Privacy Statement

Introduction

This privacy statement explains how Alpha Financial Markets Consulting PLC and other Alpha group entities (as set out at Section 6) (together, “Alpha” “we” “our” “us”) collects, uses, discloses and retains personal information, including personal information collected through the Alpha website and in connection with the management of Alpha’s clients, prospective employees and contractors. Alpha is committed to respecting and protecting your privacy and complies with all applicable data protection and privacy laws.

This privacy statement is divided into four Sections:

  1. Alpha Website Privacy Statement
  2. Alpha CRM Privacy Statement
  3. Alpha Recruitment Privacy Statement
  4. Alpha Contractor Privacy Statement

Please carefully review all Sections that apply to you.

If you provide us with the personal information of other persons (such as family members or work colleagues), please make sure the respective persons are aware of this privacy statement and only provide us with their data if you are allowed to do so and such information is correct.

Alpha reserves the right to modify or update this privacy statement at any time without notice and any changes will be posted on this page.

 

1. Alpha Website Privacy Statement

Application

This Section 1 explains how Alpha collects, uses, discloses and retains personal information when you access and use the Alpha website.

Collection of personal information and purposes of collection

Some areas of our website may require you to give us personal information, which is information that enables us to identify you, including but not limited to your name, email or other address. Should you provide Alpha with your contact information through our website (such as name, company, address, and email address) this information will only be used to contact you for the purpose for which you have expressed an interest, such as the services, career opportunities, surveys and seminars of Alpha. Alpha may also collect domain information from your visit to customise and improve your experience on our website.

We will process your personal information as necessary for the purpose of our legitimate interests (including to respond to your queries and promote our business) and on the basis of your consent to the extent required by applicable data protection and privacy laws (for example, where we use cookies on our website). For more information, please refer to the “Cookies” section of this Section 1.

The amount and type of personal information collected, used, and disclosed shall be limited to what is necessary to achieve the purposes outlined in this Section 1.

Data security

Alpha is committed to protecting your personal information and ensuring that we securely store any personal information we collect in accordance with applicable data protection and privacy laws. We may hold your personal information in hard copy (paper) or electronic form.

Whilst Alpha takes all reasonable precautions to protect personal information from loss, misuse, alteration or destruction and complies with all applicable data protection and privacy laws, data transmission over the internet may not be adequately secured by the sender. As a result, Alpha cannot ensure the secure receipt of any information that is sent to Alpha by this medium and any such information is sent at your own risk.

Data recipients

Your personal information may be shared across the Alpha group throughout the world (including in Europe, the United Kingdom, the United States, Canada, Singapore and Australia) and with certain third parties. Where third parties are given access to your personal information, Alpha will take the required contractual, technical and organisational measures to ensure that your personal information is processed only to the extent necessary and in accordance with applicable data protection and privacy laws.

In particular, the following categories of recipients may process your personal information:

  • service providers that provide services on our behalf, including IT service providers;
  • legal and other professional advisors and auditors; and
  • regulators and law enforcement agencies.

Third country transfers

Alpha may process your personal information outside of the country in which you are resident or the country in which your personal information was collected, where data protection and privacy laws may not offer the same level of protection available in your home country or the country where your personal information was collected. Your personal information may be shared overseas with certain third parties located throughout the world (including in Europe, the United Kingdom, the United States, Canada, Singapore and Australia). For example, the hosting locations of our IT infrastructure may be outside of the jurisdiction where we collected your personal information. Alpha maintains a list of the locations of its sub-processors which is available on request. Where your personal information is transferred overseas by us or on our behalf, we use appropriate safeguards to protect your personal information to a standard essentially equivalent to the law applicable to the country in which you are resident. These safeguards include implementing applicable standard contractual clauses for transfers of personal information between our group companies, which require group companies to protect personal information they transfer from the jurisdiction in which it was collected in accordance with applicable data protection and privacy laws and take reasonable steps to ensure that the overseas recipient does not breach applicable data protection and privacy laws in relation to your personal information. You may obtain information and a copy of the relevant safeguard relied on for the transfer of your personal data by contacting us via the details set out in the “Contact us” Section.

