Privacy Statement

Privacy statement of Complinet Group Ltd

1. Why do we have a privacy statement?

At Complinet we respect your privacy and this privacy statement sets out the data processing practices carried out through the use of the internet and any other electronic communications networks by Complinet Group Ltd. You should read it in conjunction with our terms and conditions, of which this statement forms part.

This privacy policy relates to the products and services we provide and in particular, to visitors who register at www.complinet.com, the web site of Complinet Group Ltd and its subsidiary companies, the details of which are:
- Client Support
  
  Complinet Inc
  
  1250 Broadway
  
  Suite 1902
  
  New York
  
  NY 10001
  
  USA
  
  Tel: 646-289-6270
- Client Support
  
  Complinet Group Ltd
  
  Third Floor
  
  Vintners' Place
  
  68 Upper Thames Street
  
  London
  
  EC4V 3BJ
  
  UK
  
  Tel: +44 (0)870-042-6400
- Client Support
  
  Complinet Ltd
  
  Third Floor
  
  Vintners' Place
  
  68 Upper Thames Street
  
  London
  
  EC4V 3BJ
  
  UK
  
  Tel: +44 (0)870-042-6400
If you have questions or concerns regarding this statement, please contact our client support team who will endeavour to help.
2. What information do we collect about you?

When you register at www.complinet.com or use our services, you volunteer the following information:
2.1 Personal data
This data includes your name, address, email address, telephone and fax numbers. If you use our training, software or consultancy services, we might also collect details of your education and skills.
2.2 Online Identifiers
This data includes your domain name and IP address, operating system, browser version, the web site that you visited prior to our site and unique number identifiers that are automatically generated by our systems when you visit our site.
2.3 Your personal Complinet preferences
This data includes details of the choices you made when indicating whether you wished to receive information on other products and services.
3. Message boards

Many of the Complinet products have message boards where registered visitors can communicate with each other on a named or anonymous basis.

If you choose to communicate with others on a named basis, you acknowledge that other visitors may collect your data. As indicated in our terms and conditions, we reserve the right to review and monitor comments posted on our message boards from time to time and delete any messages or text which we, in our sole discretion, decide are inappropriate. We reserve the right to identify you in response to a court order or threat of legal action.
4. Why do we collect information about you?

We collect information about you for the following purposes:
4.1 Technical administration of the web site
To ensure that the online products and services that you have chosen to receive are delivered to you in the most effective way.
4.2 Customer administration
To ensure that we maintain the highest levels of customer service when providing you with our products and services that you have chosen to receive.
4.3 Research and development
To develop new and improve existing Complinet products and services, which we believe may be of interest to you.
4.4 Marketing
To provide you with details of other Complinet products and services, which we believe may be of interest to you and to provide you with details of products and services offered by third parties, which we believe may be of interest to you. Our most common marketing method is via email but we may also use other methods including traditional mailing and text messaging. Third parties may also use any of these methods of marketing to let you know about their products. By providing your contact details to us, you indicate your willingness to receive information (about Complinet products and services (and those of third parties) by e-mail, text message and by other methods of marketing including postal mail. You can ask to 'opt out' of such marketing at any time.

If we were to use your personal data for a new purpose, we would offer you the means to consent to this new purpose by indicating so in a box at the point on the site where personal data is collected.
5. How do we collect your information?

We collect information about you in a number of ways:
5.1 Automatic programming
When you register at www.complinet.com and move from page to page within our site, the information you provide is automatically stored in our electronic files.
5.2 Cookies
A cookie is a very small text file placed on your hard drive by a web page server. It works like an identification card whose purpose is to tell the server that you have already been to that web page before and are now returning. A cookie cannot be executed as code or deliver viruses. It can only be read by the server that gave it to you and is unique to your computer. It is not recommended that you activate cookies to be stored for web pages, which may include sensitive or personal information about yourself if you constantly move workstation.

Cookies are useful because they save you time by remembering usernames and passwords. Cookies also enable predictive text in the location box. For example, if you begin to write Complinet's web address, by the time you have typed in www.co, your browser location box will probably be offering you www.complinet.com without having to key in further characters.If you personalise pages, or register for products or services, a cookie helps us remember who you are, so that next time you return, we know to show you the information you requested. Or, when you register for another product or service, all you need to do is type in your e-mail address and a password.

