PortfolioShop (“we” or “us”) wants to inform you about the ways we process your personal information. In this Privacy & Cookie Notice we explain what personal information we collect, use and disclose.
Personal information means any data relating to an individual or firm who can be identified, directly or indirectly, based on that information. This may include information such as names, contact details, (online) identification data, online identifiers or other characteristics specific to that individual. This Privacy & Cookie Notice applies when you visit our websites, solutions and other services, that refer or display a link to this notice (“Services”). This Privacy & Cookie Notice may be supplemented or replaced by additional privacy statements or terms provided to you.
WHO WE ARE
PortfolioShop is a service provider to investment funds, trading firms and custodians. Any personal information provided to or collected by PortfolioShop via our corporate web pages is controlled by PortfolioShop. We are committed to safeguarding the personal information of our customers, users, employees and other stakeholders, while helping our customers, employees, and investors create a deeper impact and make the right decisions.
WHAT PERSONAL INFORMATION DO WE COLLECT?
The type of personal information we collect depends on your relationship with us and the Services we provide to you. To that end, we may collect the following personal information about you:
- Name and contact details, such as, first and last name, email address, postal address, telephone number
- Work-related information, such as, job title and other employment or education information
- Account Credentials, such as, passwords and other security information for authentication and access
- Financial Information, such as, bank account numbers for processing of transactions.
- Usage information, such as, behavioral information about how you navigate within our Services and which elements of our Services you use the most.
- Other information shared by you through our websites, logins and other products.
- Computer, device and connection information, such as, IP address, browser type and version and location
HOW WE COLLECT PERSONAL INFORMATION
We and our third-party service providers may collect personal information from the following sources:
- Direct Interactions, such as when you register for our Services or enter into a service provider agreement.
- Data from Third Parties, such as information on third-party websites or other information you may have made publicly available, or information provided by third party sources, including but not limited to government entities and data resellers
Automated Tracking Technologies, such as information automatically collected about your interaction with our Services and websites using various technologies such as cookies, web logs and beacons and internet tags
HOW WE USE YOUR PERSONAL INFORMATION
The personal information collected is used for the purposes for which you have provided it, and might be further used for statutory or other legitimate purposes only. As an example, if you make use of our service contact form on our website, we will.
Lawfulness of the processing is one of the main principles relating to the processing of your personal information – we apply the following legal processing guidelines (where applicable) :
- processing is necessary for the performance of a contract, or in order to take steps prior to entering into a contract;
- processing is necessary for the purposes of our legitimate interests – for example, to improve the quality of our products and Services;
- processing is necessary for compliance with a legal obligation to which we are subject, or that is otherwise lawful under the applicable data protection laws;
- with your given consent.
Depending on how you interact with us and the Service, we may use your personal information for the following purposes:
- Administering our relationship with you and our business, such as providing and managing your access to and use of our Services. This processing is necessary for the performance of a contract;
- Improving our Services and developing new products, such as inviting you to participate in surveys or to personalize your experience with our Services. This processing is necessary for the purposes of our legitimate interests;
- Marketing, such as providing you with marketing or advertising communications that we think you may be interested in. This processing is with your given consent or for our legitimate interests;
- Other general business support purposes, including but not limited to procurement, financial and fiscal management, risk and compliance management, and external reporting. This processing is necessary for compliance with a legal obligation to which we are subject, or that is otherwise lawful under the applicable data protection laws or for our legitimate interests.
SHARING YOUR PERSONAL INFORMATION
To be able to provide you the best possible Services and further our business operations, we may share certain information internally or with selected third parties. There might also be a certain statutory or legal obligation that we believe in good faith requires us to disclose your personal information externally. Parties we might share data with include:
- our service providers, e.g. for managing or hosting services and/or underpinning technology for the Services we are providing;
- our business partners, to the extent you have purchased or expressed interest in a product or service of such a business partner, interacted with them or otherwise authorized the sharing of your personal information with such a business partner;
- subscribing, accrediting or professional organizations, e.g. for providing utilization information to organizations that provide you with access to our Services;
- other parties, e.g. as needed for external audits, compliance, risk management, corporate development and/or corporate governance related matters; or
- governmental authorities and regulators, as required under the applicable law.