Retention period

Alpha is committed to protecting your personal information and ensuring that we securely store any personal information we collect in accordance with applicable data protection and privacy laws.

Alpha will only hold your personal information for as long as required to undertake the purposes of our processing, to comply with our legal obligations, to enforce or protect our legal rights, or a longer period if required or permitted by applicable law.

Business Relationships

Our website may sometimes contain links to other websites. Please review the policies of these websites individually – Alpha is not responsible for the privacy practices or the content of such websites.

Cookies

Cookies store small amounts of data on your computer about your visit to the Alpha website. You can give consent to cookies, or withdraw any consent you have previously given, through our cookies tool or your browser settings.

Cookies can be categorised in accordance with how long they are saved on your device: “session cookies” are short-term cookies that are only saved on the device’s memory for the duration of a user’s visit to the website, whereas “persistent cookies” remain saved in the device’s memory for a set period of time, even after the browser session has ended. The expiry period for each cookie is set out below.

What cookies do we use?

  • Strictly necessary cookies – enable core functionality such as security, network management, and accessibility. You can disable these by changing your browser settings, but this may affect how the website functions. You cannot disable these using our cookies tool.We use the following strictly necessary cookies:

Name

Source

Purpose

Expiry

PHPSESSID PHP This is a general purpose identifier used to maintain user session variables; for example, maintaining a logged in status for a user between pages. Session
ASP.NET_SessionId otp.tools.invenstis.com Used to maintain an anonymised user session by the server. Session
AWSALBCORS and AWSALBTGCORS otp.tools.invenstis.com Used for load balancing, specifically for continued stickiness support. 7 days

 

  • Performance cookies – these cookies are set to understand how users interact with the website.We use the following performance cookies:

Name

Source

Purpose

Expiry

_ga Google Analytics This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and is used to calculate visitor, session and campaign data for analytics reports. 2 years
_gid Google Analytics Used to distinguish users of the Alpha website. 1 day
_cf_bm CloudFlare This cookie is used to distinguish between humans and bots. This is used to make valid reports on the use of the Alpha website. 30 minutes

 

  • Targeting cookies – these cookies are set to tailor marketing to you and your interests.

We use the following targeting cookies:

Name

Source

Purpose

Expiry

YSC .youtube.com This cookie is set to track views of embedded videos. Session
VISITOR_INFO1_LIVE .youtube.com This cookie is set to keep track of user preferences for YouTube videos embedded in sites; it can also determine whether the Alpha website visitor is using the new or old version of the YouTube interface. 6 months

 

Refusing or restricting cookies  

You may refuse to accept, or withdraw your previous consent to, cookies in two ways:

  • our cookies tool, which you can access at the bottom of our website. Our cookies tool will record when you have consented to non-essential cookies. Essential or strictly necessary cookies cannot be disabled using the tool because they are necessary to make the website function. You may change your mind about the cookies you have selected through our cookies tool by updating your choices in our tool at any time. Please be aware that our cookies tool cannot be used to block cookies on third party websites linked to our website. In order to remove these cookies, you will need to visit the relevant third party site and follow the instructions in their cookie notices. Alternatively, turn off these cookies using your browser settings; or
  • you may refuse the use of cookies by selecting the appropriate settings in your browser.

Individual data rights

Depending on which laws apply to your personal information, you may have certain statutory rights in relation to your personal information. Subject to any exemptions provided by applicable law, if your personal information is processed by Alpha in respect of your use of our website, you may have the following rights:

  • to receive confirmation from Alpha as to whether we process your personal information, and where we do, access to that personal information and certain other information;
  • to request the rectification of any inaccurate personal information that we hold about you;
  • to request the erasure of your personal data in certain circumstances;
  • to request the restriction of our processing of your personal data in certain circumstances, for example in certain scenarios where we are unable to comply with a request to erase your personal data;
  • to receive a copy of the personal information that you have provided to Alpha in a structured, machine-readable and commonly-used format and/or, where possible, to request we transmit that personal data to another organisation;
  • to object to certain processing of your personal data and to automated decision making; and
  • where our processing is based on your consent, subject to applicable law, you have the right to withdraw consent at any time by contacting us.

