Privacy and Cookies STATEMENT

Last Updated: January 18th, 2021.

The CHALK Group (“We” or “CHALK”) are committed to protecting and respecting your privacy.

This privacy statement (together with our terms and conditions and any other policies referred to in it) explains what information we gather about you, what and how we use that information, the lawful basis on which that information is used and who we give that information to. It also sets out your rights and our obligations in relation to your information and who you can contact for more information or queries.

Who this privacy statement applies to and what it covers

This privacy statement sets out how we will collect, handle, store and protect information about you when providing services to you or our clients, or performing any other activities that form part of the operation of our business CHALK.

This privacy statement also contains information about when we share your personal information with other members of our group and other third parties (for example, third parties carrying out due diligence activities on our behalf).

In this privacy statement, your information is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.

What information we collect

We may collect and process personal data about you because you give it to us, because other people give that data to us (for example, third party service providers that we use to help operate our business) or because it is publicly available.

The personal data that we collect or obtain may include: your name; age; date of birth; gender; e-mail address; home address; country of residence; lifestyle and social circumstances (for example, your pastimes); employment and education details (for example, the organisation you work for, your job title and your education details); your IP address; your browser type and language; your access times; complaint details; details of how you use our products and services; details of how you like to interact with us and other similar information.

  1. If you provide Information to us by filling in forms on our website. This may include information provided at the time of registering, subscribing to any of our services, posting material, sending messages and posting in Dashboard, making modifications through your CHALK User Account or requesting further services.

  2. Details of transactions you carry out via our website.

  3. We may ask you for information when you report an issue or concern or we have or receive a complaint or query about you (whether or not a formal Dispute is raised).

  4. We may keep a record of correspondence between you and us.

  5. We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

  6. Details of the messages you send and receive using Dashboard including without limitation, when you sent or received a message and the contents of that message. Messages are not private and are not confidential.

 

We may collect and process personal data about you from other sources as follows:

  1. We may collect or obtain personal data from you because we observe or infer that data about you from the projects you undertake, or the way you interact with us or others. For example, to improve your experience when you use our website and ensure that it is functioning effectively, we (or our service providers) may use cookies (small text files stored in a user’s browser) and Web beacons which may collect personal data. Additional information on how we use cookies and other tracking technologies and how you can control these can be found in our Cookie Notice.

  2. We sometimes supplement the information that you provide with information received from third parties. For instance, credit reference agencies, search information providers, PayPal, other companies (subject to their privacy policies and applicable law), and from other accounts we have reason to believe you control (whether in part or in whole).

  3. Where we are provided with personal data about you by any third party such as a service provider, we take steps to ensure that that third party has complied with the privacy laws and regulations relevant to that information; this may include, for example, that the third party has provided you with notice of the collection (and other matters) and has obtained any necessary consent (if applicable) for us to process that information as described in this privacy statement. CHALK may use your personal data to gather feedback regarding your experience you may have with our platform. This helps our business grow by assembling useful information from our end-user.

Employee Data

We collect personal data about our prospective, current and former employees (including contingent workers, providers and interns) as follows: basic identification information, such as your name, title, position, professional history, experience, and contract details.

For current employees, we usually collect in addition to the above:

1. Detailed identification information including passport numbers, right to work documentation, private email and/or postal address and country of residence.
2. Electronic identification data (e.g. email address, login information, badge number, online identifiers/cookies, log files, connection time).
3. Education and employment information (e.g. remuneration, bonuses, insurance and other benefits information, employment dates, position information such as title, attendance information including, where relevant, illness or leaves of absence for medical or other reasons, language skills and education details , pensions information including entitlements and recruitment information including job applications, CVs, job history and references.
4. Financial information (e.g. bank account details, and tax-related information)
5. National registry number, social security number or local equivalent.
6. In some cases, the personal data we collect may also include so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your: dietary requirements, health (for example, so that we can make reasonable accommodations for you in our buildings, products and services) and sexual orientation (for example if you provide us with details of your spouse or partner).
7. The types of personal data and special categories of personal data that we collect may vary depending on the nature of the services that we provide to you. In some rare circumstances, we might also gather other special categories of personal data about you because you volunteer that data to us or we are required to gather that data as a result of legal requirements imposed on us.

Use of personal data

We will use your personal data to fulfil your requests and we will ask only for data that is adequate, relevant and not excessive for those purposes. Where we send you information for any purpose, it may be sent by e-mail or post. When we ask you for personal data it may include the following purposes:

1. We may contact you occasionally to inform you of new products and services we will be providing;
2. We may send you regular updates on issues we think will be of interest to you;
3. We may send you requested information on our products and services;
4. We may use your personal data for marketing purposes and market research;
5. We may use your personal data internally to provide you with the services offered by us via this website, to administer this website and to help us improve our services.
6. We may use your personal data for managing and making information available to third party service providers (e.g. providers of due diligence services or in order to support our information technology) and our affiliates.
7. We may use your personal data to allow you to participate in interactive features of our service when you choose to do so;
8. We may use your personal data to notify you about changes to our services, terms and conditions, policies or website.
9. We may use your personal data to manage risk, or to investigate, detect, prevent, and/or remediate fraud, suspected fraud or other potentially illegal or prohibited activities.
10. We may use your personal data pursuant to applicable legal or regulatory requirements or to respond to requests and communications from competent authorities (including courts and tribunals).
11. We may use your personal data for the services we receive from our professional advisors, such as lawyers, accountants and consultants.
12. We may use your personal data for protecting our rights, those of our clients, or protecting those of our affiliates.
None of the information that we request from you is mandatory. However, where such information is not provided to us, CHALK may be unable to identify, protect, or return your money or assets.

The legal grounds we use for processing personal information

We are not allowed to process personal information if we do not have a valid legal ground. Therefore, we will only process your personal information for the purposes outlined above because:

  • of our legitimate interests in the performance of activities that form part of the operation of our business;

  • of our legitimate interests in the effective and lawful operation of our business so long as such interests are not outweighed by your interests or fundamental rights and freedoms;

  • of the legal and regulatory obligations that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency; or

  • the information is required in order to carry out the activities that form part of the operation of our business(e.g. the processing is necessary to perform our contractual obligations towards you).

Examples of the ‘legitimate interests’ referred to above are:

  1. to benefit from cost-effective services (e.g. we may opt to use certain IT platforms offered by suppliers);

  2. to verify the accuracy of information provided by a third party;

  3. to prevent fraud or criminal activity;

  4. to safeguard the security of our IT systems, architecture and networks, and of our physical premises; and

  5. to exercise our rights under Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and right to property.

To the extent that we process any sensitive personal data relating to you for any of the purposes outlined above, we will do so because either: (i) we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti money laundering’ obligations (or other legal obligations imposed on us); (ii) the processing is necessary to carry out our obligations under employment, social security or social protection law; (iii) the processing is necessary for the establishment, exercise or defence of legal claims; or (iv) you have made the data manifestly public.

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We may, from time to time, e-mail or post you information to make you aware of our other similar products and services which may be of interest to you. If you do not wish to receive emails or post from us for these purposes, or if you want to be removed from our electronic mailing list you can either select “unsubscribe” from any of the marketing emails that we send or alternatively contact us.