We use a customer relationship management system to collect and process personal data about business contacts such as existing clients, prospective clients and their representatives. Such personal data will typically include name, identity of employer, job title, email address, office address, telephone number and other contact details.

We collect such personal data using various methods, including the channels below:

1. Direct Interactions: we receive personal data directly from the contact to whom the personal data relates. Such direct interactions include, for example, instances when the contact:

2. Requests information about our client services

i. Provides personal data necessary for specific client services or the purposes of “know your customer” controls
ii. Provides a business card to us either in person or virtually
iii. Makes personal data available to us through digital portals and platforms we make available
iv. Registers to participate in our marketing or other promotional events or subscribes to any of our publications  vi. Provides us with feedback.

3. Websites, digital services and marketing: we receive personal data when contacts use our website, electronic portals and platforms which we offer or when contacts receive publications or marketing we send. We also collect personal data by using cookies, server logs and other similar technologies. For more information please see our website visitors policy.

4. Third party sources: we receive personal data concerning contacts from third parties when we:

i. Provide services to third parties who send us contact personal data to enable the provision of such services  ii. Perform “know your client” or other legitimate background checks
iii. Are contacted by third parties who contacts have requested provide us with their personal data on the contacts behalf
iv. Interact with public and regulatory bodies and other authorities concerning contacts.

5. Publicly available sources: we may also collect personal data from publicly available sources including:

i. Public registers of individuals and legal entities
ii. Public registers of sanctioned persons
iii. Online professional networking platforms including LinkedIn
iv. Marketing databases.

We may use such personal data and make it accessible to our people for the following purposes:

  • Managing, administering and developing our business.
  • Providing information to clients, audit entities and prospective client about our services.
  • Identifying our clients or prospective clients’ business needs.
  • Analysing interactions between our people and our contacts to provide information to our management on relationships and trends, including the use of an automated analytical tool to evaluate the frequency and timing of interactions with contacts.

We do not sell or otherwise release any personal data collected from contacts to third parties.

We will not use contact personal data to send marketing materials if the contact has expressly requested through our preference centre not to receive marketing. If our contacts request that we stop processing personal data for marketing purposes, we shall cease processing such personal data for those purposes.

Where we process personal data for the above purposes, we rely on the following lawful bases:

6. Where it is in our, or a third party’s, legitimate interests, provided that:

i.the processing is necessary to pursue the legitimate interests;
ii.the interests of the data subjects do not override the legitimate interests; and
iii. the data subjects have the right to:

a. request deletion of their personal data, provided they object to our processing and their interests override our own or a third party’s;
b. restrict processing of their personal data, provided they object to the necessity of the processing. In such circumstances, processing may be restricted for such time as to allow us to investigate their objections; and
c. object to the processing of their personal data in circumstances where such processing is necessary for a legitimate interest, or where processing is used for marketing purposes.