Laundering and Sanctions Screenings
When establishing or maintaining client relationships for the provision of certain services we process your personal information for the purposes of carrying out fraud, anti-money laundering or sanctions violations checks.
Use justification: legal obligations
How we protect your personal information
Security over the internet
No data transmission over the internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.
Export outside the EEA and the UK
Your personal information may be accessed by staff, Wisterm Affiliates or suppliers in, transferred to, and/or stored at, a destination outside the country in which you are located, whose data protection laws may be of a lower standard than those in your country. We will, in all circumstances, safeguard personal information as set out in this Policy.
Where we transfer personal information from inside the EEA or the UK to outside the EEA or the UK, we are required to take specific measures to safeguard the relevant personal information. Certain countries outside the EEA and the UK have been approved by the European Commission or the UK government as providing essentially equivalent protections to EEA and UK data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In countries which are not subject to this approval, we will establish legal grounds justifying such transfer, such as model contractual clauses or other legal grounds permitted by applicable legal requirements.
Please contact us as set out below if you would like to see a copy of the specific safeguards applied to the export of your personal information.
We will retain your personal information for as long as is necessary for the processing purpose(s) for which it was collected and any other permitted linked purpose (for example where we are required to retain personal information for longer than the purpose for which we originally collected it in order to comply with certain regulatory requirements). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information is retained) or securely destroyed.
Your rights & contacting us
You have the right to ask us not to process your personal information for marketing purposes. You can exercise the right at any time by clicking the “unsubscribe” option on any electronic marketing communication sent to you or by contacting us as set out below.
We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by contacting us as set out below.
If you have any questions in relation to our use of your personal information, you should contact us as set out below. Under certain conditions, you have the right to require us to:
- provide you with further details on the use we make of your information;
- provide you with a copy of information that you have provided to us;
- update any inaccuracies in the personal information we hold;
- delete any personal information that we no longer have a lawful ground to use;
- object to any processing that Wisterm justifies on the “legitimate interests” ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;
- object to direct marketing (including any profiling for such purposes); and
- restrict how we use your information whilst we consider your inquiry, and where processing is based on consent, you have the right to withdraw your consent by contacting us at the contact details below or as indicated when consent was given.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within 60 days.
If you are not satisfied with our use of your personal information or our response to any exercise of these rights you have the right to complain to the data protection regulator in your country.
If you have any questions in relation to this Policy, please contact our data protection team at [email protected].
How changes to this Policy will be made
This Policy was last updated on 12 September 2022.