Where you are given the option to share your personal information with us, you can always choose not to do so. If you object to the processing of your personal information, to the extent permitted by applicable data protection and privacy law, we will respect that choice. This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in this Section 1.

Right to lodge a complaint

If you have any concerns or complaints regarding this privacy statement or our handling of your personal information, you may have recourse to additional remedies under applicable data protection and privacy laws.

You may make a complaint about our privacy practices using the contact details set out below. We will investigate and respond to a complaint within any relevant time periods stipulated by applicable data protection and privacy laws.

You may also have the right to contact or lodge a complaint with your local data protection authority (as set out at Section 5).

Contact Us

If you have any questions or comments about our privacy statement or practices, this Section 1 or Alpha’s personal information handling practices, please contact us at:

Head of Legal

legal@alphafmc.com

60 Gresham Street, London EC2V 7BB

+44 (0) 207 796 9300

enquiries@alphafmc.com

2. Alpha CRM Privacy Statement

Application

This Section 2 applies to you if you are an Alpha client. Please note that “client” may refer to any of the following: client organization, TPA or Vendor, or a third party such as a recruitment agency or industry body.

2.1. Categories of personal information

When we refer to “personal data” or “personal information” we mean any information relating to an identified or identifiable individual. This could include information that could identify an individual, directly or indirectly, in particular, by reference to an identifier such as a name, ID number, location data or online identifier (however, in some jurisdictions, such as Canada, this does not include information that is publicly available in a telephone directory or that is business contact information that enables an individual to be contacted at a place of business). It also includes factors specific to an individual’s characteristics.

Alpha collects limited personal information on its clients; and this primarily encompasses the following types of information (to the extent such information constitutes personal information under applicable data protection and privacy laws):

  • contact and organisation related material such as an individual’s work email and business role; and
  • business communications, such as email exchanges or in-person meetings.

2.2. Sources of personal information

We collect your personal information in a variety of ways during the course of your dealings with us. For example, when you engage with us in respect of a project we are undertaking for your organisation. We also gather information about you when you provide it directly to us, for example when you correspond with your contacts within Alpha.

We may also receive information about you from other sources, such as directly from your organisation or via online resources including LinkedIn and other publicly available sources. We combine information about you from various sources, including the information that you have provided to us directly.

2.3. Purposes of processing

Alpha collects, uses and otherwise processes client personal information for the following purposes:

  • to manage past, current and future business engagements;
  • to send information such as engagement related proposals and materials, industry relevant information (such as regulatory digest newsletters), and event invitations;
  • to send direct marketing communications; and
  • to comply with our legal and regulatory obligations.

2.4. Lawful basis for processing

Alpha only collects, uses, and otherwise processes personal information for the purposes outlined above and in accordance with applicable data protection and privacy laws.

We process personal information on the following bases:

  • for legitimate business purposes, including ensuring that Alpha can: (i) maintain its relationships with existing clients, (ii) manage past, current and future client engagements and (iii) promote its services and products;
  • for the performance of a contract that we have entered into with our client; and
  • consent (including, to the extent required by applicable data protection law, for the purposes of sending direct marketing to individuals in a personal capacity by email, SMS or other electronic message).

2.5. Data recipients

Your personal information may be shared across the Alpha group throughout the world (including in Europe, the United Kingdom, the United States, Canada, Singapore and Australia) and with certain third parties such as:

  • service providers that provide services on our behalf, including IT service providers;
  • legal and other professional advisors and auditors; and
  • regulators and law enforcement agencies.

Where third parties are given access to your personal information, Alpha will take the required contractual, technical and organisational measures to ensure that your personal information is only processed to the extent necessary and in accordance with applicable data protection and privacy laws.

