Effective Date: January 1, 2020
This Privacy Statement details the personal information we may gather about you in relation to services we provide to our clients, as more fully set forth herein.. This Privacy Statement also sets out your rights in relation to your personal information and tells you who you can contact if you have questions.
To whom does this Privacy Statement apply and what does it cover?
This Privacy Statement applies to Alter Domus Inc., Cortland Capital Market Services LLC, Cortland Fund Services LLC, Cortland National Services, Inc., and AD Carta, LLC, all entities within the Alter Domus Group (collectively, “Alter Domus US”). As used in this Privacy Statement, “Alter Domus Group” refers to Alter Domus Participations S.à r.l., Société à responsabilité limitée and its affiliates, with our main establishment situated on 15 Boulevard F. W. Raiffeisen, in Luxembourg.
This Privacy Statement sets out how we will process your personal information as part of (a) the services we provide to you, (b) the services we provide to an entity to which you are an investor or customer, or (c) your employment with us.
Your personal information will be protected and handled with consideration for its confidentiality and Alter Domus US will only disclose it as set out in the “To whom will we disclose your personal information?” section below.
In this Privacy Statement, we refer to handling, collecting, protecting and storing your personal information as “processing.”
What categories of personal information do we collect?
Alter Domus US may collect personal information relating to you such as:
- Identifiers, such as:
- Contact details (such as work or home address, email, and phone numbers);
- Date of birth; and
- Government identifiers (such as social security number and passport details).
- Financial information, such as
- Account and bank details; and
- Purchase history and financial details.
- Internet or network activity information, such as browsing history and interactions with our website;
- Audio, electronic, visual and similar information, such as images and audio, video, or call recordings created in connection with our business activities;
- Primarily for Employees:
- Professional or employment-related information, such as work history and prior employer;
- Education history
- Human resources data, and data necessary for benefits and related administrative services;
- Insurance information; and
- Medical information and health information.
In order to provide the applicable services to you, Alter Domus US may also receive and need to process personal information about you that may be considered special category (or “sensitive”) personal information, which may include information about your health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, or sexual orientation. Special category personal information about you includes information that may be reasonably inferred from other information that we receive.
Where we receive special category personal information or other information from which special category personal information can be reasonable inferred, we will require explicit consent in order to process it.
How do we collect personal information?
Alter Domus US may collect personal information about you in different ways:
- You may provide it directly to us;
- We may obtain it because of the services that Alter Domus US provides or has previously provided, either to yourself of an Alter Domus US client;
- We may receive it from other members of the Alter Domus Group or from third parties, such as your employer/partnership, or third party service providers, credit reference agencies, sanctions checking and background screening service providers, all during the onboarding process as a client of Alter Domus US
This personal information can be received in any manner, including in-person discussions, telephone conversations, and electronic or other written communications.
Without access to all the personal information that we need, we may be unable to confirm your employment and payroll (if an employee) or provide or complete the services.
Where another party (such as a company or a partnership or any third parties acting on you or your behalf) provides your personal information to us, they must also comply with their obligations under the relevant privacy laws and regulations. If you believe that the entity for whom you work or a third party has not provided you with details of the personal information that it holds about you and/or has not obtained your authority to provide us with that personal information for processing as described in this Privacy Statement, then please contact such entity directly.
Disclosing Personal Information to us relating to third parties.
If any personal information which you provide to us relates to any third party, for example a spouse or civil partner, individuals (including children) who depend on you financially, or a joint account holder or a beneficiary or trustee of a trust, then by providing us with their personal information you will need to ensure that you have obtained any necessary permissions from those persons to the use of their personal information in the way set out in this Privacy Statement, or you are otherwise permitted to give us this personal information. You should share a copy of this Privacy Statement with those other individuals before disclosing any personal information about them to us.
How do we use your personal information?
Alter Domus US processes personal information about you to:
- Establish or maintain our relationship with you;
- Provide services to you or to the entity that has engaged us to provide the services;
- Compliance with applicable legal, regulatory, or professional requirements (such as anti-money laundering law (“AML”) and know-your-customer (“KYC”) obligations);
- Protecting our rights and/or property; and
- Perform pure employment functions, such as:
- To process payroll and track time and attendance;
- To manager worker’s compensation claims;
- To administer and maintain benefits, including group benefits, and retirement service and insurance;
- To manager employee performance of job duties and conduct workplace investigations; and
- To perform background checks on employees.
On what basis do we process personal information about you?
