Private Policy
PRIVACY STATEMENT & GDPR
SCI is committed to protecting your privacy and providing you with a positive experience while using our websites, products, or services ("Platform").
SCI reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. If we make material changes to our Privacy Policy, we may also notify you by other means prior to the changes taking effect, such as by posting a notice on our Platform or sending you a notification. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy.
1. Scope
This Policy applies to SCI’s Platform and provides you with guidance on your rights and obligations in relation to your personal information.
SCI's Privacy Policy (the "Privacy Policy") establishes and communicates the key principles that SCI follows in protecting the personal information that we collect.
2. Collection of Personal Information
"Personal information" is any information that can be used to identify an individual, and may include things such as your name, company, physical address, email address, phone number, login information, marketing preferences, company affiliation, and location. SCI may collect personal information that is necessary for legitimate business purposes, which will be disclosed to you at the time of collection. SCI will use this information for the purposes for which it was collected. SCI may also collect personal information from trusted third-party sources and engage third parties to collect personal information to assist us.
One of the most common methods of collecting personal information is during the online form submission or registration process, including where a website user is requesting a free trial or a courtesy newsletter, registering for an event, or responding to similar offers such as reports, webinars, or further product information.
In some instances, SCI and the third parties we engage may automatically collect and aggregate data using cookies, weblogs, other similar applications. This information is used to better understand and improve the usability, performance, and effectiveness of our Platform and to help us tailor content or offers for you. Please read the “Cookies” section below for more information.
3. Purpose and Use of Personal Information
SCI may use your personal information for operational, legal, administrative, and other legitimate purposes permitted by applicable law. Some of the ways we may use personal information include:
• Providing you with requested products or services.
• Providing you with information regarding similar products or events.
• Analysing and monitoring extent of use.
• Providing customized product and service information.
• Allowing users to participate voluntarily in mailings or other events.
• Providing product service updates, information, and alerts.
• Sending communications, including for marketing or other customer satisfaction purposes.
• Order processing, and to provide transaction documents.
• To contact users for information verification purposes.
4. Right to Access and Correct Personal Information
We strive to make sure that our information is reliable, accurate, and up-to-date. While personal information is maintained by SCI, you may access your personal information to the extent required by law to review, update, and correct inaccuracies. When logged into the SCI website you may view data we hold on you by clicking 'My Account' at the header of the website. You may use this page to update data or request to have some or all of your data removed from our servers. You may also opt out of SCI email correspondence by clicking the appropriate link at the footer of any news or marketing emails we send you.
Otherwise upon request made to the contact listed below, we will provide you with reasonable access to the personal information we collect about you. Because personal information—for example, your email address—is required to use the Platform, we retain personal information as long as your account is active. You will have the opportunity to correct, transfer, update, modify, or delete this information by logging into your account and updating your information online. You may also limit the use and disclosure of your information by either unsubscribing from marketing communications or contacting us at the address listed below under the section titled “Contact Information” or by emailing info@structuredcreditinvestor.com.
5. Sharing Personal Information
SCI may disclose personal information to its affiliates/related companies. SCI may also disclose personal information to service providers for the purposes of operating our business, delivering, improving, and customizing our products or services, sending marketing and communications related to our business, payment processing, and for other legitimate purposes permitted by applicable law or otherwise with your consent. Personal information handled by these service providers is subject to their terms of use and privacy policies. Please review the service provider’s terms of use and privacy policies to better understand how they manage your personal information.
There may also be instances when SCI may disclose your personal information without providing you with a choice in order to honour a request that you have made through the products or services; comply with the law or in response to a court order, government request, or other legal process; protect the interests, rights, safety, or property of SCI or others; protect against fraud or for risk management purposes; or respond to adverse third parties (i.e., adverse parties and their counsel and other agents) in the context of litigation. In addition, if SCI sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, you agree that SCI may transfer your personal information to a third party as part of that transaction.
In all cases SCI requires all unaffiliated third parties to treat personal information as confidential. SCI will not provide personal information to third parties for their own marketing purposes without your consent.
If you participate in a discussion forum, chat room, or provide comments related to SCI on a social media or other public platform, you should be aware that the information you provide there (i.e., your public profile) will be made broadly available to others, and could be used to contact you, send you unsolicited messages, or for purposes neither SCI nor you have control over. Also, please recognize that social media forums and chat rooms not controlled by SCI may have additional rules and conditions. SCI is not responsible for the personal information or any other information you choose to submit on these forums that are not SCI controlled.
The Platform may offer you the ability to share personal information through a social networking site (e.g., Facebook, Twitter), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables you to share personal information about yourself with other individuals or the public, depending on the settings that you have established with such social networking site. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.
6. Security of Personal Information
SCI has physical, administrative, and technical safeguards in place to help protect the personal information SCI collects. While there is no such thing as perfect security on the Internet, we will take reasonable and appropriate steps to ensure the safety of your personal information.
