Clocktower Group, L.P. and/or any of its affiliates (together and/or separately, as the context may require, “Clocktower” or “we” or “us”) may collect and process certain personal data about you (i.e., information that identifies you).
This privacy notice sets out the basis on which personal data about you will be processed by Clocktower. If you are dealing with Clocktower (i) in a capacity of an officer, employee, director, contractor, agent or principal of (a) a past or prospective client of Clocktower or investor in a fund managed by Clocktower, (b) a counterparty of Clocktower or a fund managed by Clocktower; or (c) a service provider; (ii) as a director of any of Clocktower fund; or (iii) as an individual interested in a career at Clocktower, please take the time to read and understand this privacy notice.
Personal Data that We Collect About You
Clocktower may collect and process some or all of the following personal data about you which you provide to us by filling in forms or by communicating with us, whether face-to-face, by phone, in writing or by e-mail or which we otherwise collect in the course of our interactions.
Information that you may provide to us:
- your personal details - your full name, gender, date of birth, nationality, occupation and your signature
- your contact details – email address, place of work, telephone number, current and/or previous work and/or home address
- identification documents - passport, national identity card, driving license, copy of your visa, photograph and government-issued personal identifiers such as National Insurance Number or social security number
- education and qualification details – your current and past job positions, employment history, previous employer references, conduct history (civil and criminal), education and certifications
- financial information - bank account details, personal account dealing information, utility bills, bank statements or mortgage statements
- investment information - source of funds, investment experience and objectives, risk tolerance, representation required under the applicable law or regulations
- other personal information that you provide to us, including health information, marital status, personal details relating to your immediate family members
Information we collect or generate about you:
- personal data that we collect through your use of our web-site or email system
- information obtained in the course of our business activities
- search results of the records of regulators (e.g., US Internal Revenue Service, UK Financial Conduct) Authority records, recruitment and screening agencies and social media searches
- information obtained as part of due diligence, know-your-customer and related process
- technical information collected via our web-site about the services you use and how you use them
Some of the above information (such as biometric data, civil and criminal conduct history, health information, political affiliations) is categorized as sensitive personal data. As with any personal data, we will only collect and process sensitive information where we have a legal basis for such collection and processing, including where required or permitted under applicable law or where we have your consent (where we are legally required to do so).
You are not required to supply any of the personal data that we request. However, failure to supply any of the personal data that we request may result in our being unable to provide services to you or your company, discuss any business opportunities with you or deal with other matters.
Uses of Your Personal Data
Your personal data may be stored and processed by us for the following purposes:
- to meet our legal obligations owed to you and to perform our obligations and exercise our rights under our contract with you, or the relevant counterparty, if different;
- to conduct KYC and background screening checks to verify information provided by you for due diligence purposes or in order to confirm your suitability for any future recruitment, appointment as a service provider or admission as a preferred counterparty;
- to comply with legal, regulatory or self-regulatory practices and industry standards or procedures which relate to our business;
- to contact you about services and products we offer;
- to allow you secure access to our web-site and to prevent any potential disruption or cyberattack;
- for statistical monitoring of our web-site trafficking;
- for the management and administration of our business.
Clocktower is entitled to process your personal data in these ways for the following reasons:
- to discharge our legal and regulatory obligations
- to perform our obligations and exercise our rights in connection with a contract between us, or with a relevant counterparty
for the legitimate business interests of Clocktower, such as:
- allowing us to effectively and efficiently administer and manage the operation of our business
- to establish, exercise or defend our legal rights or for the purpose of legal proceedings
- maintaining compliance with all legal and regulatory obligations, industry standards, internal policies
- in respect of any processing of sensitive personal data falling within special categories, if there is a legislative justification for its processing
Disclosure of Your Information to Third Parties
We may share your personal data within the Clocktower group for the purposes of: (i) management and administration of our business, (ii) complying with the functions that each of the entities may perform, (iii) regional or global investor relations or HR activities (iv) assessing compliance with applicable laws, rules and regulations, internal policies and procedures across our business and (v) enabling adequate communication with you.
Clocktower may from time to time, in connection with the purposes described in the previous section, disclose your personal data to third parties outside of the Clocktower group, including (i) third parties that process your personal data on our behalf; (ii) professional advisers such as law firms, auditors, and accountancy firms, (ii) recruitment consultants, travel agents, payments, technology and communication service providers, (iii) counterparties and (iv) courts and regulatory, tax and governmental authorities.
Clocktower will make reasonable efforts to ensure that your personal data is accessed by the Clocktower group’s staff and third parties on a need-to-know basis and subject to general confidentiality arrangements.
Protecting Your Personal Data
We are committed to safeguarding and protecting your personal data and we maintain appropriate security measures to protect your personal data from improper, unauthorized, unlawful or accidental disclosure, destruction, alteration, use, access, loss or damage.
Retention of Personal Data
How long Clocktower holds personal data for will vary. The retention period will be determined by various criteria, including the purposes for which Clocktower is using it and legal obligations (as laws or regulations may set a minimum period for which Clocktower has to keep your personal data).
U.S. natural persons:
To the extent you are a U.S. natural person, U.S. federal law gives you the right to limit: (i) Clocktower’s sharing of your personal data with our affiliates for their everyday business purposes if such information concerns your creditworthiness, (ii) Clocktower from using your personal data to market to you, and (iii) Clocktower sharing of your personal data with non-affiliates to market to you. State laws and individual companies may give you additional rights to limit sharing. To protect your personal data, we permit access only by authorized employees who need access to that information in order to perform their jobs. To protect your personal data from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
E.U. natural persons:
Your personal data may be transferred to and stored by persons outside of the European Economic Area (the “EEA”), and in particular may be transferred to and stored by individuals operating outside of the EEA who work for a non-EEA Clocktower group entity or a third party.
Where personal data is transferred outside of the EEA, Clocktower will ensure that the transfer is subject to appropriate safeguards or is otherwise permitted under applicable law. For example, the country to which the personal data is transferred may be approved by the European Commission, the recipient may have agreed to model contractual clauses approved by the European Commission that oblige them to protect the personal data, or the recipient may be located in the United States and be a certified member of the EU-US Privacy Shield scheme.
Pursuant to Regulation (EU) 2016/679 (General Data Protection Regulation), you have a number of legal rights in relation to the personal data that we hold about you. 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
- where you have actively provided your consent for us to process your personal data, the right to withdraw your consent at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so
- 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 to us
- the right to request that we rectify your personal data if it is inaccurate or incomplete
- the right to request that we erase, or restrict our processing of, your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase, or restrict our processing of, your personal data but we are legally entitled to retain it or to refuse that request
- the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us
You can find out more information about your rights at the European Commission’s website, https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en , or by contacting the UK’s Information Commissioner’s Office or searching their website at https://ico.org.uk/.
Updates to this Privacy Notice
We may change or update portions of this privacy notice to reflect changes in our practices and or applicable law and regulation. Please check this privacy notice from time to time so you are aware of any changes or updates. Where required under applicable data protection and privacy laws, we will notify you of any change or update portions of this privacy notice by individual message or by disclosing the changes to the data processing on a publicly available medium.