PRIVACY POLICY
This Privacy Policy explains what the New Mellon Asset and Wealth Management group (“NMAWM”) does with two types of personal data:
· Personal data you supply to the firm in circumstances where you apply for a job at the firm either directly or via a third party recruiter.
· Information you supply NMAWM and its Investor Relations team as a prospective investor.
The policy describes how NMAWM collects, uses and processes your personal data, and how, in doing so, it complies with its legal obligations to you. Your privacy is important to NMAWM, and the firm is committed to protecting and safeguarding your data privacy rights.
Depending on your jurisdiction, the UK GDPR and Data Protection Act 2018 are applicable to the processing of personal data by NMAWM and various undertakings appointed by it, along with certain European Union laws regarding personal data.
We may amend this Privacy Policy from time to time. Please visit this page if you want to stay up to date, as NMAWM will publish any changes here.
If you are dissatisfied with any aspect of NMAWM’s Privacy Policy, you may have legal rights and, where relevant, we have described these below.
Identity and contact details of data controller
New Mellon Asset and Wealth Management, Vasilissis Sofias 37, 10675 Athens, Greece
Please contact a representative of NMAWM with any queries or concerns regarding the handling of your personal data: info@nmawm.com
What kind of personal data does NMAWM collect?
· Candidate data: In order to assess you for employment opportunities, NMAWM needs to process certain information about you. NMAWM only asks for details that will genuinely help to assist in this process, such as your name, contact details, education details, employment history, emergency contacts, immigration status, financial information (where we need to carry out financial background checks) social security number as well as verbal and written references. Where appropriate and in accordance with local laws and requirements, we may also collect information related to your health (such as where we collect diversity data as outlined below) and any criminal convictions. NMAWM may also, with your consent, collect information relating to your health, age, gender identity, sexual orientation, religion and ethnicity in order to monitor our diversity, equity and inclusion (D,E&I) efforts in the context of our recruitment practices and to provide reasonable accommodations and adjustments to candidates with disabilities. This information is collected on an entirely voluntary basis.
· Prospective investor data: In order to provide you with information about NMAWM and its funds and associated investment opportunities it may be necessary for NMAWM to process certain personal information such as names, telephone numbers and email addresses and any personal identification documents you supply in order to confirm your identity.
How does NMAWM collect Personal Data?
NMAWM may collect personal data through a range of means. These may include:
· direct interactions (where you provide personal data to NMAWM through telephone or email correspondence or other direct methods of communication, including applications to invest in NMAWM ’s funds or for prospective employment);
· from third parties such as intermediaries and banks in the case of prospective investors or third party recruitment firms in the case of prospective employees;
· other publicly available sources (such as a website (for example, LinkedIn) or publicly- available registries (for example, FCA or other regulatory registers)); and
· in the case of prospective candidates your personal referees or former colleagues now working at NMAWM may share personal information about you with NMAWM.
NMAWM’s website uses cookies. By continuing to use NMAWM’s website you are giving consent to cookies being used. For information on cookies and how you can disable them, please visit our Cookies Policy.
Please be aware that if you visit NMAWM’s offices CCTV is in use for security purposes and that you will be recorded in public areas of the office.
For the protection of all parties and in order to help draft accurate records of conversations, telephone calls to NMAWM or its affiliates may be recorded. NMAWM may also use automatic transcription tools.
How does NMAWM use your personal data?
Candidate data:
· Your personal details are used by NMAWM to help us (a) assess your suitability for roles that you have applied for either directly or via a recruiter; (b) provide any reasonable accommodations or adjustments where relevant; (c) monitor our D,E&I efforts in our recruitment practices; (d) carry out background checks, verification and referencing on you as a candidate; (e) carry out NMAWM’s obligations relating to any potential contracts entered into between NMAWM and you; and (f) to comply with legal or regulatory obligations applicable to NMAWM.
· We are entitled to use candidate data in these ways because:
· we need to in order to take steps in preparation for entering into a contract with you, in particular to consider you for a position at NMAWM;
· to the extent this is required by applicable data protection laws and regulations, we have separately asked you for your consent and provided information as to what happens if you do not give consent;
· we have legal and regulatory obligations that we have to discharge;
· we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; and/or
· the use of your personal data as described is necessary for our legitimate business interests, such as:
o allowing us to effectively assess your skills, qualifications and/or the strength and merits of your application and your suitability for the role applied for;
o allowing us to effectively verify your information;
o allowing us to effectively and efficiently administer and manage the operation of our business;
o ensuring a consistent approach to the recruitment of NMAWM personnel worldwide; or
o being able to contact you in relation to your application and the recruitment process.