7. Retention of Personal Information
SCI will retain your personal information as needed to fulfil the purposes for which it was collected. We will retain and use your personal information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.
8. Cookies
When visiting an SCI Platform, our servers may query your computer to see if there are cookies previously set by SCI. A cookie is a text file that is created when your browser visits a particular website, such as an SCI website. Afterwards, every time you visit the SCI website, your browser retrieves and sends this file to the SCI website's server. Cookies enhance the website user experience by:
• Helping SCI authenticate you as a user when you log in to a secure area of the website;
• Storing information about your website user activities so you may easily pick up where you left off on the SCI server's pages;
• Storing your user preferences, which allows you to customize how information is presented through site layouts or themes; and
• Personalizing the manner in which SCI responds to you via marketing communications.
The cookies SCI collects may include the following information: a unique identifier, user preferences, and profile information used to personalize the content shown to the individual users. It is your choice whether you allow SCI to store such information on your computer or device. You may be able to set your web browser to alert you when a cookie is being used and may use your browser to accept or reject the cookie; additionally, you may also disable the cookie feature on your browser entirely. However, disabling cookies may prevent you from using some features on SCI websites. You can find more detailed information about cookies and how they work at AboutCookies.org.
We may collect and share the physical location of your device with your consent for purposes consistent with this Privacy Policy, such as to provide you with personalized location-based products or services. In some instances, you may be permitted to allow or deny such use of your device's location, but if you choose to deny such use, we may not be able to provide you with the applicable personalized products or services.
Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time, SCI does not modify your experience based upon whether such a signal is broadcast.
SCI participates in interest-based advertising. This means that a third party may use cookies or similar technologies to collect information about your use of our products and services so that they can provide advertising about our products and services tailored to your interests. This advertising may appear either on our website, or on other sites.
10. Prospective Employee and Employee Information
If you submit an application for employment to or are currently an employee of SCI, SCI is authorized to collect the information in any form it obtains through your application for employment or continued employment with SCI, and your submission of employee related documents, including but not limited to the personal information that you submit in connection with your employment or intended employment (collectively "Employee Information"). Examples of Employee Information collected in connection with your employment or application for employment includes but is not limited to your name, date of birth, government issued identification (passport, social security number, driver’s license number), banking information, marital status, health information, benefit information, title, employment history, education, job qualifications, and other relevant employee personal data.
SCI will collect, use, store and retain, and secure your National Insurance number in accordance with this Privacy Policy. SCI will not intentionally communicate or make available, in any manner, your National Insurance number to the general public. SCI will not print your National Insurance number on any card required for you to access colleague member services provided by SCI. SCI will not require you to transmit your National Insurance number over the Internet. In accordance with applicable law, SCI may use Employee Information to evaluate applications for employment, manage work-related aspects of the employee-employer relationship (i.e., training, payroll, benefits, travel, reimbursement expenses, performance appraisals, succession planning, team member health and safety), investigate and respond to any claims related to your employment, and comply with applicable laws and regulations. Your Employee Information will not be used for direct marketing purposes by us or any third-party service provider, unless you specifically consent to such use.
SCI shares your Employee Information with third parties who provide outsourced human resource functions to us. Those third parties are required to protect your Employee Information. SCI may disclose your Employee Information if required or permitted to do so by law (such as when part of a governmental agency action or litigation), governmental or quasi-governmental requests, or a regulatory organization, or to relevant third parties such as site technicians, brokers, auditors, lawyers, or professional advisors. In the event that SCI considers it necessary or where required by law to disclose Employee Information in certain situations where the health, safety, or wellbeing of a team member is at imminent risk, we may share your Employee Information with our outside lawyers, law enforcement or others who are legally authorized. As SCI continues to develop our business, we may buy or sell assets. In the unlikely event that SCI or substantially all of our assets are acquired, Employee Information may be one of the transferred assets.
Employee Information may be stored in hard copy or electronic format within your branch office or in the cloud in the United States or other countries where SCI, its affiliates, agents, or contractors conduct business. Your Employee Information may be transferred into our human resources systems and used to manage your employment, may become part of your personnel file, and may be used for other work-related purposes. Your Employee Information will be kept for as long as is legally required, and in some instances longer depending upon the needs of the organization and industry practices.
If you have any complaints regarding our compliance with this Privacy Policy, you should first contact us at the address listed below under the section titled "Contact Information" or by emailing info@structuredcreditinvestor.com
11. EU General Data Protection Regulation
The SCI Policy for the Processing of Data Governed by the GDPR addresses our commitment to the processing of personal data under the EU General Data Protection Regulation
12. Other Contractual Relationships
If you enter into a separate contractual relationship with SCI which requires, or contemplates, collecting, using, or sharing information about you in a manner that is different than that which is described in this Privacy Policy, the terms of that agreement will apply.
