Background This   Privacy   Notice   sets   forth   how   Conrad   Family   Office   and   its   affiliates,   together   Controllers   (referred   to   collectively   as   “Conrad   Family   Office”   “we”,   “us”   or “our”), collect and process certain Personal Data. “Personal   Data”   means   any   data   which   relates   to   a   living   individual   who   can   be   identified   from   that   data   or   from   that   data   and   other   information   which   is   in the   possession   of,   or   is   likely   to   come   into   the   possession   of,   Conrad   Family   Office   (or   its   representatives   or   service   providers).   In   addition   to   factual information,   it   includes   any   expression   of   opinion   about   an   individual   and   any   indication   of   the   intentions   of   Conrad   Family   Office   or   any   other   person   in respect of an individual. Conrad   Family   Office   is   responsible   for   ensuring   that   it   uses   Personal   Data   in   compliance   with   data   protection   laws.   We   respect   the   privacy   of   individuals and we are committed to keeping Personal Data secure. This Privacy Notice applies to non-public personal information of individuals outside our organisation with whom we interact, including but not limited to: current, prospective and former investors and clients (collectively, “Investors”) and their personnel; visitors to our website; vendors and service providers; and visitors to our offices. These   policies   may   be   changed   at   any   time.   Changes   will   be   effective   immediately   upon   posting   onto   our   Website   for   internet   users   or   provided   to   you   if visiting our offices. Your information This   Privacy   Notice   concerns   the   following   categories   of   information   that   we   collect   about   you   when   providing   our   products   and   services   (together,   the “services”) and includes information we receive through our Website. Many   of   the   services   offered   by   Conrad   Family   Office   require   us   to   obtain   Personal   Data   about   you   in   order   to   perform   the   services   we   have   been   engaged to provide. Information   that   you   provide   to   us   will   depend   upon   the   nature   of   the   services   you   are   requesting   though   such   information   may   include   basic   Personal Data (such as full name; job title; company name; company email address; business phone number; business address; city; postcode; country). Information   that   we   collect   or   generate   about   you   includes   a   file   with   your   client   records   and   contact   history   to   be   used   for   enquiry   purposes   so   that   we may ensure that you are satisfied with the services which we have provided to you; and details of site and marketing/communication preferences. Information we may obtain from other sources includes: Website This   will   include   information   such   as:   number   of   people   visiting   our   Website;   pages   visited;   features   used;   how   long   they   stay   and   the   websites   they   are connecting   from;   collected   on   an   aggregate   basis   on   public   areas   of   our   Website,   or   on   an   individual   basis   on   areas   of   our   Website   that   require   Website visitors to logon using and access code (e.g. user ID and/or password). Cookies When you visit our Website, cookies are used to collect information about the services that you use, and how you use them. Anonymised   data-In   addition   to   the   categories   of   Personal   Data   described   above,   we   may   also   process   further   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 for the following purposes: to understand your needs and interests; for the management and administration of our business including to improve the calibre of online information and services offered; to assess your application for Conrad Family Office services, where applicable; to understand feedback on Conrad Family Office services and to help provide more information on the use of the services quickly and easily; to communicate with you in order to provide you with services or information about Conrad Family Office or its services; in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; for the administration and maintenance of databases storing Personal Data; or for   ongoing   review   and   improvement   of   the   information   provided   on   our   Website   to   ensure   it   is   user   friendly   and   to   prevent   any   potential disruptions or cyber-attacks. However   when   we   use   Personal   Data   we   make   sure   that   the   usage   complies   with   the   law.   The   law   allows   us   and   requires   us   to   use   Personal   Data   for   a variety of reasons, including but not limited to the following: in order to perform our contractual obligations; where we have obtained your consent to use the information; where we have legal and regulatory obligations that we have to discharge; where 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 is necessary for our legitimate business interests, such as: – allowing us to effectively and efficiently manage and administer the operation of our business; – maintaining compliance with internal policies and procedures; – monitoring the use of our copyrighted materials; – enabling quick and easy access to information on Conrad Family Office services; and, – obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market. We   will   take   steps   to   ensure   that   the   Personal   Data   is   accessed   only   by   our   employees   that   have   a   need   to   do   so   for   the   purposes   described   in   this   Privacy Notice. Disclosure of your information to third parties We   may   share   your   Personal   Data   within   the   Conrad   Family   Office   for   the   purposes   described   above.   