We can then fill in any questions you've already answered. You can switch off cookies by changing your browser settings (but this may affect your use of the Complinet web site). If you want help in doing this, please contact client support who will be happy to talk you through the process or alternatively, please visit the 'Help' menu on your browser.
5.3 Telephone
If we speak to you by telephone we will ask your permission to retain the information you provide in our client database (electronic files).
5.4 Research
We may find out information about you through research. For example, you may have consented to have some of your details appear in literature and directories or on the web site of your employers in order to promote their goods and services.

In the course of undertaking the activities specified in this privacy statement, we might transfer the data we collect about you outside the European Economic Area to countries that do not have data protection laws or to countries where your privacy and other fundamental rights may not be protected as extensively as in the UK.

For example, we might transfer your data to Complinet Inc, our subsidiary in the USA. By accepting Complinet's terms and conditions you acknowledge and agree to the transfer of your data on an international basis for the purposes set out in this privacy statement.
6. Does Complinet disclose personal data to other parties?

We may disclose your personal data to our subsidiaries (Complinet Ltd and Complinet Inc) and to other organizations (such as other service providers to the financial services industry), successors in title to our business and suppliers that process data on our behalf.

Where we disclose your personal data for commercial purposes, we provide you with the means to either opt-in or opt-out of the disclosure by:
- Indicating your preference in a box at the point where personal data is collected
- Sending an email to clientsupport@complinet.com
- Sending postal mail to Complinet Inc, 1250 Broadway, Suite 1902, New York, NY 10001, USA or to Complinet Ltd, 86-88 Upper Richmond Road, London, SW15 2ST, UK
- Telephoning us at the US office on: +1 212-758-7000 or the UK office on +44 (0)20-8246-4100
- Directing you to a web page where you can change your personal preferences
We will not disclose your personal data to any other third parties unless we are required to do so by law.
7. What methods of confidentiality and security does Complinet deploy?

We give you the option of using a secure transmission method to send us the following types of personal data:
- Primary personal data (such as name and contact details)
- Business information (such as your employer's name, address and your job title)
- Identifiers (such as credit card details, web site password)
We have implemented security policies, rules and technical measures to protect the personal data that we have under our control from:
- Unauthorized access
- Improper use or disclosure
- Unauthorized modification
- Unlawful destruction or accidental loss
All our employees and data processors that have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of our visitors' personal data.
8. Hyperlinks within our web site

Our web site includes links to many third party web service providers including associations, bodies and non-governmental organizations.

These links are provided to give Complinet visitors access to as much information as possible; however, Complinet is not responsible for the accuracy or efficacy of any of the information or data policies and procedures contained within these third party web sites. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours.
9. Can you access the personal data we hold about you?

You can ask us whether we are keeping personal data about you by:

Sending an email to: clientsupport@complinet.com

or

Sending postal mail to:
- Client Support
  
  Complinet Inc
  
  1250 Broadway
  
  Suite 1902
  
  New York
  
  NY 10001
  
  USA
  
  Tel: 646-289-6270
- Client Support
  
  Complinet Group Ltd
  
  Third Floor
  
  Vintners' Place
  
  68 Upper Thames Street
  
  London
  
  EC4V 3BJ
  
  UK
  
  Tel: +44 (0)870-042-6400
- Client Support
  
  Complinet Ltd
  
  Third Floor
  
  Vintners' Place
  
  68 Upper Thames Street
  
  London
  
  EC4V 3BJ
  
  UK
  
  Tel: +44 (0)870-042-6400
We will provide you with a readable copy of the personal data, which we keep about you within 40 days; however, we may require proof of your identity and apply an administration charge of £10 before disclosing your personal data to you.
10. What can you do if you have more questions about our privacy policy?

If you have an enquiry or concern about our privacy policy, in the first instance please contact:
- Client Support Manager
  
  Complinet Inc
  
  1250 Broadway
  
  Suite 1902
  
  New York
  
  NY 10001
  
  USA
  
  Tel: 646-289-6270
- Client Support Manager
  
  Complinet Group Ltd
  
  Third Floor
  
  Vintners' Place
  
  68 Upper Thames Street
  
  London
  
  EC4V 3BJ
  
  UK
  
  Tel: +44 (0)870-042-6400
If, after discussing your enquiry or concern with the Client Support manager, you are not satisfied with the response, your request will be escalated to:

Company Secretary

Complinet Group Ltd

Third Floor

Vintners' Place

68 Upper Thames Street

London

EC4V 3BJ

UK

Tel: +44 (0)870-042-6400

If, after discussing your enquiry or concern with the company secretary, you are still not satisfied with the response, you may wish to contact:

The Information Commissioner

Wycliffe House,

Water Lane,

Wilmslow,

Cheshire

SK9 5AF

UK

www.informationcommissioner.gov.uk