· Please note, if your application is successful and you are subsequently offered and accept employment at NMAWM, the information we collect during the application and recruitment process will become part of your employment record.
· The provision and processing of your personal data is necessary for NMAWM in the context of your potential employment. Without the ability to process your personal data, NMAWM would not be able to assess you for employment at the firm. NMAWM will not discriminate automatically against any subject of a criminal record check on the basis of a conviction or other information revealed. To help draft accurate records of conversations, NMAWM may use automatic transcription tools.
Prospective investor data:
· Information about prospective investors is used by NMAWM (a) for the purposes of discussing and reviewing potential investments in NMAWM funds (b) assessing an investor’s appropriateness to invest in the fund as an unregulated collective investment scheme (c) to carry out NMAWM’s obligations relating to contracts to be entered into between NMAWM funds and you; (d) for the general administration of potential investments into the NMAWM funds; and (e) to comply with legal or regulatory obligations applicable to NMAWM.
· We are entitled to use prospective investor data in these ways because:
· we need to in order to take steps in preparation for entering into a contract with you;
· we have legal and regulatory obligations that we have to discharge;
· we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; and/or
· the use of your personal data as described is necessary for our legitimate business interests, such as:
o allowing us to effectively assess your appropriateness to invest in the fund;
o allowing us to effectively verify your information;
o allowing us to effectively and efficiently administer and manage the operation of our business;
o ensuring a consistent approach to our investors worldwide; or
o being able to contact you in relation to your prospective investments.
· In order to ensure NMAWM provides you with efficient investor relations service and access to information about NMAWM and its funds, NMAWM will store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of conversations, meetings and investor preferences. To help draft accurate records of conversations, NMAWM may use automatic transcription tools. The provision and processing of your personal data is necessary for NMAWM in the context of your potential interest in the fund. Without the ability to process your personal data, NMAWM would not be able to assess you as suitable to invest in the fund.
· As a matter of practice, we will seek to limit the sensitive personal data (for example data concerning health, racial or ethnic origin or political opinions) about you we collect and process. If there is a need for us to process such sensitive personal data for purposes of the employment relationship with you (for example where we would need to know about any disabilities to provide a suitable workplace environment or for tax purposes), we will only process such sensitive personal data in strict compliance with applicable laws and regulations. Likewise, if you have provided your freely given consent for the processing of certain sensitive personal data (for example, in relation to voluntary D,E&I questionnaires), we will also only process such sensitive personal data in strict compliance with the consent that you provide, as well as applicable laws and regulations.
Who does NMAWM share your personal data with?
· Candidate data: Your personal data will be shared internally with any of NMAWM’s group companies for the purposes of candidate selection and appointment. Your personal data will also be shared with inter alia third party suppliers who provide screening and testing services to the firm as well as legal, tax and HR advisers and third party recruiters. If references are sought NMAWM will also share your personal data with previous employers and referees.
· Prospective investor data: NMAWM will share personal data on prospective investors with inter alia the fund boards, administrators to the funds, legal, tax and accounting advisers as well as third party financial intermediaries in certain instances.
· Personal data will only be disclosed by NMAWM to a third party in circumstances where that third party has agreed to respect the security of personal data and treat it in accordance with applicable law. Third parties to whom any personal data may be disclosed will be permitted to use personal data only as described in this policy and they will only be permitted to process personal data for specified purposes and otherwise in accordance with the instructions of NMAWM.
Transfer of Personal Data outside the UK and European Economic Area
NMAWM may transfer your personal data to other NMAWM companies based outside of the UK and the European Economic Area (the “EEA”).
Where NMAWM transfers personal data outside the UK and EEA, it will seek to ensure a similar degree of protection is afforded by ensuring that personal data is transferred only to persons in countries outside the UK and EEA in one of the following circumstances.
· To persons and undertakings in countries that have been deemed to provide an adequate level of protection for personal data by the Greek government.
· To persons and undertakings to whom the transfer of such personal data is made pursuant to a contract that is compliant with the model contracts for the transfer of personal data to third countries from time to time approved by the Greek government.
