Effective: December 12, 2020
Welton Investment Partners LLP and its affiliates (collectively, “Welton,” “we,” “us,” or “our”) are committed to protecting the privacy of all individuals who utilize our websites or investment products and services. Welton is the data controller of the personal data collected, and is responsible for the processing of your personal data.
It is important that you read this Policy together with any other notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other policies and is not intended to override them. In the event of a conflict between this Policy and another policy which applies to a specific site or engagement (i.e., file sharing platforms), the latter shall prevail over this Policy to the extent of the conflict.
What Information Do We Collect?
We collect a variety of personal data (meaning information about an individual from which that person can be identified) from and about you, in a number of situations. What data we collect will depend on the specific circumstances:
- when you provide your personal data to us in direct communications with us through our website, by email, phone, or otherwise, such as when you subscribe to receive publications or product updates, including your name, employer information, and contact details;
- when you instruct us in connection with the provision of investment products and services, you may provide us with personal data, including your name, contact details, and such other information as may be appropriate in context;
- we may also ask you to provide, in certain circumstances, additional personal data in order for you to apply for a job or to comply with legal obligations to which we are subject;
- automatically through logging and analytics tools, cookies, and as a result of your use of and access to our website. We utilize commonly-used logging and analytics tools to collect information about your device, the network used to access the website, and occasionally about your use of the website (such as how you navigate and move around the website).
You have choices about certain information we collect. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary for us to collect by law or to perform a contract, we may not be able to enter into or perform such contract or perform other obligations with respect to you. In addition, as noted below in the section captioned “Your Choices” it is possible to change your browser settings to block the automatic collection of certain information.
We also collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, that data is not subject to this Policy.
In the event that you provide us with information about another person, you must ensure that you have the right to provide that information and, as appropriate, that they understand how their information will be used by us.
How Do We Process Personal Data?
We process personal data as follows:
Operational and Marketing Uses. We process your personal data as part of our business operations and for marketing, which include:
- providing you with information tailored to your requests, responding to inquiries, and delivering and managing investment products and services;
- screening and other activities in connection with employment or other engagement by us of you;
- communications with you regarding our investment products and services;
- compliance with our legal obligations, including compliance checks, and related record-keeping;
- endeavoring to protect our rights, property, or safety, and the rights, property, and safety of our users and other third parties; and
- in connection with the exercise or defense of our legal rights, as well as in response to court orders.
Legal Bases for Processing. We process personal data for, or based on, one or more of the following legal bases:
- to facilitate your investment in products and services offed by Welton on an ongoing basis which are necessary to fulfill all contractual and regulatory obligations related to your investment;
- as is necessary for our legitimate interests, including direct marketing;
- to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harms; and
- in certain circumstances, based on your express consent.
Sharing of Personal Data. Some of the above processing involves sharing collected personal data with third parties, including service providers and affiliates. This occurs in the following circumstances:
- we share personal data with third parties when you ask us to do so;
- we share personal data among our affiliated entities;
- we share personal data with our service providers, including, as applicable, IT service providers, commercial email providers, security consultants, and other vendors we engage so that they may provide services to us or on our behalf; and
- we share personal data with third parties when we believe it is required by, or necessary to comply with, applicable law.
We do not sell or rent your personal information to third parties.
Protecting Personal Data
Because security is important to both Welton and you, we employ reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data. If you suspect unauthorized access to your information, you should contact Welton immediately as provided in the section captioned “Additional Information and Assistance” below.
No method of safeguarding information is completely secure. While we use measures designed to protect personal data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit to us through the Internet is or will be secure.
Retention of Personal Data.
We retain personal data for as long as is necessary to fulfil the purpose for which it was collected, as well as to the extent we deem necessary to carry out the processing activities described above, including compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our rights, property, or safety, and the rights, property, and safety of our users and other third parties. For details on the retention periods applicable to specific elements of your personal data, please contact us as provided in the section captioned “Additional Information and Assistance” below.
