PRIVACY STATEMENT – GENERAL DATA PROTECTION REGULATION (GDPR)
FOR PERSONS LOCATED IN THE EUROPEAN ECONOMIC AREA
Under applicable data protection laws and regulations in the areas where we operate, we have a duty to protect any personal data we collect from you. We are committed to protecting your information and to complying with the requirements of applicable data protection legislation.
It is important that you read this Privacy Statement together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This Privacy Statement is issued on behalf of DCS Advisory LLC (“DCS Advisory”).
What is personal data?
Personal data means any information relating to an individual person who can be identified, directly or indirectly, by reference to a particular identifier, for example, name, email address, date of birth.
What personal data do we collect?
We may collect personal data such as your email address regarding your preferences if you subscribe to receive marketing communications or where it is relevant to a service we provide.
If you attend a DCS Advisory event, we may collect your name, office location, email address and telephone number.
How is your personal data collected?
We use different methods to collect data from and about you, including the following:
- When you or your organization seek financial advisory services from us;
- When you or your organization subscribe to our publications or sign up to receive our marketing communications or to attend a DCS Advisory event;
- When you or your organization offer to provide services to us.
What is the basis for using your data?
We will only use your personal data when we are legally permitted to do so.
The purposes for which we will use your data, in general, will be in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests;
- Where we need to comply with a legal or regulatory obligation (e.g. anti-money laundering regulations);
- Where we provide you with financial advisory services and need to perform our services; or
- Where you have expressly given us your consent.
For which purposes will we use your personal data?
When you request to receive our marketing materials, we will keep you up-to-date with transaction announcements, market commentary, relevant sector briefings, DCS Advisory announcements and details of events.
You may be added to our client contact system if you provide us with your contact details.
How long will we keep your personal data?
We will retain your personal data for as long as is necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or regulatory reporting requirements.
When it is no longer necessary for us to retain your personal data we will delete or destroy it.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and applicable legal or regulatory requirements.
Will we share your personal data?
We may share your personal data within DCS Advisory or with our affiliates on a confidential basis where necessary for the purpose of us providing our services to you.
We may need to share your personal data with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also share your personal data with our financial auditors, our insurers and insurance brokers and other professional advisers in the course of the advice we provide to you. We may also need to share some personal data with other parties, for example, if we advise you to sell your business, we may need to disclose personal data held by us to a prospective buyer of your business.
We do not sell, rent or exchange your personal data with any third party for commercial reasons.
Will we transfer your personal data abroad?
The ultimate parent company for the DCS Advisory is incorporated in Japan and we also have other affiliated entities based both inside and outside the European Economic Area (EEA). We may need to transfer your personal data to one of these jurisdictions for the legitimate purposes outlined above. The countries where we may need to transfer data may not provide the same level of data protection as the laws within the EEA. We will ensure that any such international transfers are made subject to appropriate legal safeguards, such as by using EU Standard Contractual Clauses.
How do keep your personal data secure?
We will take appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way. These measures include information security processes as well as organizational policies and procedures.
What are your rights?
If you are in the EEA or UK, we will only send you marketing communication if you so elect. You can also ask us to stop sending you marketing messages at any time by following the out-out links on any marketing message sent to you or by emailing firstname.lastname@example.org at any time.
Subject to certain legal conditions, you are entitled at any time to ask us for a copy of the personal data which we hold about you. You are also entitled to ask that any information we hold about you is updated or changed and to object to or restrict our using your personal data. You can make any of these requests free of charge by contacting us at email@example.com; however, we reserve the right to charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive.
If you feel that we have not been able to resolve your inquiry or concern you may raise a formal complaint. If you remain unsatisfied with our response, you may take your complaint to the relevant privacy regulator, which for persons in the EEA and UK, is the Information Commissioners Office (ICO) in the United Kingdom. Further information is available on the ICO website or by telephone on 0303 123 1113.
We use a technology called “cookies” as part of a normal business procedure. Cookies are small text files that are created by a web server and stored on your computer when you visit a website. They are not executable code and can only be read by (you and) the website that created them. You can view and edit the cookies on your computer like any other text file using a text editor (the contents are usually just strings of unique identifiers and date/timestamps). The website that created the cookie can read the contents when you are at their website.
Cookies are widely used across the internet: you may have hundreds of cookies on your computer at any one time. Each browser has its own set of cookies so, if you run multiple browsers, you will have multiple sets of cookies on your computer.
If at any time you wish to disable our cookies you may do so through the settings on your browser. These settings allow you to specify which cookies you will accept by type and often by specific websites using an exception list, for example, you can block all cookies and then list the website from which you will accept cookies.
Updates to this Privacy Statement
We may make changes to this Privacy Statement from time-to-time in order to reflect any changes to the way in which we process your personal data or changes in applicable law or regulatory requirements. We encourage you to review this Privacy Statement periodically to be informed of how we use your personal data.