This Privacy Statement sets out the grounds upon which we rely in order to process your personal information. We may use your personal information for the purposes outlined above because: (a) where relevant, we have a contract with you to provide services and processing your personal information is necessary for the performance of that contract; (b) we are subject to legal, regulatory, or professional obligations; or (c) we have a legitimate interest in processing your personal information, which may be to:
- Provide services to you and/or to the entity that has engaged us to provide the services;
- Support the management of our client engagements;
- Evaluate, develop, or improve our services or products;
- Perform AML and KYC checks as related to our services;
- Provide employment-related services to an employee; and
- Protect our business interests.
To whom will we disclose your personal information?
In connection with one or more of the purposes outlined in this Privacy Statement, we may disclose your personal information to:
- Other members of the Alter Domus Group;
- Those with whom you have requested us to share information;
- Competent authorities, including courts and authorities regulating us or another member of the Alter Domus Group, in each case to comply with legal, regulatory, or professional obligations or requests;
- Vendors and administrative support, infrastructure, and other service providers handling your information on our behalf, such as AML/KYC providers, background check providers, and payroll providers; in each case, such vendors and service providers will be contractually bound by confidentiality and privacy obligations consistent with the obligations in this Privacy Statement; or
- Third parties to whom we disclose information in the course of providing services to you or to the entity that has engaged us to provide the services.
Alter Domus US does not sell or lease your personal information to others.
Please note that some of the recipients of your personal information referred to above may be based in countries or regions without data protection rules similar to those in effect in your area of residence. In such cases, adequate safeguards will be in place to protect your personal information.
For further details about the transfers detailed above and the adequate safeguards used by Alter Domus US with respect to the same, please contact us using the details below.
How do we keep your personal information secure?
We have in place reasonable commercial standards of technology and operational security to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Only authorized personnel, with appropriate awareness of privacy obligations, are provided access to your personal information.
How long will we keep your information?
We retain personal information as long as is necessary to fulfill the purposes identified in this Privacy Statement or (i) as otherwise necessary to comply with applicable laws or regulations or (ii) as long as the period in which litigation or investigations might arise in respect of our services.
What are your rights in relation to your personal information?
You have various rights in relation to your personal information. In particular, you have a right to:
- Obtain confirmation that we are processing your personal information and request a copy of the personal information we hold about you; and
- Ask that we update the personal information we hold about you or correct such information that you think is inaccurate or incomplete.
Depending on the jurisdiction in which you are located (i.e., California or Europe), you may also have the right to:
- Request the following information regarding the personal information we hold about you:
- The categories of personal information
- The categories of sources from which the personal information is collected
- The business or commercial purpose for collecting personal information
- The categories of third parties with whom we share personal information
- Ask that we delete personal information that we hold about you, or restrict the way in which we use your personal information, which request will be subject to whether we require your personal information for legitimate interest;
- Withdraw consent to our processing of your personal information (to the extent our processing is based on your consent);
- Ask us to stop or start sending you marketing messages at any time;
- Obtain and/or move your personal information to another service provider; and
- Object to our processing of your personal information.
Where our processing of special category personal information is reliant on your consent and you withdraw that consent, we will cease processing relevant information for the purposes of providing our services and the effect may be that we are no longer able to provide the services.
However we may still retain a copy of your relevant information for as long as necessary to comply with applicable laws or professional standards, or as long as the period in which litigation or investigations might arise in respect of our services.
To exercise any of your rights or raise any questions that you have about our use of your personal information, please contact us using the details below
Privacy Shield Notice
Alter Domus US adheres to the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce with respect to personally identifiable information that is transferred from the European Economic Area and the United Kingdom to the United States within the scope of their Privacy Shield certifications and therefore provides for an adequate level of data protection under European Union General Data Protection Regulation and as recognized by the European Commission. To learn more, see our Privacy Shield Notice located on our website at http://www.cortlandglobal.com/privacy-shield-notice. You may have the right to lodge a complaint with your local European data protection authority regarding our processing of such personal information.
Changes to this Privacy Statement
We may modify or amend this Privacy Statement from time to time at our discretion. When we make changes to this Privacy Statement, we will amend the revision date at the top of this page and the modified or amended Privacy Statement shall apply to you and your personal information as of that revision date. We encourage you to review the Privacy Statement our website periodically to be informed about how we are protecting your personal information.
If you have any questions or concerns regarding this Privacy Statement or your personal information, please contact our data protection officer by email at USPrivacyQuestions@cortlandglobal.com.