Your Rights Regarding Personal Data
These rights vary depending on the particular laws of the jurisdiction applicable to you, but may include:
- the right to know whether, and for what purposes, we process personal data about you;
- the right to be informed about the personal data we collect and/or process about you;
- the right to access, modify, and correct personal data about you (as set forth in more detail below under “Accessing, Modifying, Rectifying, and Correcting Collected Personal Data”);
- the right to know with whom we have shared personal data about you, for what purposes, and what personal data has been shared (including whether personal data was disclosed to third parties for their own direct marketing purposes);
- where processing of personal data about you is based on consent, the right to withdraw your consent to such processing; and
- the right to lodge a complaint with a supervisory authority located in the jurisdiction of your habitual residence, place of work, or where an alleged violation of law occurred.
For additional information, please see “Your California Privacy Rights” and “Your European Union Privacy Rights,” if applicable, for more information about certain legal rights.
Accessing, Modifying, Rectifying, and Correcting Collected Personal Data. We strive to maintain the accuracy of any personal data collected from you, and will use commercially reasonable efforts to respond promptly to update our database when you tell us the information in our database is not accurate. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us, and please notify us as soon as possible of any updates or corrections.
In accordance with applicable law, you may obtain from us certain personal data that we process about you. If you wish to access, review, or make any changes to personal data you have provided to us through our website or related services, you may do so at any time by contacting us as provided below. Please note, however, that we reserve the right to deny access as permitted or required by applicable law.
Your California Privacy Rights. California Civil Code Section 1798.83, known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us a list of what personal data (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to the email address below, and are free of charge.
We do not disclose personal data protected under the “Shine the Light” law to third parties for their own direct marketing purposes.
Your European Union Privacy Rights. In addition to the above-listed rights, European Union privacy law provides individuals with enhanced rights in respect of their personal data. These rights may include, depending on the circumstances surrounding the processing of personal data:
- the right to object to decisions based on profiling or automated decision making that produce legal or similarly significant effects on you;
- the right to request restriction of processing of personal data or object to processing of personal data carried out pursuant to (i) a legitimate interest or (ii) performance of a task in the public interest (including processing for direct marketing purposes);
- in certain circumstances, the right to data portability, which means that you can request that we provide certain personal data about you that we process in a machine-readable format; and
- in certain circumstances, the right to erasure, which means that you can request deletion or removal of certain personal data we process about you.
Note that we may need to request additional information from you to validate a request relating to the exercise of any of the rights above.
In addition to your choices with respect to the collection of personal data (see “What Information Do We Collect?” above), you have the ability to make certain choices about how we communicate with you, and how we process certain personal data.
Communications Opt-Out. You may opt out of receiving marketing or other communications from us at any time through a given communications channel (such as email or telephone) by following the opt-out link or other unsubscribe instructions provided in any email message received and/or by contacting us as provided in section captioned “Additional Information and Assistance” below.
Cookies, Web Tracking, and Advertising. If you wish to disable the storage of cookies on your computer, you may do so by using the settings on your browser or device. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your device. Please note, however, that without cookies, you may not be able to use all of the features of our websites and file sharing platforms. For more information on deleting or controlling cookies, visit www.aboutcookies.org.
Other Important Information About Personal Data.
Collection of Personal Data from Children. The website is designed for a general audience and is not directed to children under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13 through the website. If we become aware that we have collected personal information from a child under the age of 13 through the website, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information through the website, please contact us as provided in the section captioned “Additional Information and Assistance” below.
Business Transfer. We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal data we obtain from or about you via the website or through investment products and services we provide to you may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.
Do Not Track. We use analytics systems and providers that may process personal data about your online activities over time and across third-party websites or online services. We do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms. Note, however, that you may find information about how to block or reject certain tracking technologies by visiting www.aboutcookies.org.
International Transfers. We may share your personal data as noted in the section “Sharing of Personal Data” with third parties, including service providers and affiliates, and this may involve the transfer of your personal data to jurisdictions outside of the United States. Also, if you are using the website from outside the United States, by your use you acknowledge that we will transfer your data to, and store your personal data in, the United States.
Additional Information and Assistance
Welton Investment Partners LLC
The Eastwood Building
San Carlos between 5th and 6th
Carmel, CA 93921 USA
Tel: +1 (831) 626-5190
If you would like to make a complaint about the way Welton has collected, used or retained your personal data, please contact us at [email protected].