EMAlpha LLC is a provider of financial products, datasets, proprietary content, information solutions and analytical applications to the investment community, asset managers, asset owners, corporate, academia. To protect your privacy better, EMAlpha wants our customers, suppliers and other relevant parties to know how we collect personal data, the types of personal data we collect, and how we use and share your personal data when we act as the controller of that personal data that is subject to the EU General Data Protection Regulation (GDPR). Hence this notice only applies to personal data which is subject to GDPR and which we collect:
On this Website;
- on client and supplier facing applications and tools (e.g. Workstations, Starboard and Gateway, Object Reference, Endpoint Reference, Confluence, Jira);
- in email, text, and other electronic messages between you and our employees; when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this notice;
- from customers and suppliers subject to contractual relationships;
- from public and third-party sources for the purposes of providing and/or administrating our content services;
It does not apply to any other personal data, and notably personal data collected by:
- any third party regardless whether collected through any application; or
- any content (including advertising) that may link to or be accessible from or on the Website.
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, “we”, “us” and “our” refer to EMAlpha LLC. For more information about us, see Section 11.
We collect and process personal data mainly from our customers and suppliers while doing business with them and we collect and receive personal data on this Website and through social networks. The personal data we process is mainly business contact information from our clients and suppliers and also information you and our customers provide when using our products or accessing our websites or other applications. We also collect and collate information (including some personal data) from third party suppliers and public sources to make available to our customers as part of the services we offer to them. We mainly process the personal information in order to provide our services and to fulfill our contractual obligations and to improve our products and offerings. We do not sell such personal data to third parties for their own use but we might share it with third parties when there is a legal requirement to do so or where we need a third party to fulfill our services. We transfer personal data within our group based on an Intragroup-Data-Transfer-Agreement which subject to the GDPR. This notice informs you also about our retention policy. You have rights in respect of your personal data. To learn more about those rights, please read section 7.
- How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your website user account data (“account data“). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.4 We may process information relating to our customer relationships, including customer contact information, that you enter into with us and/or through our website (“customer relationship data“). The customer relationship data may include your contact details, your employer details, your job title or role, and information contained in communications between us and you or your employer. The source of the customer relationship data is you and/or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping proper records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
3.5 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
3.6 We may process information contained in or relating to any communication that you send to us (“correspondence data”). This data may include the communication content and metadata associated with the communication. The source of this data is metadata associated with communications made using the website contact forms. This data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.7 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.8 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.9 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.10 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
- Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose usage data, account data, profile data, enquiry data, customer relationship data, notification data and correspondence data to our suppliers or subcontractors insofar as reasonably necessary for the proper administration of our website and business.
Personal Data that we collect
We collect several types of information and personal data:
- that relates to an identified or identifiable individual, such as name, postal address, email address, telephone number, IP or MAC address etc. and related information, such as the contents of an email (“personal data”);
- about your internet connection, the equipment you use to access our Website and usage details (e.g. statistics) regarding our products (“usage information”).
We collect this information and personal data:
- directly from you and/your employees when you or they provide it to us;
- automatically as you and/or your employees navigate through the site and/or use our products. Information and personal data collected automatically may include usage information, IP addresses, and information and personal data collected through cookies, web beacons, and other tracking technologies;
- from public and third-party sources.
Personal Data You Provide to Us
The personal data we collect may include:
- personal data that you provide by conducting business with us, by filling in forms on our Website, or at a trade show, or anywhere else we conduct business, by subscribing to newsletters or other communications, or by corresponding with us by phone, e-mail or otherwise using our contact details. This includes personal data provided at the time of requesting information or services, soliciting business or performing a service. We may also ask you for personal data when you enter a contract with us, or a contest or promotion sponsored by us, and when you report a problem;
- records and copies of your correspondence (including email addresses);
- your responses to surveys that we might ask you to complete for research purposes;
- your search queries on the Website;
- during the contractual relationship for execution of the supplier or customer contract;
- by using our incident management and project management tools and applications;
- by communicating with our customer care teams for error resolving issues, training and support;
- Your usage of our products and relating tools and applications.
