INFORMATION WE COLLECT
You may use our Site without disclosing to us any personally identifiable information, such as your name, address, email address, phone number, and certain other information. We collect personally identifiable information about you only if you choose to provide it to us.
Although our web server does log certain technical information automatically, such as the identity of your Internet Service Provider and your computer’s IP address, none of this technical information reveals your identity to us, and it is not associated with any personally identifiable information you may choose to provide.
Marwood may also collect certain personally identifiable information about you, such as your name, address, email address and phone number, when you communicate with us in person, over the phone, through email or otherwise.
USE AND DISCLOSURE OF INFORMATION
Marwood uses personal information: (i) to maintain contact lists for the purposes of sharing our latest notes, analyses and publications, inviting you to join events and conference calls, and advising on policy updates; (ii) to provide goods and services and deliver invoices to clients pursuant to executed agreements; (iii) to communicate with and respond to requests, inquiries and complaints from current and prospective clients; (iv) to process payments; (v) to collect data that analyzes how current and prospective clients interact with our products and services; (vi) to comply with applicable laws and regulations and Marwood’s internal policies and procedures; and (vii) for any other relevant purposes relating to Marwood’s business.
We do not disclose, share or sell any user or personally identifiable information gathered on our Site or collected by Marwood in any other manner with third parties for their marketing purposes, but we may use third-party software and services to assist us with collecting, storing and analyzing information for Marwood’s purposes listed above. Third-party services include data analytics on how current and prospective clients engage with our marketing and our products and services based on tracking technology that records, on an individual and aggregated basis, email delivery status, email open rates, the products clicked on and the number of times such products are accessed, and geographic location. Third-party service providers utilized by Marwood agree not to disclose or sell any personally identifiable information without Marwood’s permission, or to use such information for any purpose other than its intended purposes.
We may disclose your personally identifiable information if we reasonably believe, in our sole discretion, we are required by applicable law, regulation, legal process or governmental request to do so.
OUR LEGAL BASIS FOR PROCESSING DATA
Depending on the purposes for which Marwood uses your personal information, we may collect and process your personal information pursuant to each of the following legal bases described in Article 6 of the GDPR:
1) Legitimate Interests: We have a legitimate interest in: (i) marketing, promoting and sharing our products and services that may be of interest to you; (ii) developing, supporting and improving our business, including expanding our client base; and (iii) communicating with prospective and current clients to address and respond to any requests, inquiries and complaints; provided that such interests are not overridden by your interests or fundamental rights and freedoms.
2) Contract Performance: We must perform our contractual obligations to clients, including, but not limited to, providing products and services, delivering invoices, and processing payments.
3) Consent: You have expressly given us consent to process your personal information for one or more specific purposes, in which case you may withdraw such consent at any time. Withdrawing your consent does not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
4) Legal Obligations: We must comply with laws, regulators, court orders, or other legal obligations, or pursuant to legal process.
Marwood aims to retain your personal information for only as long as it is necessary for us to do so for the purposes for which we are using it and in line with our internal policies and procedures. In some circumstances, it may be necessary to keep your information for a longer time period for purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal information, Marwood considers the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
YOUR RIGHTS UNDER THE GDPR
The GDPR sets forth a number of rights that you may exercise with respect to the processing of your personal information, subject to certain limitations and exceptions, which include, but are not necessarily limited to:
1) Right of access: You have the right to confirm whether your personal information is being processed, to receive information about that processing and to have a copy of the personal information provided to you.
2) Right to rectification: You may correct or revise any of your personal information that is incorrect or incomplete.
3) Right to erasure/Right to be forgotten: Under certain circumstances, you may request the deletion or removal of your personal information.
4) Right to restrict processing: Under certain circumstances, you may request limited use of your personal information.
5) Right of portability: Under certain circumstances, you may receive your personal information in a structured, commonly used and machine-readable format.
6) Right to object: You may object to your personal information being used for direct marketing or certain other purposes.
CHANGES TO THIS POLICY
LINKS TO OTHER WEBSITES
Marwood will take reasonable steps to protect personal information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. Marwood has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information from loss, misuse, unauthorized access or disclosure, alteration, or destruction. Please do not disclose any private or confidential information to us via email or this Site. Third-party service providers utilized by Marwood are also required to employ reasonable industry-recognized technical, administrative and physical safeguards, such as firewalls, to protect the confidentiality and security of your personal information, and to adopt and implement security procedures to protect your information from loss, misuse or unauthorized alteration. Marwood cannot guarantee the security of information on or transmitted via the Internet.
Marwood will only process personal information in a way that is compatible with and relevant to the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Marwood will take reasonable steps to ensure that personal information is accurate, complete, current, and reliable for its intended use.
You also have the right to lodge a complaint with your national data protection supervisory authority at any time if you believe that Marwood is using your information in a way that breaches data protection law, including the GDPR. The United Kingdom supervisory authority for data protection issues is the Information Commissioner’s Office.