You agree not to disclose or to attempt to use or personally benefit from (e.g., use to trade securities or make investment decisions) any Restricted Information (as defined below) that is disclosed to or known by you because of your participation in the ExpertConnect India Councils until such time as the Restricted Information has become publicly available through no action of your own, except to the extent required by law or as expressly permitted by ExpertConnect India for the purpose of facilitating a particular Project. The following should be considered strictly confidential: (1) the identity of Clients (e.g., do not list Clients on your resume or website); (2) information about Projects; (3) information about any actual or potential business, investment or trading decisions, or transactions of any Client; or (4) any other nonpublic or proprietary information of ExpertConnect India or its Clients (collectively, “Restricted Information”). If you are compelled by order of a court or other governmental or legal body (or have notice that such an order is being sought) to divulge any Restricted Information to anyone, you will promptly notify ExpertConnect India, unless prohibited from doing so by the express terms of a court order, and will cooperate fully with ExpertConnect India in protecting such information to the extent possible under applicable law. Upon request by ExpertConnect India or the applicable Client, you agree to return or destroy all Restricted Information in your possession.
What information is collected
We only collect the personally identifiable information that you provide to us.
If you register for certain Services on this Site, you will be asked to provide certain personally identifiable information as part of the registration process. This may include:
We may Process the following categories of Personal Data about you:
- Personal details including given name(s) and preferred name, if any
- Demographic information: date of birth; salutation; title; and language preferences.
- Contact details: address; telephone number; email address; and details of your public business networking profile(s) or online biographies.
- Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
- Payment details: invoice records; payment records; billing address; payment method; bank account number; card or account security details; BACS details; SWIFT details; IBAN details; payment amount; and payment date.
- Data relating to our Sites: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; username; password; security login details; usage data; aggregate statistical information; internet service provider (ISP) details; referring and exit pages; and clickstream data.
- Employer details: where you interact with us in your capacity as an employee, the name, address, telephone number and email address of your employer, to the extent relevant.
- Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.
We may use personally identifiable information in order to develop, offer, and deliver products and services; respond to inquiries from you or your representative; or to fulfil legal and regulatory requirements. ExpertConnect India may collect non-public personal information about you from any of the following sources:
- From you or your representative on applications, registrations, or other forms (for example, your name, address, assets and income);
- From you or your representative regarding your preferences (for example, based on your activity on our website);
- From other sources with your consent or with the consent of your representative (for example, from other institutions such as credit reporting agencies);
- From investment activity (for example, your investments in private placements);
- From other interactions with ExpertConnect India (for example, discussions with our customer service staff or your entry of information into our interactive tools).
- From email correspondence from you (we may gather the information in a file specific to you).
We also may collect certain non-personally identifiable information when you visit the Site. This information includes the type of Internet browser and operating system you are using, the domain name of your Internet service provider, the URL that you visited before you came to our Site, the URL to which you next go, and your IP (Internet Protocol) address, pages visited, and average time spent on our Site. This information may be used, for example, to alert you to software compatibility issues, or it may be analysed to improve our Site design and functionality. When you use the contact features of the Site, you consent to the review and internal use of your communication by ExpertConnect. We also may use non-personally identifiable information in the aggregate to analyse Site usage and to gather broad demographic information.
How we use and disclose the information
Disclosure of Information: As a general rule, ExpertConnect India will not share, rent, sell or otherwise disclose any of your personal information except with your permission. However, ExpertConnect India may disclose personal information in the following ways:
- In using certain of the services, some of your personal information will be displayed either to other persons or entities whom you designate, or to the public. You may modify the settings on your account to designate to whom certain information is disclosed.
- Affiliates, including affiliated services providers;
- We may disclose your personal information to our third-party contractors, service providers, and agents who perform services for ExpertConnect India. These contractors and service providers are permitted to use the personal information only for the purposes of such services.
- We may disclose and transfer your information as part of a merger, acquisition or other sale or disposition of our assets or business.
- Other organizations, with your consent or as directed by your representative; and
- Other organizations, as permitted or required by the laws that protect your privacy (for example, for fraud prevention).
In addition, we may disclose aggregated information to advertisers and for marketing or promotional purposes. In these situations, we do not disclose to these entities any information that could be used to personally identify you.
We require each of the above parties to adhere to our privacy standards and to use this information only for the limited purpose for which it was shared. Individuals interact with us in a variety of ways, and under some of these variations, we may exchange information with parties in addition to those described above.
If you are a former customer, your information is treated in the same manner as the information of current customers. If you have any questions or concerns regarding your privacy with ExpertConnect India, please contact us at firstname.lastname@example.org
Data retention and minimization
We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed in connection with a lawful purpose.
- we will retain copies of your Personal Data in a form that permits identification only for as long as:
- We maintain an ongoing relationship with you (e.g., where you are a user of our services, are a COE Member (or have applied to become one), or you are lawfully included in our mailing list and have not unsubscribed);
- Should you cease being a COE Member, six (6) years from your most recent interaction with any ExpertConnect Indiaclient; or
- The duration of:
- Any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data may be relevant); and
- An additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim), and:
- In addition, if any relevant legal claims are brought, we may continue to Process your Personal Data for such additional periods as are necessary in connection with that claim.
During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either: permanently delete or destroy the relevant Personal Data; or anonymize the relevant Personal Data.
Under applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. We may require proof of your identity before we can give effect to these rights.
Subject to applicable law, you may have a number of rights regarding the Processing of your Relevant Personal Data, including:
- The right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our Sites, or our services, if you do not provide us with your Personal Data – e.g., we may not be able to process your orders without the necessary details);
- The right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
- The right to request rectification of any inaccuracies in your Relevant Personal Data;
- The right to request, on legitimate grounds:
- Erasure of your Relevant Personal Data; or
- Restriction of Processing of your Relevant Personal Data;
- The right to object, on legitimate grounds, to the Processing of your Relevant Personal Data by us or on our behalf;
- The right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
- The right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).
This does not affect your statutory rights.
Please note thatwe may require proof of your identity before we can give effect to these rights; and where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.
Except as described above, we do not reveal information about you to third parties. We restrict access to non-public personal information about you to those employees who need to know that information to provide products or services to you. We maintain reasonable physical, electronic, and procedural safeguards to guard your non-public personal information. With respect to information given on the Internet, ExpertConnect India uses a variety of proven protections to maintain the security of your online session. This may include the use of firewall barriers, encryption techniques and authentication procedures.
Linked sites and other third parties
We may also share all individual investor information, under joint marketing agreements with non-affiliated financial services business partners, in order to offer discounts or other special access to products and services.