13. Other Websites
This Privacy Policy does not apply to sites or applications offered by other companies or individuals, including third party products and services, that may be displayed as content in a search on our website. SCI encourages you to read the privacy policy of any third-party site or applications before transmitting personal information.
SCI Policy for the Processing of Data Governed by the GDPR
In connection with the services offered by SCI we may collect, process or handle Personal Data relating to individuals in the European Economic Area (the “Personal Data”) on behalf of its customers and its affiliates, where applicable (“customer”).
Although SCI’s relationship with its customers is typically governed by general terms and conditions and/or a master agreement, which includes order forms, schedules and addenda (the “Agreement”), SCI is also legally bound under the EU General Data Protection Regulation concerning the manner in which it collects, uses, and processes Personal Data. This Policy describes SCI’s commitment to the processing of Personal Data under the GDPR.
- Appropriate Technical and Organizational Measures. When SCI processes Personal Data on behalf of a customer, SCI implements appropriate technical and organizational measures to satisfy the requirements of the GDPR, to ensure the level of security of Personal Data is appropriate to the level of risk, and to help ensure the protection of the rights of the data subject.
- Written Instructions. SCI only processes Personal Data in accordance with the terms (and to satisfy our obligations) set out in any Agreement, this Policy, the SCI Privacy Policy and any other written terms agreed with customer from time to time. The foregoing documents set out the subject-matter, duration, nature, purpose, types of Personal Data, categories of data subjects, and the obligations and rights of SCI’s customer relating to its processing of such Personal Data.
- Confidentiality. SCI requires that the people it authorizes to process Personal Data are under appropriate obligations of confidentiality.
- Cooperation Concerning Data Subjects. SCI cooperates with the reasonable requests of its customers (at the customer’s reasonable expense) to help them fulfil their obligations under the GDPR to respond to requests by data subjects to access, modify, rectify, or remove their Personal Data.
- Cooperation Concerning Customer Documentation. SCI cooperates with the reasonable requests of its customers to provide information necessary to demonstrate compliance with this Policy and the GDPR or to conduct audits of the Personal Data held by SCI that was received from the customer. SCI will typically agree to such audits on the following basis: (a) audits may only occur once per calendar year and during normal business hours, and only after reasonable notice to SCI (not less than 30 business days); (b) audits will be conducted by customer or an appropriate independent auditor appointed by customer (not being a competitor of SCI) to conduct audits, in a manner that does not have any adverse impact on SCI’s normal business operations; (c) customer and/or its representatives will comply with SCI’s standard safety, confidentiality and security procedures in conducting any such audits and shall not have access to any proprietary or third party information or data; and (d) any records, data or information accessed by the Company and/or its representatives in the performance of any such audit will be deemed to be the confidential information of SCI, as applicable, and may be used for no other reason than to assess SCI’s compliance with the terms of this Policy (in connection with the foregoing, SCI may require Customer and and/or its representatives to enter into a customary confidentiality agreement prior to any such audit); (e) to the extent any such audit incurs or is reasonably likely to incur in excess of 10 hours of SCI personnel time, SCI shall be entitled to charge Customer £500 per hour for any such excess hours.
- Personal Data Breach. In the event of a Personal Data breach under the GDPR, SCI will notify its applicable customers without undue delay after becoming aware of the breach. Such notification(s) may be delivered to an email address provided by Customer or, at SCI’s discretion, by direct communication (for example, by phone call or an in-person meeting). Customer is responsible for ensuring that any email address provided by Customer is current and valid. SCI will take reasonable steps to provide its customers with information that they may reasonably require to comply with their obligations to notify impacted data subjects or supervisory authorities.
- Deletion of Data; Termination and Variation. At the termination of a customer’s relationship with SCI, SCI will delete or return all Personal Data to our customer, unless SCI is permitted to retain it or is otherwise required to retain it by applicable laws, regulations or bona fide audit and compliance policies. SCI reserves the right to charge a reasonable fee to comply with any customer’s request to return Personal Data. This Policy shall be effective from May 25, 2018 and will remain in effect until, and automatically expire upon, deletion of all Personal Data by SCI. SCI reserves the right to reasonably amend and update this Policy from time to time.
- Governing Law. This Policy shall be governed by the governing law (and subject to the jurisdiction(s)) of the relevant Agreement and otherwise subject to the limitations and remedies expressly set out in the Agreement.
If you have any questions or concerns related to this Privacy Policy, please contact the SCI Chief Privacy Officer:
SCI
Attn: Chief Privacy Officer
55 Goswell Rd, 3rd Floor South
London EC1R 0AT
info@structuredcreditinvestor.com
If SCI needs, or is required, to contact you concerning any event that involves information about you we may do so by email, telephone, or mail.