If you are an EU national and reside in the EU, or are a non-EU national residing in the EU, the data controller (as defined under EU data protection law) will be the Harris Williams' relevant entity that you engage with.
INFORMATION WE COLLECT
Harris Williams asks for and collects from you personally identifiable information, in particular name, gender, personal contact information such as email address, telephone number, address, preference information, details about your operating system, internet service provider, browser, IP address, the pages you visited on the Website, the newsletter articles or ads you clicked on, and websites you linked to and from the Website (“Personal Information”). However, with respect to users inside the EU, only limited Personal Information is processed – please see section “The Website and EU websites” below.
The provision of your Personal Information is not a statutory or contractual requirement, or a requirement to enter into a contract. This means that you are not obliged to provide your Personal Information to us.
PURPOSES OF THE PROCESSING
The purposes for which we process and store your Personal Information are:
- To administer, monitor, understand Website performance and use, and to improve the user experience
- To administer, monitor, understand e-newsletter performance and use, and to improve the user experience
- To enable us to aggregate user profiles;
- Where you have requested it or in accordance with applicable privacy laws, to provide you (by email, phone and/or mail) with marketing, promotional, or other information that we think may be of interest to you;
- To execute events and other programs in which you participate;
- To execute digital advertising campaigns;
- To protect or defend our legal rights or property of third-party licensors of any material on the Website;
- As part or current or future legal or similar proceedings; and
- To enable us to comply with our legal and regulatory obligations.
Any promotional correspondence to you will provide you with the ability to opt-out of receiving future promotional material from us and you may contact us at any time and at no cost to tell us that you do not want to receive marketing information from us by emailing us at the email address below.
LEGAL BASIS FOR THE PROCESSING
The processing of your Personal Information is permitted by applicable data protection laws. In the EU, the legal basis for the processing are, with respect to most purposes set out above, our legitimate business interests in providing and improving the Website and any services provided on the Website, including our newsletter and marketing activities, or in defending our legal rights (see Art. 6(1)(f) of the General Data Protection Regulation – “GDPR”). Our legitimate interests outweigh the relevant privacy interests as users usually have an own interest in our Website services; in case of marketing, they also have a right to object to receiving further marketing materials which protects their privacy interests. Where you participate in events and other programs, the legal basis for processing your Personal Information is carrying out a contract with you (Art. 6(1)(b) GDPR). Where we need to comply with legal obligations, the legal basis is Art. 6(1)(c) GDPR. In particular cases, such as providing electronic marketing, we also rely on your informed consent (Art. 6(1)(a) GDPR).
HOW WE COLLECT INFORMATION
Harris Williams directly collects from you Personal Information, e.g. through cookies, web beacons, pixel tags or similar digital marker technologies. We also collect Personal Information through our service providers (Google Analytics, Google AdWords, LeadLander, and LinkedIn). Harris Williams may combine this information with the Personal Information and other information it collects.
Harris Williams may disclose your Personal Information to third parties (i) for purposes of outsourcing one or more of the functions described in the previous section; (ii) to confirm or update information provided by you; (iii) to inform you of events, information about our services, and other important information, (iv) if you direct us to do so, or if we are required or authorized by law or if we reasonably believe that the disclosure is necessary in order to (a) fulfill a government request; (b) conform with the requirements of law or to comply with legal process served on us; or (c) protect or defend our legal rights or property or third party licensors of any material on the Website, or (v) for other purposes disclosed at or before the time the information is collected. If you tell us you wish to attend an event, your name and organization will be shared with the venue and may appear on a list which we provide to other delegates at the event. We may also share your information when legally required to do so.
