375 Park Associates

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26th Floor 

Seagram Building

375 Park Avenue

New York, NY 10152

+1 (212) 763-0159

375 PARK ASSOCIATES GLOBAL PRIVACY POLICY

Your Privacy Is Important to 375 Park Associates.

 

In the course of serving you as someone associated with a corporate or institutional client, 375 Park Associates may obtain personal information about you.  Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

 

This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy.  As used throughout this policy, the term “375 Park Associates” refers to The 375 Park Associates and its affiliates worldwide.

 

The Sources of Information

 

The personal information we collect about you comes primarily from applications or other forms and materials you submit to 375 Park Associates during the course of your relationship with us.  

We may also collect information about your transactions and experiences with 375 Park Associates relating to the products and services 375 Park Associates provides.  In addition, depending on the products or services you require, 375 Park Associates may obtain additional information about you with your consent.

 

Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g. recording of telephone calls and monitoring e-mails).  In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.

 

The Information We Have about You

 

If you deal with 375 Park Associates as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company the typical information we collect about you would include:

 

  • Your name, address and other contact details;

  • Your age, occupation and marital status;

  • Extensive financial information, including source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources;

  • A head and shoulders photograph from, as applicable, your passport, national identity card or driver's license, as required by laws and regulations addressing due diligence and related matters; and

  • A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.

 

If you are an employee/officer/director/principal, etc. of one of our corporate or institutional clients, the typical information we collect about you personally would include:

 

  • Your name and contact details;

  • Your role/position/title and area of responsibility; and

  • Certain identifying information (e.g. passport photo, etc.) as required by laws and regulations addressing money laundering and related matters.

 

Of course, you are not required to supply any of the personal information that we may request.  However, failure to do so may result in our being unable to open or maintain your account or to provide services to you.  While we make every effort to ensure that all information we hold about you is accurate, complete, and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

 

Our Use of Your Personal Information

We may use your personal information to:

 

  • Administer, operate, facilitate, and manage your relationship and/or account with 375 Park Associates.  This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;

  • Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account;

  • Provide you with information (such as investment research), recommendations, or advice concerning products and services offered by 375 Park Associates; and

  • Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

 

If your relationship with 375 Park Associates ends, 375 Park Associates will continue to treat your personal information, to the extent we retain it, as described in this policy.

 

Disclosures of Your Personal Information within 375 Park Associates

 

In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within 375 Park Associates may be given, or given access to, your personal information.  For example, one 375 Park Associates entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts, or as part of its arranging for the performance of specialized services such as US and international brokerage, asset management and advisory and trust services.  When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information.  Additional information on how your personal information is protected while within 375 Park Associates is provided below, under Information Security: How We Protect Your Privacy.

 

Disclosures of Your Personal Information to Third Parties

 

375 Park Associates does not disclose your personal information to third parties, except as described in this policy.  Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with 375 Park Associates, including those that provide professional, legal, or accounting advice to 375 Park Associates.  Non-affiliated companies that assist 375 Park Associates in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that 375 Park Associates dictates.

 

We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent.  Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges and clearinghouses.

 

You should know that 375 Park Associates WILL NOT SELL your personal information.

 

Information Security: How We Protect Your Privacy

 

375 Park Associates is committed to protecting the privacy and confidentiality of your personal information.  We limit access to your personal information to authorized 375 Park Associates employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, our service providers are held to stringent standards of privacy.  We also maintain physical, electronic, and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure.  

 

Privacy and the Internet

 

The following additional information will be of interest to you as a visitor to this site:

 

Users of private 375 Park Associates Web sites are required to identify and authenticate themselves prior to accessing our services.  Generally, identification and authentication take place through the use of your username, password, and a Personal Identification Number (PIN).

Private 375 Park Associates Web sites are built upon a secure infrastructure with multiple layers of protection, including measures ranging from proper physical security of our machines to system intrusion detection capabilities.  Within such private sites, 375 Park Associates uses industry standard encryption technologies to protect your information from external compromise.

 

Security is a cooperative effort between 375 Park Associates and the users of the 375 Park Associates Web sites.  Please remember that your password and PIN are personal to you and should not be made available to any other person.  In Addition, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them.

“Cookies” are small text files that may be placed on your Web browser when you visit our Web sites or when you view advertisements, we have placed on other Web sites.  For more information about cookies, how our Web sites use them, and your options with respect to their use, please see our cookies policy.

 

“Clickstream” data (e.g., information regarding which of our Web pages you access, the frequency of such access, and your product and service preferences) may be collected by 375 Park Associates itself, or by our service providers, using cookies, Web beacons, page tags, or similar tools that are set when you visit our Web site or when you view an advertisement we have placed on another Web site.  Clickstream data and similar information may be shared internally within 375 Park Associates and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with our Web sites; and as otherwise permitted by applicable law or regulation.  If you are a 375 Park Associates client, this information helps us suggest products or service offerings that may be of interest to you.  This information may be processed by us for the purposes described above, or on our behalf by third parties, solely in accordance with our instructions.

 

When you visit this site, your browser may be momentarily directed to the Web site of an ad server or other third party service provider.  This re-direction process will not be apparent to you.  These third party Web sites automatically receive your IP address when this happens, and they may collect information from your interaction with our Web sites including computer and connection information, standard Web log information, and ad information.  Such information does not identify you individually.

 

375 Park Associates may make available on this Web site third party applications such as content linking or sharing facilities.  Information collected by providers of such applications is governed by their privacy policies.

 

Our Web sites are not currently configured to respond to “do not track” signals or similar mechanisms.

 

Other Privacy Policies or Statements; Changes to Policy

 

This policy provides a general statement of the ways in which 375 Park Associates protects your personal information.  You may, however, in connection with specific products or services offered by 375 Park Associates, be provided with privacy policies or statements that supplement this policy.  This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information.  The revised policy will be effective immediately upon posting to our Web site.  This version of the Policy is effective December 13, 2013.

 

Additional Information: The European Economic Area – Singapore, Switzerland, Hong Kong, Japan, Australia, and New Zealand (This section applies only if your information is processed by 375 Park Associates in a Member State of the European Economic Area (EEA), Singapore, Switzerland, Hong Kong, Japan, Australia, or New Zealand).

 

You are entitled to access any personal data about you held by 375 Park Associates by sending a written request to the applicable individual identified below.  You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorized disclosure of your personal information.  We will process your request within the time provided by applicable law.  You are also entitled to have 375 Park Associates modify or delete any information that you believe is incorrect or out of date.

 

375 Park Associates may occasionally contact you by post, telephone, electronic mail, facsimile, etc., with details of products and services that we believe may be of interest to you.  If you do not wish to be contacted in this way, if you wish to exercise your rights of correction and access, or if you require further information regarding our privacy policies and practices in the above-referenced regions, please contact:

 

The Privacy Officer

375 Park Associates

19th Floor

Two International Finance Centre

8 Finance Street

Central, Hong Kong SAR

 

Additional Information: The United States

 

If you require further information regarding our privacy policies and practices in the United States, please contact:

 

Privacy Officer

The Privacy Officer

375 Park Associates

26th Floor

Seagram Building

375 Park Avenue

New York, New York 10152

PRIVACY & SECURITY