Equilibrium Global Privacy Statement
Who this privacy statement applies to and what it covers
- This privacy statement applies to Equilibrium Global (and its other entity, Equilibrium Gulf).
- We are committed to protecting your privacy and handling your information openly and transparently. This privacy statement explains how we will collect, handle, store and protect information about you when:
- providing contract support to you or services to our clients;
- you use our Website; or
- performing any other activities that form part of the operation of our business.
- In this privacy statement, your information is sometimes called “personal data”. We may also refer to “processing” your data, which includes handling, collecting, protecting and storing it.
What personal data we collect
- We may collect, record and use your personal data in physical and electronic form, and will hold, use and otherwise process that data in line with the General Data Protection Regulation (GDPR) and as set out in this statement.
- When we provide contract support and services to you or our clients and perform due diligence checks in connection with our services (or discuss possible services we might provide), we will process personal data about you. We may process your data because:
- you have given it to us;
- other people give it to us (for example, your employer or adviser, or third-party service providers that we use to help operate our business); or
- it is publicly available.
- name, gender, age and date of birth;
- contact information, such as address, email, and mobile phone number;
- country of residence;
- details of how your relationship with our contracts and services;
- details of how you like to interact with us, and other similar information relevant to our relationship.
- 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, in relation to Equilibrium Global-organised dinners);
- health (for example, so that we can make it easy for you to access our buildings, products and services); and
- sexual orientation (for example, if you provide us with details of your spouse or partner).
- We may also process personal data relating to ethnic or racial origin (for example, any multicultural networks you belong to), or about your political opinions (inferred from information you give us about political associations you belong to or have donated to).
- We will typically seek separate permission from you in writing to process these special categories of personal data.
- If you choose not to provide, or object to us processing, the information we collect, we may not be able to process your instructions or continue to provide some or all of our services to you or our client.
Personal data provided by or about third parties
- When a third party gives us personal data about you, we make sure they have complied with the relevant privacy laws and regulations. This may include, for example, that the third party has informed you of the processing and has obtained any necessary permission for us to process that information as described in this privacy statement.
- If any information you give us relates to a third party (such as a spouse, financial dependent, or joint account holder), by providing us with such personal data you confirm that, in line with the above provisions, you have obtained any necessary permission to use it or are otherwise permitted to give it to us.
How we use your personal data
- We process information about you and/or your business to enable us and other members of the Equilibrium Global (and its other entities) Network to provide our services to you or our clients, and to meet our legal or regulatory obligations.
- Some of your personal data may be used for other business purposes, such as the use of personal data to provide services to our clients
- We will use your personal data to provide you or our clients or other third parties with services, and this includes using your personal data in correspondence relating to those services. That correspondence may be with:
- other third parties or other members of the Equilibrium Global (and its entities) Network;
- our service providers; or
- competent authorities.
- We may also use your personal data to conduct due diligence checks relating to the services.
Use of personal data for other activities which form part of the operation of our business
- We may also use your personal data in connection with:
- legal or regulatory requirements;
- requests and communications from competent authorities;
- client account opening and other administrative tasks;
- financial accounting, invoicing and risk analysis;
- relationship management, which may involve:
- sending you operational updates;
- contacting you for feedback on services;
- sending you event invitations;
- recruitment and business development, which may involve:
- the use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission); and
- the use of third-party data sources to help us verify and improve the information we hold about key business relationships with individuals;
- services we receive from our professional advisors, such as lawyers, accountants and consultants;
- investigating or preventing security incidents; or
- protecting our rights and those of our clients.
Use of personal data collected via our Website
- In addition to the above, we may also use your personal data collected via our Website:
- to manage and improve our Website;
- to tailor the content of our Website to give you a more personalised experience;
- to draw your attention to information about our products and services that may be of interest to you; or
- to manage and respond to any request you submit through our Website.
