Last updated: January 29, 2020
- providing services to you or our clients;
- you use “our Website” or;
- performing any other activities that form part of the operation of our business.
What information do we collect?
In the course of providing services to you or our client, and performing due diligence checks in connection with our services (or discussing possible services we might provide,) we will collect or obtain personal data about you. We may also collect personal data from you when you use this Website or through digital interactions with you.
We may collect or obtain such data because you give it to us (for example in a form on our Website,) because other people give that data to us (for example your employer or adviser, or third party service providers that we use to help operate our business) or because it is publicly available.
The personal data that we collect or obtain may include but is not limited to: your name; age; date of birth; gender; e-mail address; home address; country of residence; lifestyle and social circumstances (for example, your pastimes); family circumstances (for example, your marital status and dependents); employment and education details (for example, the organization you work for, your job title and your education details); financial and tax-related information (for example your income and tax residency); your postings on any blogs, forums, wikis and any other social media applications and services that we provide; your IP address; your browser type and language; your access times; complaint details; details of how you use our products and services; details of how you like to interact with us and other similar information.
The personal data we collect may also include so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your: dietary requirements (for example, where Van York would like to provide you with lunch during a meeting,) health (for example, so that we can make reasonable accommodations for you in our buildings, products and services) and sexual orientation (for example if you provide us with details of your spouse or partner.)
The types of personal data and special categories of personal data that we collect may vary depending on the nature of the services that we provide to you or our client, or how you use our Website. In some rare circumstances, we might also gather other special categories of personal data about you because you volunteer that data to us or we are required to gather that data as a result of legal requirements imposed on us.
We understand the importance of protecting children’s privacy. Our Website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children.
How do we use information about you?
We will use your personal data to provide you or our client with services. As part of this, we may use your personal data in the course of correspondence relating to the services. Such correspondence may be with you, our client, our service providers or competent authorities. We may also use your personal data to conduct due diligence checks relating to the services.
We will only collect personal information that is necessary to fulfill the following purposes:
- To verify identity;
- To identify preferences;
- To open and manage an account;
- To ensure you receive a high standard of service;
- To meet regulatory requirements;
- Other legal reasons as applicable to the goods and services requested.
We will obtain your consent to collect, use or disclose personal information. In some cases, we can do so without your consent (see below.) You can provide consent orally, in writing, electronically or through an authorized representative. You provide implied consent where our purpose for collecting, using or disclosing your personal information would be considered obvious or reasonable in the circumstances. Consent may also be implied where you have notice and a reasonable opportunity to opt-out of having your personal information used for mail-outs, marketing or fundraising, and you do not opt-out. We may collect, use or disclose personal information without consent:
- When permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- When the personal information is available from a public source;
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt or protection from fraud;
- Other legally established reasons.
We will not sell your personal information to other parties unless consent has been provided or implied. We retain your personal information for the time necessary to fulfill the identified purposes or a legal or business purpose. We will make reasonable efforts to ensure that your personal information is accurate and complete. You may request correction to your personal information to ensure its accuracy and completeness. A request must be in writing and provide sufficient detail to identify your personal information and the correction being sought. We are committed to ensuring the security of your personal information and may use passwords, encryption, firewalls, restricted employee access or other methods, in our discretion. We will use appropriate security measures when destroying your personal information such as shredding documents or deleting electronically stored information, in our discretion.
We may also collect information that your browser sends whenever you visit our Website (“Log Data.”) This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages and other statistics. In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Website’s functionality. These third party service providers have their own privacy policies addressing how they use such information.
A cookie is a data file that certain Websites write to your computer’s hard drive when you visit such sites. A cookie file can contain information, such as a user identification code, that the site uses to track the pages you have visited, but the only personal information a cookie can contain is information you supply yourself. A cookie can’t read data off your hard disk or read cookie files created by other sites. We may collect information from your web sessions by using cookies, to determine, for example, user traffic patterns, and the effectiveness of our navigational structure.
Most Website browsers automatically accept cookies, but you can usually change your browser settings to display a warning before accepting a cookie, or to refuse all cookies. You don’t need to have cookies turned on to use/navigate through many parts of this Website, however, you may have to accept the receipt of cookies to access some resources on this Website.
We may employ third party companies and individuals to facilitate our Website, to operate the Website on our behalf, to perform Website-related services or to assist us in analyzing how our Website is used. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
Compliance with Laws
As set out above, and for clarity, we will disclose your personal information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Website.
The security of your personal information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
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