We   may   also   share   your   Personal   Data   outside   of   the Conrad Family Office for the following purposes: with   our   affiliated   companies   or   other   trusted   businesses   or   persons   for   the   purpose   of   processing   personal   data   on   our   behalf   for   the   above   stated purposes; with   our   business   partners.   Personal   Data   will   only   be   transferred   to   a   business   partner   who   is   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,   our   accountants,   professional   advisors,   IT   and communications   providers).   These   third   parties   will   be   subject   to   appropriate   data   protection   obligations   and   they   will   only   use   your   Personal   Data   as described in this Privacy Notice; to   the   extent   required   by   law,   for   example   if   we   are   under   a   duty   to   disclose   your   Personal   Data   in   order   to   comply   with   any   legal   obligation (including,   without   limitation,   in   order   to   comply   with   tax   reporting   requirements   and   disclosures   to   regulators),   or   to   establish,   exercise   or   defend   its legal rights; and if   we   sell   our   business   or   assets   or   are   acquired   by   a   third   party,   in   which   case   we   may   need   to   disclose   your   Personal   Data   to   the   prospective   buyer for due diligence purposes. International transfers of personal data Conrad   Family   Office   is   a   global   business   with   customers   and   operations   spread   around   the   world.   As   a   result   we   may   collect   and   transfer   Personal   Data   on a global basis. That means that we may transfer your Personal Data to locations outside of your country. Where   we   transfer   your   Personal   Data   to   a   country   outside   the   EEA,   we   will   ensure   that   it   is   protected   and   transferred   in   a   manner   consistent   with European legal requirements. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways: the   country   might   be   approved   by   the   European   Commission   as   offering   an   adequate   level   of   protection   for   Personal   Data   (e.g.   Israel   is   an   approved country); the   recipient   might   have   signed   up   to   a   contract   based   on   “model   contractual   clauses”   approved   by   the   European   Commission,   obliging   them   to protect your Personal Data; where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or in other circumstances where the law may permit us to otherwise transfer your Personal Data outside Europe. You   can   obtain   more   details   of   the   protection   given   to   your   Personal   Data   when   it   is   transferred   outside   Europe   (including   a   copy   of   the   standard   data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described below. Security standards – how we safeguard your information We   work   hard   to   ensure   that   our   systems   are   secure   and   that   they   meet   industry   standards.   Where   appropriate,   we   employ   firewalls,   encryption technology,   user   authentications   systems   (e.g.   passwords   and   personal   identification   numbers)   to   control   access   to   systems   and   data.   We   will   continue   to assess new technology to evaluate its ability to provide additional protection for your Personal Data. Access   to   our   computer   systems   is   controlled   and   restricted.   Physical   access   to   areas   where   Personal   Data   is   gathered,   processed   or   stored   is   limited   to authorised employees. As   a   condition   of   employment,   Conrad   Family   Office   staff   are   required   to   follow   all   applicable   laws   and   regulations,   including   in   relation   to   data   protection law.   Unauthorised   use   or   disclosure   of   confidential   client   information   by   a   Conrad   Family   Office   employee   is   prohibited   and   may   result   in   disciplinary measures. How long we keep your personal data The length of time we will hold your Personal Data will vary and will depend on: the purpose for which we are using it – we 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   all   the   above   cases   in   which   we   collect,   use   or   store   your   Personal   Data,   you   may   have   the   following   rights   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   the   processing   of   your   Personal   Data   at   any   time.   Please   note,   however,   that   we   may   still   be   entitled   to   process your   Personal   Data   if   we   have   another   legitimate   reason   for   doing   so.   For   example,   we   may   need   to   retain   Personal   Data   to   comply   with   a   legal obligation; 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   that   data   to   a   third-party   where   this   is   technically   feasible.   