In other circumstances the law may permit us to otherwise transfer your personal data outside the UK and EEA. In all cases, however, we will ensure that any transfer of your personal data is compliant with applicable data protection law.
You can obtain more details about the protection given to your personal data when it is transferred outside the UK and EEA by contacting us in accordance with the “Identity and contact details of data controller” section.
How does NMAWM safeguard your data?
NMAWM has in place security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These security measures include procedures to deal with any suspected personal data breach. NMAWM will notify any affected person and any applicable regulator of any personal data breach in circumstances where they are required to do so by applicable law.
How long does NMAWM retain your personal data for?
· Candidate data: If your candidature does not proceed to employment with, or hiring by, NMAWM it will retain your personal details for a period of twelve months after the position you may be suitable for is filled. After that point NMAWM’s policy is to delete your personal data from its systems unless NMAWM believes in good faith that the law or other regulation requires NMAWM to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation) or if NMAWM considers that you may be suitable for an alternative role. If you do receive an offer of employment with NMAWM, further details shall be provided to you in or around the time of your hire, regarding how your personal data may be used for the purposes of your employment.
· Prospective investor data: In order to comply with legal and regulatory obligations regarding the proper classification and identification of potential investors in funds which are unregulated collective investment schemes your personal details will be retained by NMAWM for a period of up to six years after the last contact with you. After that point NMAWM will delete your personal data from its systems unless NMAWM believes in good faith that the law or other regulation requires NMAWM to preserve it (for example, because of NMAWM’s obligations to tax authorities or in connection with any anticipated litigation). In some circumstances, NMAWM may decide to retain anonymized personal data for research or statistical purposes, in which case such information may be retained and utilised indefinitely without further notice.
How can you access, amend or take back the personal data that you have given to NMAWM?
You have various rights in relation to your personal data. To get in touch about these, please email info@nmawm.com. NMAWM will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that NMAWM will keep a record of your communications to help it resolve any issues which you raise.
You have the right to obtain information regarding the processing of your personal data and request access to any personal data concerning you that NMAWM is processing. Whilst NMAWM takes efforts to ensure that all personal data that it processes is accurate and up-to-date, you may ask NMAWM to rectify any inaccurate or incomplete personal data concerning you and NMAWM will do so without undue delay. In the event NMAWM relies on consent to process any of your personal data, you have the right to withdraw your consent to the processing of your personal data at any time. Please note, however, that NMAWM may still be entitled to process your personal data if we have another legitimate reason for doing so. For example, NMAWM may need to retain personal data to comply with a legal obligation and as noted in this privacy notice, NMAWM relies mainly on its legitimate interests to process your personal data. You may, in certain circumstances, request that NMAWM erase your personal data and/or request that NMAWM restricts, or you object to, NMAWM’s processing of your personal data if certain criteria apply. Please note that there may be circumstances where you ask us to erase your personal data, or where you object to or request we restrict, our processing of your personal data, but we are legally entitled to retain it. You have the right in certain circumstances to data portability. This means that, in those circumstances, you have the right to receive from NMAWM any personal data concerning you in a structured, commonly used and machine-readable format, and may request that NMAWM transmit it directly to another data controller, where technically feasible. Please note that this right only applies to personal data which you have provided directly to NMAWM. Should you have any concerns about how NMAWM processes your personal data you should contact NMAWM at the email address above.
Incidental personal data processed via email and mobile applications
In the process of providing our investor relations service and information about NMAWM and its funds, NMAWM may receive certain personal data, such as the name, address, email and/or telephone number of a financial adviser or other contact of prospective investors. In such circumstances, the personal data of that contact may be retained on a general contact database that is maintained by NMAWM, or in NMAWM’s email storage system, for as long as is necessary to process the personal data for the purpose for which NMAWM is using it, or to comply with our legal obligations. Such personal data will only be processed by NMAWM’s employees in compliance with NMAWM’s data protection and data security policies and procedures.
In the process of managing and operating certain mobile applications, NMAWM may receive certain personal data of users, such as name, username, password, email, tokens, and/or device identifier. In such circumstances, the personal data of the user may be retained in on-device secure storage or in backend databases until the user is deleted for a longer period for diagnostics, support, or incident resolution. To allow RSL to operate the applications, personal data of users may be shared with certain third parties but will remain subject to NMAWM’s data protection and data security policies and procedures.