Typically, the personal data you give us may include name, business affiliation, business address, telephone number, and email address, and any personal details required to conduct business with you or to resolve any enquiries or complaints.
We will indicate to you when personal data is required to enter into a contract with you (such as in anticipation of a services agreement) or to perform a contract with you (such as to provide services at your request), and failure to provide any personal data may result in our inability to provide requested services or products.
Personal Data We Collect From Public Sources and Third Parties
In order to provide our content services to our customers, we rely on content provided by third party suppliers, as well as content that is available to the public. Some of that content includes general information about names of directors, registered board members, managers, fund managers and other official persons of companies published on public accessible websites, letterheads, prospects, annual financial statements, invitations to shareholder meetings etc.
Lawful Grounds for Processing
All processing and use of your personal data is justified by a “lawful ground” for processing. In the majority of cases, processing will be justified on the lawful ground that:
- the processing is necessary to perform a contract with you or take steps to enter into a contract at your request, such as to negotiate a contract with us, to fill an order, or to provide product information that you have requested;
- the processing is necessary for us to comply with a relevant legal obligation, such as keeping accounting records;
- the processing is in our legitimate interests, which are not overridden by the interests and rights of the relevant individual whose personal data is collected; and
- you have consented to the processing.
Where we rely on our legitimate interests to process personal data, those interests are:
- to use supplier, customer and website user data to conduct and develop our business activities and improve our services in order to grow our business and profitability, while limiting the use of their personal data to purposes that support the conduct and the development of our business and the improvement of our services;
- to use third party supplier and publicly available content (which in some instances includes personal data) in order to provide our content services to customers for their business purposes, which may include, but not be limited to taking investment decisions or compliance with applicable laws and regulations such as insider trading regulations and anti-bribery legislation, but which are for our customers to determine and explain in their privacy notices).
Why We Collect Personal Data
The following is an overview of our purposes for using your personal data. Additional details on how we process your personal data may be provided to you in a separate notice or contract.
We use the personal data we collect to:
- provide customer services, including products and services; to take, verify, process, and deliver orders and returns; to process payments, technical support, or other similar purposes; and to establish and maintain customer accounts;
- to provide training and after-sales-support on our products and answer to and perform change requests;
- to organize and perform incident management processes;
- to implement projects by working together with customers and their users as part of the project team;
- communicate with customers and suppliers, including responding to requests for assistance and to update them about the status of their orders by postal mail, email, telephone, and/or text message;
- investigate, prevent or take action regarding unauthorized use of our services, illegal activities, suspected fraud or situations involving potential threats;
- to provide you with underlying tools and applications helping to implement projects and solving incidents;
- to discuss, carry out and implement change request and further developments of our products;
- to provide our content services to our customers and to report and administer customers’ users’ usage of third-party information products (e.g. real-time data from stock exchanges etc.);
- administer and manage performance of purchase or sales agreements with our suppliers and customers;
- to enhance the experience for our users, we use notes relating to support provided to specific employees, advisors or agents of customers in relation to our products and services for their future use of our services;
- service your account;
- market and promote our products including through email or equivalent electronic means, to send news and newsletters, special offers and promotions, or to otherwise contact customers about products, services or information;
- process, evaluate and complete certain transactions involving the website, and more generally transactions involving EMAlpha’s products and services;
- operate, evaluate, maintain, improve and develop the Website (including by monitoring and analyzing trends, tracking user behavior, access to, and use of the website for advertising and marketing);
- engage with you about events, promotions, the Website and EMAlpha’s products and services;
- provide you with documentation or communications which you have requested, or which is part of a product;
- correspond with users to resolve their queries or complaints;
- send you marketing communications, where it is lawful for us to do so;
- protect the security of the Website, EMAlpha confidential and proprietary information (which may include personal data), and EMAlpha employees;
- manage, protect against and investigate fraud, risk exposure, claims and other liabilities, including but not limited to violation of our contract terms or laws or regulations;
- share your personal data with third parties in connection with potential or actual sale of our company or any of our assets, or those of any affiliated company, in which case personal data held by us about our users may be one of the transferred assets.
EMAlpha will not sell or rent your personal data you provided to us to third parties.
- Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) All personal data categories except Enquiry and Notification data will be retained for a minimum period of 10 ms following the latest date we had business contact with you or your employer, and for a maximum period of 36 months following the latest date we had business contact with you or your employer; and
(b) Enquiry and Notification data will be retained for a minimum period of 10 ms following the latest date you gave consent, and for a maximum period of 36 months following the latest date you gave consent.
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of all personal data categories will be determined based on the necessity of storing that data for longer than necessary.
5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of significant changes to this policy by email or through the private messaging system on our website.
- Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us by email.
8.0 Data Security
EMAlpha takes reasonable precautions to protect personal data from loss, misuse, unauthorized access, disclosure, altercation, and destruction. Unfortunately, while we work hard to ensure the security of your personal data while it is on our systems, no security measures are perfect, and data transmitted over the Internet cannot be guaranteed to be 100% secure. We cannot and do not ensure or warrant the security of any personal data you transmit, and you do so at your own risk.
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
10.1 We may update this policy from time to time by publishing a new version on our website.
10.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
10.3 We may notify you of significant changes to this policy by email.
- Our details
11.1 This website is owned and operated by EMAlpha LLC.
11.2 Our principal place of business is at Suite 130, 10 Glenlake Parkway, Suite 130, Atlanta, GA 30328, United States of America.
11.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website; or
(d) by email, using the email address published on our website.
12.1 Our representative within the EU with respect to our obligations under data protection law is Pankaj Sharma and you can contact our representative by firstname.lastname@example.org .
12.2 Our representative within the UK with respect to our obligations under data protection law is Pankaj Sharma and you can contact our representative by email@example.com .
- Data protection officer
13.1 Our data protection officer’s contact details are: firstname.lastname@example.org .
California Residents’ Rights under the CCPA
You have specific rights regarding how your personal data is collected and used.
- You have the right to request that EMAlpha disclose our collection and use of your personal information during the past 12 months, specifically:
- Categories of personal information collected;
- Sourced of personal information collected;
- Our business purpose for collecting (or selling) that personal information;
- Categories of third parties with whom we share your personal information;
- Categories of personal information sold or disclosed to third parties.
- You have the right to request a copy of the personal information collected prior to your request in the past 12 months;
- You have the right to request deletion of that information (with exceptions noted by law);
- You have the right to request that your personal information not be sold to third parties, if applicable; and
- You have the right not to be discriminated against because you exercised these rights.
We will respond to your verifiable request to disclose and or delete your personal information within 45 days, providing you with an electronic copy of your information; however, if we up to an additional 90 days as permitted under the CCPA to respond, we will inform you within 45 days of your request.
In the event you request deletion, EMAlpha will be unable to do so, as permitted by the CCPA, in event the personal information is necessary to:
- Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of a business’s ongoing business relationship with you, or otherwise perform a contract between EMAlpha and you;
- Detect security incidents, protect against malicious deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with section 1546) of Title 12 of Part 2 of the Penal Code;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of that information is likely to render impossible or seriously impair the achievement to such research, if you have provided informed consent;
- To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
- Comply with a legal obligation;
- Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided information.
How to Contact EMAlpha to Exercise Your Rights
You can submit your request for disclosure, copies or deletions of your personal information to EMAlpha by contacting us (or contact us with your questions regarding our collection, use and sharing of your personal information):
- Call our compliance officer +1. 917.319.1851
- Visiting emalpha.com/privacy
The CCPA restricts you to two verifiable requests within a 12-month period. Only you or a person registered with the California Secret of State that you authorize to act on your behalf may make a verifiable request regarding your personal information. EMAlpha cannot respond to a request if we are unable to verify your identity or authority to make the request on behalf of another. Please provide information sufficient to confirm your identify or your authority to make the request on behalf of another, and describe your request with sufficient detail that allows us to understand and respond to your request. We will endeavor to respond to your request within 45 days of receipt. If more time is required (up to 90 days), we will inform you of the reason and extension of time required. There is no fee charged for processing your request.
Reservation of Rights
EMAlpha reserves it rights with regard to any verifiable request, its evaluation of what is necessary to comply with the CCPA, and to amend this notice at any time within EMAlpha’s discretion.