This Privacy Policy explains how we use the Personal Data that Creeksquare Capital collects or generates in relation to our Website and interactions with individuals and third parties.
BACKGROUND
We do not collect Personal Data, such as names and addresses, when you visit our Website. Should you decide to send us any Personal Data, for example if you apply for an open role at Creeksquare Capital or via email or other communications with us, we will collect and use such Personal Data in accordance with this Privacy Policy. Creeksquare Capital is responsible for ensuring that it uses that Personal Data in compliance with data protection laws. We also collect some limited Personal Data through other means, for example from publicly available sources, third parties and through CCTV at our premises.
At Creeksquare Capital, we respect privacy and we are committed to keeping all your Personal Data secure. This Privacy Policy governs the handling of Personal Data by Creeksquare Capital in connection with our Website and other interactions and communications with us.
We use the following definitions in this Privacy Policy:
“Personal Data” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with, directly or indirectly, a particular living individual or household of living individuals and other personal information which is in the possession of, or is likely to come into the possession of, Creeksquare Capital. In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Creeksquare Capital or any other person in respect of an individual.
“Creeksquare Capital”, “we” or “us” means Creeksquare Capital and each other legal entity within the Creeksquare Capital group. A full list of the entities of the Creeksquare Capital group that process your Personal Data can be obtained by contacting us using the information set out in section below.
“Website” means www.creeksquarecapital.com.
THE TYPES OF PERSONAL DATA WE COLLECT
In relation to the use of our Website and other communications and interactions with us, we may collect and process the following Personal Data about you:
- Information that you provide to Creeksquare Capital. This includes information about you that you give to us by filling in forms or by communicating with us, whether face-to-face, by phone, e-mail or otherwise. Such information may include (by way of a non-exhaustive list):
- your name, postal address, e-mail address, telephone number, educational background, employment history, any other information contained within your resume and business contact details; and
- records and copies of your correspondence with us, if you contact us.
- Information that we collect or generate about you. This includes (by way of non-exhaustive list):
- a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the responses which we have provided to you;
- a record of your application for a position with Creeksquare Capital, if you submit such an application via our Website;
- certain information that is provided by the cookies that we use;
- details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website;
- information about your computer and internet connection, including your IP address, operating system, browser type, etc.;
- telephone recordings in limited instances;
- CCTV footage if you visit our premises; and
- other information you or others may provide to us during your communications or relationship with us.
- Information we obtain from other sources. This includes limited publicly available information we collect directly or indirectly. We also collect some data from third party vendors.
- Anonymized data. In addition to the categories of Personal Data described above, Creeksquare Capital may also process anonymized information and data that is not processed by reference to a specific individual.
HOW WE USE YOUR INFORMATION
Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
- to allow you to use and access the functionality provided by the Website;
- to consider you for a position at Creeksquare Capital, if you have contacted us to apply for such a position;
- in order to respond to your queries and to provide you with Creeksquare Capital products and/or services or information about them upon your request;
- for in-depth threat analysis;
- for in-depth statistical report about Website usage;
- in order to comply with, and in order to assess compliance with, applicable laws, rules and regulations;
- for security purposes in relation to CCTV;
- for regulatory and internal obligations related to telephone conversations;
- for business analysis and development of products and services;
- for the administration and maintenance of databases storing Personal Data; or
- for our general operational or business purposes.
We use Personal Data for a variety of reasons. These include:
- we may need to do so in order to perform our contractual obligations with customers and other third parties;
- we may have legal and regulatory obligations that we have to discharge;
- we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
- the use of your Personal Data as described may be necessary for our legitimate business interests, such as allowing us to effectively and efficiently manage and administer the operation of our business (including our Website);
- monitoring the use of our copyrighted materials;
- monitoring Website usage;
- responding to correspondence that we receive via our Website;
- enabling quick and easy access to information on Creeksquare Capital products and services; and
- maintaining the security of our networks and IT systems and physical premises.
We collect and process personal data about our suppliers, vendors (including trading counterparties) and their representatives in order to manage the relationships, the related contracts, and to receive services from them.
We take steps to ensure that the Personal Data is accessed only by employees of Creeksquare Capital that have a need to do so for the purposes described in this Privacy Policy.
DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
We may share your Personal Data within the Creeksquare Capital group for the purposes described above.
We may also share your Personal Data outside of the Creeksquare Capital group for the following purposes:
- with our business partners. For example, this could include our partners from whom you or your company or organisation purchased Creeksquare Capital products or services. We take steps to ensure that Personal Data is only transferred to business partners that are contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
- with third party agents and contractors for the purposes of providing services to us (for example, Creeksquare Capital’s professional advisors, and IT and communications providers). We take steps to ensure these third parties are contractually obliged to comply with appropriate data protection obligations and to only use your Personal Data as described in this Privacy Policy;
- to the extent compelled by law, for example, if we are under a duty to disclose your Personal Data in order to comply with any legal obligation, or to establish, exercise or defend our legal rights;
- police and law enforcement in the event of a security or other investigation that necessitates their involvement;
- if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
- if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer.
INTERNATIONAL TRANSFERS OF PERSONAL DATA
Creeksquare Capital is a global business. Our customers and our operations are spread around the world. As a result, we collect and transfer Personal Data on a global basis. The personal data that we collect from you may be transferred to, and stored at, a destination outside the jurisdiction(s) in which you, or we, are located. In all cases, we will ensure that any collection, use, and/or transfer of your personal data is compliant with applicable data protection law.
HOW WE SAFEGUARD YOUR INFORMATION
We have certain controls in place designed to maintain the security of our information and information systems, including controls designed to protect Personal Data with safeguards according to the sensitivity of the relevant information and controls (such as restricted access) placed on our computer systems. We take steps to ensure physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.
As a condition of employment, Creeksquare Capital employees are required to follow all applicable laws and regulations, including in relation to data protection. We take steps to ensure access to Personal Data is limited to those employees who need it to perform their roles. Unauthorised use or disclosure of confidential client information by a Creeksquare Capital employee is prohibited and may result in disciplinary measures.
When you contact a Creeksquare Capital employee about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
HOW LONG WE KEEP YOUR PERSONAL DATA
How long we will hold your Personal Data for will vary and will be determined by the following criteria:
- the purpose for which we are using it – Creeksquare Capital will need to keep the data for as long as is necessary for that purpose; and
- legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
YOUR RIGHTS
In certain of the above cases in which we collect, use or store your Personal Data, you may have specific rights with respect to our collection, use, or storage and, in most cases, you can exercise them free of charge. 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;
- the right to withdraw your consent to our processing of your personal data at any time. Please note that we may still be entitled to process your personal data if we have another lawful basis to do so;
- in some circumstances, the right to receive some personal data in a structured format and/or request that we transmit that data to a third party. 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 your personal data in certain circumstances. Please note that we may be legally entitled to retain it in some instances;
- the right to object to, and the right to request that we restrict, our processing of your personal data in certain circumstances. Please note that there may be circumstances where we are legally entitled to continue processing your personal data; and
- the right to lodge a complaint with the applicable data protection regulator if you think that any of your rights have been infringed by us.
You can exercise your rights by contacting us. We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our privacy officer, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, Creeksquare Capital will provide you with the contact information for that regulator.