Please   note   that   this   right   only   applies   to   Personal   Data   which   you   have provided directly to Conrad Family Office; 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   there   may   be   circumstances   where   you   ask   us   to erase your Personal Data but we are legally entitled to retain it; the   right   to   object   to,   or   request   that   we   restrict,   our   processing   of   your   Personal   Data   in   certain   circumstances.   Again,   there   may   be   circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us. You can exercise your rights by contacting us using the details listed below. Use of Cookies A   cookie   is   a   small   piece   of   information   that   an   Internet   site   sends   to   a   website   visitor’s   computer.   In   some   cases,   it   is   stored   on   the   visitor’s   computer’s hard   drive.   Cookies   can   save   the   visitor’s   name,   password,   user-name,   screen   preferences   and   the   pages   of   the   site   viewed   by   the   visitor.   Visitors   may decline   the   Internet   cookie   by   using   the   appropriate   feature   of   their   Web   software,   if   available.   Declining   the   Internet   cookie   may,   however,   interfere   with   a visitor’s ability to view certain content is this web site. Contact Us It   is   important   to   us   at   Conrad   Family   Office   to   hear   what   visitors   have   to   say   about   our   Website   or   our   services.   If   you   have   any   questions   and/or   concerns for instance about the handling of your Personal Data, or want to let us know what you think, please contact us by Email at: data@conradfamilyoffice.com Address: Conrad Family Office 34 Queen Anne Street London W1G 8HE We   are   usually   able   to   resolve   privacy   questions   or   concerns   promptly   and   effectively.   If   you   are   not   satisfied   with   the   response   you   receive,   you   may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.
Background This   Privacy   Notice   sets   forth   how   Conrad   Family   Office   and   its   affiliates, together   Controllers   (referred   to   collectively   as   “Conrad   Family   Office”   “we”, “us” or “our”), collect and process certain Personal Data. “Personal   Data”   means   any   data   which   relates   to   a   living   individual   who   can be   identified   from   that   data   or   from   that   data   and   other   information   which is   in   the   possession   of,   or   is   likely   to   come   into   the   possession   of,   Conrad Family   Office   (or   its   representatives   or   service   providers).   In   addition   to factual    information,    it    includes    any    expression    of    opinion    about    an individual   and   any   indication   of   the   intentions   of   Conrad   Family   Office   or any other person in respect of an individual. Conrad   Family   Office   is   responsible   for   ensuring   that   it   uses   Personal   Data in    compliance    with    data    protection    laws.    We    respect    the    privacy    of individuals and we are committed to keeping Personal Data secure. This     Privacy     Notice     applies     to     non-public     personal     information     of individuals   outside   our   organisation   with   whom   we   interact,   including   but not limited to: current,    prospective    and    former    investors    and    clients    (collectively, “Investors”) and their personnel; visitors to our website; vendors and service providers; and visitors to our offices. These    policies    may    be    changed    at    any    time.    Changes    will    be    effective immediately   upon   posting   onto   our   Website   for   internet   users   or   provided to you if visiting our offices. Your information This   Privacy   Notice   concerns   the   following   categories   of   information   that   we collect   about   you   when   providing   our   products   and   services   (together,   the “services”) and includes information we receive through our Website. Many   of   the   services   offered   by   Conrad   Family   Office   require   us   to   obtain Personal   Data   about   you   in   order   to   perform   the   services   we   have   been engaged to provide. Information   that   you   provide   to   us   will   depend   upon   the   nature   of   the services   you   are   requesting   though   such   information   may   include   basic Personal   Data   (such   as   full   name;   job   title;   company   name;   company   email address;     business     phone     number;     business     address;     city;     postcode; country). Information   that   we   collect   or   generate   about   you   includes   a   file   with   your client   records   and   contact   history   to   be   used   for   enquiry   purposes   so   that we    may    ensure    that    you    are    satisfied    with    the    services    which    we    have provided     to     you;     and     details     of     site     and     marketing/communication preferences. Information we may obtain from other sources includes: Website This    will    include    information    such    as:    number    of    people    visiting    our Website;   pages   visited;   features   used;   how   long   they   stay   and   the   websites they   are   connecting   from;   collected   on   an   aggregate   basis   on   public   areas   of our   Website,   or   on   an   individual   basis   on   areas   of   our   Website   that   require Website    visitors    to    logon    