THE CAZENOVE ASSOCIATION – PRIVACY POLICY

Background

The Cazenove Association (“we”, “us” or “the Association”) with its registered office at 1, London Wall Place, London. EC2Y 5AU collects and uses certain Personal Data (as defined below). We are responsible for ensuring that we use that Personal Data in compliance with data protection laws.

At the Association we respect your privacy and we are committed to keeping all our members’ Personal Data secure. This Privacy Policy concerns information we collect about you as a member or supporter of the Association.

We use the following definitions in this Privacy Policy:

Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, us (or our representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of our intentions or the intentions of any other person in respect of an individual.

“Cazenove” means Cazenove & Co, any of the Cazenove group of companies, Cazenove Capital Management Limited, or J P Morgan Cazenove.

Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.

Information we may collect from you

We may collect and process the following data from you in the course of your membership of the Association:

  • Personal Data that you provide by filling in forms on this website, including Personal Data provided at the time of registering for membership – first name, surname, address, telephone number(s), email, and dates of employment at Cazenove; and
  • Any other information that you choose to share with us which may be considered Personal Data.

How we use your information

Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

  • to establish and maintain your membership or support of the Association;
  • to contact you by electronic means (e-mail) with news and information about the Association and our forthcoming events and activities;
  • to provide or administer activities to you as a member of the Association;
  • for the management and administration of the Association; and
  • for the administration and maintenance of our databases storing Personal Data.

However we use Personal Data, we make sure that the usage complies with the law and the law allows us to use Personal Data for a variety of reasons. These include:

  • we need to do so in order to perform our contractual obligations with you;
  • we have obtained your consent;
  • we have legal and regulatory obligations that we have to discharge;
  • we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
  • the use of your Personal Data as described is necessary for our legitimate business interests, such as:
    • allowing us to effectively and efficiently manage and administer the operation of the Association; or
    • maintaining compliance with our internal policies and procedures.

We will take steps to ensure that the Personal Data is accessed only by employees of the Association that have a need to do so for the purposes described in this Privacy Policy.

Disclosure of your information

We may share your Personal Data with third parties as further described below:

  • with third party agents and organisations for the purposes of providing services to us in relation to our activities and events. These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data for the purposes described in this Privacy Policy.
  • with other members of the Association; and
  • to the extent required by law, for example if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or to protect the rights, property, or safety of the Association, our members, or others.

Where we store your personal data

The Personal Data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.

Where we transfer your Personal Data to another country outside the EEA, we will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in a manner consistent with legal requirements and this Privacy Policy. In relation to data being transferred outside the EEA, for example, this may be done in one of the following ways:

  • the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;
  • the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
  • where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
  • in other circumstances the law may permit us to otherwise transfer your Personal Data outside the EEA.

You can obtain more details of the protection given to your Personal Data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us using the contact details provided below.

How we safeguard your information

Information is a critical business asset and must be protected, appropriate to its risk as well as its importance or value. We operate layers of safeguards and defences designed to ensure that the Association is able to operate safely in a dynamic threat and technological environment. We have extensive controls and mechanisms in place designed to detect, respond and recover in case of any adverse events that may arise.

How long we keep your Personal Data

How long we will hold your Personal Data for will vary and will be determined by the following criteria:

  • the purpose for which we are using it (as further described in this policy) – we will need to keep the data for as long as you are a member or supporter of the Association or for as long as necessary for member administration; and
  • legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

Your rights

In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

  • the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
  • the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
  • in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to the Association;
  • the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
  • the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
  • the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
  • the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

You can exercise your rights at any time by contacting us at The Cazenove Association, 1, London Wall Place, London. EC2Y 5AU or [cazenoveassociation@cazenovecapital.com].

Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.

Contact

Questions, comments and requests regarding this Privacy Policy or the handling of your Personal Data are welcomed and should be addressed to The Cazenove Association, 1, London Wall Place, London. EC2Y 5AU or [cazenoveassociation@cazenovecapital.com]. If you are not satisfied with the response you receive, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.