Data Recipients: We may provide your Personal Information to our affiliates, including The PNC Financial Services Group, Inc. to the extent permitted by applicable law or for hosting and maintaining this Website (which is hosted on servers in the United States). For this purpose, we may transfer the Personal Information outside your country to another country that does not have similarly high data protection level as the EU and for which there is no adequacy decision of the European Commission. We use EU Standard Contractual Clauses as a safeguard to secure your Personal Information in the context of such transfer. You can request a copy hereof or you can obtain a copy of the EU Standard Contractual Clauses at this link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
We also share your Personal Information with vendors we have hired to provide services for us. Where necessary to (a) fulfill a government request; (b) conform with the requirements of law or to comply with legal process served on us; or (c) protect or defend our legal rights or property of third party licensors of any material on the Website, we may also need to disclose Personal Information with regulatory authorities or courts or with other parties to legal proceedings.
UPDATING YOUR PERSONAL INFORMATION
To ensure that you have as much control over your Personal Information as possible, you may update your Personal Information by contacting us as provided in the “Contacts” section below. We will use reasonable efforts to process any change you make; provided, however, that requests to delete Personal Information are subject to Harris Williams’ internal reporting and retention policies and all applicable legal obligations.
THE WEBSITE AND EU WEBSITES
Please note that this Policy does not apply to other organizations to which we link. We are not responsible for their privacy policies or practices of any other third party websites and you should make your own inquiries regarding them.
Children under 13 years old are not the target audience for the Website. To protect their privacy, we prohibit the solicitation of Personal Information from these children. If you are under the age of 13, please do not submit your email address or any other personal information to us through the Website.
We store your Personal Information only as long as required for reaching the relevant purposes outlined above (“Purposes of the processing”), and we will delete your Personal Information thereafter, and in any case will not retain your Personal Information for a period of more than ten years.
ACCESS TO YOUR INFORMATION AND OTHER RIGHTS
If we process your Personal Information, you have the right to access your Personal Information and to request a copy of the Personal Information that we hold about you. If you wish to request access to such personal information, please email or write to us at the email address or postal address set out below in the “Contact Us” section. We may charge you a small fee for this service if you request more than one copy of the Personal Information. If you discover any inaccuracy, please let us know so that we can make whatever corrections are appropriate.
You also have the rights:
- To erasure of your Personal Information, i.e. you may demand your Personal Information to be deleted in certain circumstances (e.g., where processing of such data is no longer necessary for the purposes for which we collected or otherwise processed them);
- To restrict the processing of your Personal Information, i.e. you may, in certain circumstances, demand the restriction of your Personal Information (e.g., if you contest the accuracy of such data, processing will be restricted for a period enabling Us to verify their accuracy);
- To tell us that you do not wish to receive marketing information;
- To demand, in some circumstances, certain of your Personal Information to be transferred to you or a third party; and
- Not to be subject to a decision based solely on automated processing, including profiling, which produces effects concerning you or similarly significantly affects you.
Furthermore, you have the right to object to us processing your Personal Information at any time (i) in case of direct marketing or (ii) on grounds relating to your particular situation, in case we process your Personal Information for the purposes of our legitimate interests. As to such purposes, you will find more information above (“Purposes of the processing”).
To the extent our processing of your Personal Information is based on your consent, you also have the right to withdraw your consent, without affecting the lawfulness of our processing based on your consent before its withdrawal. You may also ask us to remove your name from our marketing databases and if you do that we will comply as soon as practicable.
You can further lodge a complaint about our processing of your Personal Information with a data protection authority, in particular, in the EU Member State of your habitual residence, place of work or of an alleged infringement of applicable data protection laws.
Exercising any of your rights mentioned above is subject to legal prerequisites and, in certain circumstances, your rights may be limited due to legal exceptions set out, in particular, in Articles 17 para. 3 and 22 para. 2 GDPR. Should you have any questions relating to your rights or their limitations, please feel free to contact our data protection officer under the contact details set out below.
To make use of your rights listed above, or should you feel that your privacy or security is being compromised, wish to make a request for access to any personal data we may hold about you or to have inaccuracies in your information corrected (as described further on the “Access To Your Information” section above), or have any questions on this policy, please contact us at Harris Williams, 1001 Haxall Point, 9th Floor, Richmond, Virginia 23219 or email email@example.com.
Date of last update or revision: May 17, 2018