using    and    access    code    (e.g.    user    ID    and/or password). Cookies When   you   visit   our   Website,   cookies   are   used   to   collect   information   about the services that you use, and how you use them. Anonymised   data-In   addition   to   the   categories   of   Personal   Data   described above,   we   may   also   process   further   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   for   the   following purposes: to understand your needs and interests; for   the   management   and   administration   of   our   business   including   to improve the calibre of online information and services offered; to   assess   your   application   for   Conrad   Family   Office   services,   where applicable; to   understand   feedback   on   Conrad   Family   Office   services   and   to   help provide    more    information    on    the    use    of    the    services    quickly    and easily; to   communicate   with   you   in   order   to   provide   you   with   services   or information about Conrad Family Office or its services; in    order    to    comply    with    and    in    order    to    assess    compliance    with applicable    laws,    rules    and    regulations,    and    internal    policies    and procedures; for     the     administration     and     maintenance     of     databases     storing Personal Data; or for   ongoing   review   and   improvement   of   the   information   provided   on our   Website   to   ensure   it   is   user   friendly   and   to   prevent   any   potential disruptions or cyber-attacks. However   when   we   use   Personal   Data   we   make   sure   that   the   usage   complies with   the   law.   The   law   allows   us   and   requires   us   to   use   Personal   Data   for   a variety of reasons, including but not limited to the following: in order to perform our contractual obligations; where we have obtained your consent to use the information; where    we    have    legal    and    regulatory    obligations    that    we    have    to discharge; where   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    is    necessary    for    our legitimate business interests, such as: –    allowing    us    to    effectively    and    efficiently    manage    and    administer    the operation of our business; – maintaining compliance with internal policies and procedures; – monitoring the use of our copyrighted materials; –   enabling   quick   and   easy   access   to   information   on   Conrad   Family   Office services; and, –   obtaining   further   knowledge   of   current   threats   to   network   security   in order to update our security solutions and provide these to the market. We   will   take   steps   to   ensure   that   the   Personal   Data   is   accessed   only   by   our employees   that   have   a   need   to   do   so   for   the   purposes   described   in   this Privacy Notice. Disclosure of your information to third parties We   may   share   your   Personal   Data   within   the   Conrad   Family   Office   for   the purposes   described   above.   We   may   also   share   your   Personal   Data   outside of the Conrad Family Office for the following purposes: with   our   affiliated   companies   or   other   trusted   businesses   or   persons for   the   purpose   of   processing   personal   data   on   our   behalf   for   the above stated purposes; with   our   business   partners.   Personal   Data   will   only   be   transferred   to a    business    partner    who    is    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,   our   accountants,   professional   advisors,   IT and   communications   providers).   These   third   parties   will   be   subject   to appropriate   data   protection   obligations   and   they   will   only   use   your Personal Data as described in this Privacy Notice; to   the   extent   required   by   law,   for   example   if   we   are   under   a   duty   to disclose    your    Personal    Data    in    order    to    comply    with    any    legal obligation   (including,   without   limitation,   in   order   to   comply   with   tax reporting   requirements   and   disclosures   to   regulators),   or   to   establish, exercise or defend its legal rights; and if   we   sell   our   business   or   assets   or   are   acquired   by   a   third   party,   in which    case    we    may    need    to    disclose    your    Personal    Data    to    the prospective buyer for due diligence purposes. International transfers of personal data Conrad   Family   Office   is   a   global   business   with   customers   and   operations spread   around   the   world.   As   a   result   we   may   collect   and   transfer   Personal Data   on   a   global   basis.   That   means   that   we   may   transfer   your   Personal   Data to locations outside of your country. Where   we   transfer   your   Personal   Data   to   a   country   outside   the   EEA,   we   will ensure   that   it   is   protected   and   transferred   in   a   manner   consistent   with European   legal   requirements.   In   relation   to   data   being   transferred   outside of Europe, for example, this may be done in one of the following ways: the    country    might    be    approved    by    the    European    Commission    as offering   an   adequate   level   of   protection   for   Personal   Data   (e.g.   