ZAIS Group, LLC (“ZAIS”) does not disclose nonpublic personal information about its clients or former clients to third parties other than as described below.
ZAIS collects information about you (such as your name, address, social security number, assets and income) from its discussions with you and from any information that you may deliver to us and in the course of providing advisory services to you. ZAIS may use this information to provide advisory services to you, to open an account for you, to process a transaction for your account or otherwise in furtherance of our business. In order to service your account and effect your transactions, ZAIS may provide your personal information to our affiliates and to firms that assist us in servicing your account and have a need for such information, such as a broker or fund administrator. ZAIS may disclose such information to service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for purposes for which ZAIS discloses the information to them. ZAIS does not otherwise provide information about you to outside firms, organizations, or individuals except to government regulators as it may be required by law, our attorneys, accountants and auditors and as permitted by law or applicable regulations. Furthermore, ZAIS restricts access to nonpublic personal information about you to its employees who need to know that information to provide products or services to you. ZAIS maintains physical, electronic and procedural safeguards that comply with applicable federal standards to guard your personal information.
This Privacy Statement relates to the following entities:
This notice applies to individuals who are resident in the European Union and explains how ZAIS Group (comprising ZAIS Group, LLC and its subsidiaries and affiliates, including, without limitation, ZAIS Group (UK) Limited) may collect, use or otherwise process your personal data.
“Personal data” is information relating to you as a living, identifiable individual.
What information may we hold about you?
In the course of the prospective, current or former commercial or other relationship between you (including your employer or client) and ZAIS Group, we may obtain a range of personal data about you. We may receive this data directly or indirectly from you, from your employer or it may be received from a third party or a public source.
The types of personal data that we may hold include:
The purposes and legal basis for processing your personal data
Our primary legal basis for processing your personal data is that the processing is necessary in the context of our relationship with you (or your employer). In addition, processing of your personal data may be necessary for compliance with our legal and regulatory obligations.
How we use and share your information within ZAIS Group
Your personal data may be seen or used by our staff in the course of their duties. Information collected by ZAIS Group is held on servers located in the USA and may be accessed by staff in the USA and the UK. Staff are only permitted to access your personal data in the proper conduct of their duties including, without limitation, for compliance with legal and regulatory requirements.
Who else will see or use your data and who might we share it with?
Your personal data may be seen or used by third parties lawfully working with us in the ordinary course of our business. We may need to share your data with relevant third parties for example our accountants, fund administrators, business partners, professional advisors and others for legal, regulatory, administrative and/or other business purposes.
We may share your information with UK, EU, US or other regulatory bodies. We may also need to share your personal information in order to obtain necessary confidential legal advice or to comply with insurance, legal or regulatory obligations.
We will take steps to provide adequate protection of your personal data.
The consequences if you decide not to provide your data
If you decide not to supply personal data that we have requested, and as a result we are unable to comply with our legal or regulatory obligations, we may be unable to engage or continue to engage with you and/or your employer.
How long will we keep your data
We may retain your personal data for such period as we deem necessary or appropriate in the context of and following the conclusion of our relationship with you (or your employer or client).
Your rights over your data
Subject to certain conditions and exceptions, as set out in EU data protection law, you have, among other things:
If you wish to exercise any of your rights in relation to your data as processed by us, you may contact us by email at firstname.lastname@example.org. Some of your rights are not automatic, and we reserve the right to discuss with you why we might not comply with a request from you to exercise them.
For recipients of this notice in the UK, further guidance on your rights is available from the Information Commissioner’s Office (https://.ico.org.uk/). You have the right to complain to the UK’s supervisory office for data protection, the Information Commissioner’s Office at https://ico.org.uk/concerns/ if you believe that your data has been processed unlawfully. Recipients in other countries should seek guidance from the relevant body in their jurisdiction.
If you believe that we have not complied with any of our obligations under applicable data protection laws, please let us know. Nothing in this privacy notice affects any rights you may otherwise have under applicable law or regulation.