Whenever we share personal information internally or with third parties in other countries, we have appropriate safeguards in place in accordance with the applicable data protection laws, including as applicable the EU Model clauses. As required under the applicable law, third parties are required to use appropriate safeguards to protect personal information, and they can only access the personal information that is necessary for performing their specific tasks.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
Your personal information will be processed to the extent necessary for the performance of our obligations, and for the time necessary to achieve the purposes for which the information is collected, in accordance with our data retention policies and the applicable data protection laws. When we no longer need your personal information, we will take all reasonable steps to remove it from our systems and records or take steps to properly anonymize it so that you can no longer be identified from it.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We have put in place an internal framework of policies and minimum standards to keep your data safe. In addition, we limit access to personal information by our employees, business partners, service providers and third-party service providers to a ‘need-to-know’ basis. More specifically and in accordance with the law, we take appropriate technical and organizational measures (policies and procedures, IT security and others) to ensure the confidentiality and integrity of your personal information and the way it is processed.
WHAT ARE YOUR RIGHTS?
We will honor your rights under the applicable laws. To the extent provided under your local data protection laws, including the European data protection laws, your rights may include the following:
- Right of access (‘an overview of your personal information’): the right to get an overview of your personal information that we process.
- Right to rectification (‘correct your personal information’): if your personal information is inaccurate or incomplete, the right to ask us to rectify or complete your personal information.
- Right to erasure (‘right to be forgotten’): the right to request that we delete your personal information to the extent permitted by the applicable law. In certain circumstances, it may not be possible for us to accept your request; for example, when the processing is necessary to comply with a legal obligation, or if the processing is necessary for the performance of a contract. In some cases, your personal information is necessary in order to provide the Services and if you do not provide such information to us then you may be precluded from accessing and using the Services or using certain Services features.
- Right to data portability (‘transfer your personal information’): the right to ask us to transfer your personal information directly to you. This applies to certain personal information if processed by automated means and with your consent, or based on a contract you have with us.
Right to restrict processing: the right to request that we restrict or stop the processing of your personal information held by us for a certain period of time, or for an indefinite period. In certain circumstances, it may not be possible for us to accept your request; for example, when the processing is necessary to comply with a legal obligation, or if we can demonstrate compelling legitimate grounds otherwise.
- Right to object: the right to object to the processing of your personal information. The reasons for an objection should relate to your particular situation, and be related to processing based on the legitimate interest condition. We will then no longer process the personal information, unless we can demonstrate compelling reasons otherwise. In certain circumstances, you have the unconditional right to object; for instance, in the context of direct marketing activities.
- Withdrawal of Consent: the right to withdraw your consent to the processing of your personal information at any time; for instance, after you consented to us keeping you informed about our Services, you have the right to withdraw this consent at any time.
Cookies or similar techniques (referred to collectively as “Cookies”) are small text files or pixels, which might be stored on your computer or mobile device. Cookies may be necessary to facilitate website browsing and making it more user-friendly. Third party Cookies may collect information to analyze personal browsing behavior.
- Necessary Cookies – these mandatory Cookies are needed for our websites to function properly.
- Non-Necessary Cookies – these Cookies add additional functionality to our websites, including support for analytic services that help us to improve our website’s functionality and user experience, as well as interests that can be applied to collect insights, to issue personalized content and advertising on our own and other websites.
LINKS TO OTHER WEBSITES
Our websites may contain links to third-party websites, which may have privacy notices that differ from ours. We are not responsible for the collection, processing or disclosure of personal information collected through other websites.
We are also not responsible for any information or content contained on such websites. Links to other websites are provided solely for convenience. Your usage and browsing on any such website is subject to that website’s own policies. Please review the privacy notices posted on other websites that you may access through our website.
PortfolioShop may provide you with additional or different privacy notices, in specific instances, on how your personal information is collected and used for a specific Service.
HOW YOU CAN CONTACT US
If you have any questions about how we process your personal information or if you want to exercise one of your rights, you can contact us at 516-364-6800 or [email protected]. In response to a request, we might ask you to verify your identity if needed, and to provide information that helps us to understand your request better. If we do not grant your request, whether in whole or in part, we will explain why.
UPDATES TO THIS NOTICE
From time to time we may update this Privacy & Cookie Notice or any other specific privacy statement. When making changes to this Privacy & Cookie Notice, we will add a new date to this Privacy Statement. This version is effective as of November 16, 2020.