Israel is an approved country); the   recipient   might   have   signed   up   to   a   contract   based   on   “model contractual   clauses”   approved   by   the   European   Commission,   obliging them to protect your Personal Data; where    the    recipient    is    located    in    the    US,    it    might    be    a    certified member of the EU-US Privacy Shield scheme; or in   other   circumstances   where   the   law   may   permit   us   to   otherwise transfer your Personal Data outside Europe. You   can   obtain   more   details   of   the   protection   given   to   your   Personal   Data when   it   is   transferred   outside   Europe   (including   a   copy   of   the   standard   data protection    clauses    which    we    have    entered    into    with    recipients    of    your Personal Data) by contacting us as described below. Security standards – how we safeguard your information We   work   hard   to   ensure   that   our   systems   are   secure   and   that   they   meet industry    standards.    Where    appropriate,    we    employ    firewalls,    encryption technology,    user    authentications    systems    (e.g.    passwords    and    personal identification    numbers)    to    control    access    to    systems    and    data.    We    will continue    to    assess    new    technology    to    evaluate    its    ability    to    provide additional protection for your Personal Data. Access   to   our   computer   systems   is   controlled   and   restricted.   Physical   access to   areas   where   Personal   Data   is   gathered,   processed   or   stored   is   limited   to authorised employees. As   a   condition   of   employment,   Conrad   Family   Office   staff   are   required   to follow    all    applicable    laws    and    regulations,    including    in    relation    to    data protection    law.    Unauthorised    use    or    disclosure    of    confidential    client information   by   a   Conrad   Family   Office   employee   is   prohibited   and   may result in disciplinary measures. How long we keep your personal data The   length   of   time   we   will   hold   your   Personal   Data   will   vary   and   will   depend on: the   purpose   for   which   we   are   using   it   –   we   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   all   the   above   cases   in   which   we   collect,   use   or   store   your   Personal   Data, you   may   have   the   following   rights   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   the   processing   of   your   Personal Data   at   any   time.   Please   note,   however,   that   we   may   still   be   entitled to   process   your   Personal   Data   if   we   have   another   legitimate   reason for   doing   so.   For   example,   we   may   need   to   retain   Personal   Data   to comply with a legal obligation; 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    that    data    to    a    third-party    where    this    is technically    feasible.    Please    note    that    this    right    only    applies    to Personal   Data   which   you   have   provided   directly   to   Conrad   Family Office; 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   there   may   be   circumstances   where you   ask   us   to   erase   your   Personal   Data   but   we   are   legally   entitled   to retain it; the   right   to   object   to,   or   request   that   we   restrict,   our   processing   of your   Personal   Data   in   certain   circumstances.   Again,   there   may   be circumstances    where    you    object    to,    or    ask    us    to    restrict,    our processing   of   your   Personal   Data   but   we   are   legally   entitled   to   refuse that request; and the    right    to    lodge    a    complaint    with    the    relevant    data    protection regulator   if   you   think   that   any   of   your   rights   have   been   infringed   by us. You can exercise your rights by contacting us using the details listed below. Use of Cookies A   cookie   is   a   small   piece   of   information   that   an   Internet   site   sends   to   a website    visitor’s    computer.    In    some    cases,    it    is    stored    on    the    visitor’s computer’s   hard   drive.   Cookies   can   save   the   visitor’s   name,   password,   user- name,   screen   preferences   and   the   pages   of   the   site   viewed   by   the   visitor. Visitors   may   decline   the   Internet   cookie   by   using   the   appropriate   feature   of their   Web   software,   if   available.   Declining   the   Internet   cookie   may,   however, interfere with a visitor’s ability to view certain content is this web site. Contact Us It   is   important   to   us   at   Conrad   Family   Office   to   hear   what   visitors   have   to say   about   our   Website   or   our   services.   If   you   have   any   questions   and/or concerns   for   instance   about   the   handling   of   your   Personal   Data,   or   want   to let us know what you think, please contact us by Email at: data@conradfamilyoffice.com Address: Conrad Family Office 34 Queen Anne Street London W1G 8HE We   are   usually   able   to   resolve   privacy   questions   or   concerns   promptly   and effectively.   If   you   are   not   satisfied   with   the   response   you   receive,   you   may escalate   concerns   to   the   applicable   privacy   regulator   in   your   jurisdiction. Upon   request,   we   will   provide   you   with   the   contact   information   for   that regulator.
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