2.6. Third country transfers

Alpha may process your personal information outside of the country in which you are resident or the country in which your personal information was collected, where data protection and privacy laws may not offer the same level of protection available in your home country or the country where your personal information was collected. Your personal information may be shared overseas with certain third parties located throughout the world (including in Europe, the United Kingdom, the United States, Canada, Singapore and Australia). For example, the hosting locations of our IT infrastructure may be outside of the jurisdiction where we collected your personal information. Alpha maintains a list of the locations of its sub-processors which is available on request. Where your personal information is transferred overseas by us or on our behalf, we use appropriate safeguards to protect your personal information to a standard essentially equivalent to the law applicable to the country in which you are resident. These safeguards include implementing applicable standard contractual clauses for transfers of personal information between our group companies, which require group companies to protect personal information they transfer from the jurisdiction in which it was collected in accordance with applicable data protection and privacy laws and take reasonable steps to ensure that the overseas recipient does not breach applicable data protection and privacy laws in relation to your personal information. You may obtain information and a copy of the relevant safeguard relied on for the transfer of your personal data by contacting us via the details set out in the “Contact us” Section.

2.7. Retention period

Alpha is committed to protecting your personal information and ensuring that we securely store any personal information we collect in accordance with applicable data protection and privacy laws. We may hold your personal information in hard copy (paper) or electronic form.

Alpha will only hold your personal information for as long as required to undertake the purposes of our processing and to comply with Alpha’s legal obligations or enforce or protect Alpha’s legal rights, or a longer period required or permitted by applicable law.

We hold personal information about our clients for the following periods:

  • data relating to prospective clients will be retained for up to five years, after which the record will be deleted if there is no recorded contact between Alpha and the prospective client;
  • data relating to clients will be retained for the duration of the client relationship plus a further period to comply with certain obligations, legal requirements and best practices.

We will also retain your personal information for as long as necessary in connection with any legal action or any investigations involving Alpha.

We take steps to destroy or anonymise data that we no longer require or as required by applicable data protection and privacy law.

2.8. Individual data rights

Depending on which laws apply to your personal information, you may have certain statutory rights in relation to your personal information. Subject to any exemptions provided by applicable law, if your personal information is processed by Alpha in respect of our client relationship activities, you may have the following rights:

  • to receive confirmation from Alpha as to whether we process your personal information, and where we do, access to that personal information and certain other information;
  • to request the rectification of any inaccurate personal information that we hold about you;
  • to request the erasure of your personal data in certain circumstances;
  • to request the restriction of our processing of your personal data in certain circumstances, for example in certain scenarios where we are unable to comply with a request to erase your personal data;
  • to receive a copy of the personal information that you have provided to Alpha in a structured, machine-readable and commonly-used format and/or, where possible, to request we transmit that personal data to another organisation;
  • to object to certain processing of your personal data and to automated decision making; and
  • where our processing is based on your consent, subject to applicable law, you have the right to withdraw consent at any time by contacting us.

Where you are given the option to share your personal information with us, you can always choose not to do so. If you object to the processing of your personal information, to the extent permitted by applicable data protection and privacy laws, we will respect that choice. This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section 2.3 above.

2.9 Right to lodge a complaint

If you have any concerns or complaints regarding this privacy statement or our handling of your personal data, you may have recourse to additional remedies under applicable data protection and privacy laws.

You may make a complaint about our privacy practices to us at the contact details set out below. We will investigate and respond to a complaint within any relevant time periods stipulated by applicable data protection and privacy laws.

You also have the right to contact or lodge a complaint with your local data protection authority (as set out at Section 5).

2.10. Contact us

Please feel free to contact us if you have any questions about this Section 2 or any of our practices in relation to your personal information. Clients should direct requests to their primary contact at Alpha in the first instance, whether this is to seek further information or to exercise any of your statutory rights.

You can also contact us at:

Head of Legal

legal@alphafmc.com

60 Gresham Street, London EC2V 7BB

+44 (0) 207 796 9300

enquiries@alphafmc.com

3. Alpha Recruitment Privacy Statement

Application

This Section 3 applies to you if you apply for a position with Alpha.

Personal Information

Alpha is committed to the fair treatment of individuals’ personal information and complies with all applicable data protection and privacy laws and regulations. Alpha is also committed to ensuring the security of individuals’ data and has taken appropriate technical and organisational measures to this end. This document provides the required information on the treatment of any personal information that you submit to Alpha or that Alpha may request from you.