The legal grounds we use for processing personal data
- We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal data. We rely on one or more of the following lawful grounds:
- the processing is necessary for contractual purposes, to perform the agreement we have with you or to take steps to enter into an agreement with you;
- the processing is necessary for the purposes of a legitimate interest pursued by us or a third party, which might be:
- to provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
- to prevent fraud;
- to protect our business interests;
- to ensure that complaints are investigated;
- to evaluate, develop or improve our services or products; or
- to keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.
- To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
- you have given us your explicit consent to process that data;
- we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us);
- the processing is necessary to carry out our obligations under employment, social security or social protection law;
- the processing is necessary for the establishment, exercise or defence of legal claims; or
- you have made the data manifestly public.
- Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
Sharing your personal data
- In connection with any of the purposes outlined in the “How we use your personal data?” section above, we may disclose details about you to:
- other members of the Equilibrium Global Network or third parties which provide services to us;
- competent authorities (including courts and authorities regulating us);
- your employer and/or its advisers, or your advisers;
- anyone to whom we may transfer our rights and/or obligations.
- any other person or organisation after a restructure, sale or acquisition of any member of the Equilibrium Global Network, as long as they use your information for the same purposes we did;
- credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
- other third parties that reasonably require access to personal data relating to you.
Transferring your personal data outside the UK
- Information we hold about you may be transferred to other countries (which may include countries outside the EU):
- where we do business;
- which are linked to your engagement with us;
- from which you regularly receive or transmit information; or
- where our third parties conduct their activities.
- These countries may have less stringent privacy laws than we do, so any information they hold can become subject to their laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies and private persons. In addition, a number of countries have agreements under which information is exchanged with other countries for law enforcement, tax and other purposes.
- When we, or our permitted third parties, transfer your personal data outside the EU, we will impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing.
- We may also transfer your personal data when:
- the transfer is to a country deemed to provide adequate protection of your personal data by the European Commission; or
- where you have consented to the transfer.
- If we transfer your personal data outside the EU in other circumstances (for example, because we have to by law), we will make sure it remains adequately protected.
Protecting your personal data
- We use a range of measures to ensure we keep your personal data secure, accurate and up to date. These include:
- education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
- administrative and technical controls to restrict access to personal data to a ‘need to know’ basis;
- technological security measures, including fire walls, encryption and anti-virus software; and
- physical security measures, such as controlled access our premises.
- The transmission of data over the internet (including by e-mail) is never completely secure. So, although we use appropriate measures to try to protect personal data, we cannot guarantee the security of data transmitted to us or by us.
How long we keep your personal data for
- We seek to ensure that we only keep your personal data for the longest of:
- the period necessary for the relevant activity or services;
- any retention period that is required by law; or
- the period in which litigation or investigations might arise in respect of the services.
- You have various rights in relation to your personal data. In particular, you have a right to:
- obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
- be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third-party sources from where it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
- ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
- ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data; withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
- receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);
- object to our processing of your personal data.
- If you would like to access or see a copy of your personal data, you must ask us in writing. We will endeavour to respond within a reasonable period, and in any event within one month in line with the GDPR. We will comply with our legal obligations as regards your rights as a data subject.
Right to complain
- If you wish to raise a complaint about how we are using your information, exercise any of the rights set out above, or if you have any questions or comments about privacy issues, you can contact us by:
- writing to Equilibrium Global, Chief Operating Officer, c/o Hedley Dunk, Trinity House, 3 Bullace Lane, Dartford, DA1 1BB
You can also complain to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, on 0303 123 1113. If you are not based in the UK, you have a right to complain to the EU Data Protection Authority (“DPA”) in your jurisdiction.
Changes to this privacy statement
- We may modify or amend this privacy statement from time to time.
When we make changes to this privacy statement, we will amend the revision date at the top of this page. The modified or amended privacy statement will apply from that date. We encourage you to review this statement periodically to remain informed about how we are protecting your information.