3.1. The personal information we collect, hold and otherwise process about you

When we refer to “personal information”, we mean any information that allows an individual to be identified, either directly or indirectly, in particular by reference to an identifier such as a name or identification number or other characteristic that may reveal identity. In respect of our job candidates’ personal information, we typically collect, hold and otherwise process personal information including:

  • contact details such as your name, address, email address and telephone number;
  • your date of birth;
  • recruitment information such as copies of documents proving your right to work, references, CV information, cover letter or correspondence with us as part of the application and recruitment process (such as information about your qualifications, experience, knowledge, skills and abilities);
  • financial information such as your current salary, and your bank account details for the purposes of reimbursing expenses;
  • other people’s opinions about you, including references;
  • travel information such as your name, address, car registration number, personal details required for any public transport tickets;
  • CCTV footage, including photo stills and other information obtained through electronic means such as entry and exit data if you attend an interview at our premises;
  • background checks, including information raised in criminal record checks and government screening checks;
  • information relating to your health and medical conditions as is necessary to ensure your fitness for work and compliance with our health and safety obligations during your application process; and
  • in some jurisdictions, we may collect diversity related data, including information about your racial or ethnic origin, sexual orientation and marital status which is tracked on an aggregated basis to ensure we are attracting diverse candidates.

3.2. Sources of processing

We collect your personal information during the recruitment process for which you have put yourself forward. For example, your CV and cover letter, your communications with Alpha HR staff and, as appropriate, your performance in assessments.

We may also receive information about you from other sources, such as background checking and online resources including LinkedIn and other publicly available sources. We combine information about you from various sources, including the information that you have provided to us directly.

3.3. Purpose of processing

Candidate personal information is collected, held, used and otherwise processed for the following purposes:

  • assessing your suitability for employment;
  • checking you are legally entitled to work in the jurisdiction in which the role you have applied for is based;
  • ascertaining your fitness for work;
  • monitoring equal employment opportunities;
  • establishing, exercising or defending legal rights and disputes; and
  • ensuring compliance with our internal policies and procedures.

3.4. Lawful basis for processing

Alpha collects, uses, processes and discloses personal information only for the purposes outlined in this policy and in accordance with applicable data protection and privacy laws. We limit our collection to what is reasonably required to fulfill the purposes for which it was collected. We process personal information on the following bases:

  • in accordance with your explicit consent;
  • for our legitimate business purposes of our employee recruitment activities; and
  • to comply with certain legal and regulatory obligations of Alpha.

3.5. Data recipients

Your personal information may be shared with Alpha’s affiliates throughout the world (including in Europe, the United Kingdom, the United States, Canada, Singapore and Australia), and with certain third parties such as:

  • service providers that provide services on our behalf, including IT service providers;
  • legal and other professional advisors and auditors; and
  • regulators and law enforcement agencies.

Where third parties are given access to your personal information, Alpha will take the required contractual, technical and organisational measures to ensure that your personal information is only processed to the extent necessary. Third parties will only process your personal information in accordance with applicable law.

3.6. Third country transfers

Alpha may process your personal information outside of the country in which you are resident or the country in which your personal information was collected, where data protection and privacy laws may not offer the same level of protection available in your home country or the country where your personal information was collected. Your personal information may be shared overseas with certain third parties located throughout the world (including in Europe, the United Kingdom, the United States, Canada, Singapore and Australia). For example, the hosting locations of our IT infrastructure may be outside of the jurisdiction where we collected your personal information. Alpha maintains a list of the locations of its sub-processors which is available on request. Where your personal information is transferred overseas by us or on our behalf, we use appropriate safeguards to protect your personal information to a standard essentially equivalent to the law applicable to the country in which you are resident. These safeguards include implementing applicable standard contractual clauses for transfers of personal information between our group companies, which require group companies to protect personal information they transfer from the jurisdiction in which it was collected in accordance with applicable data protection and privacy laws and take reasonable steps to ensure that the overseas recipient does not breach applicable data protection and privacy laws in relation to your personal information. You may obtain information and a copy of the relevant safeguard relied on for the transfer of your personal data by contacting us via the details set out in the “Contact us” Section.

3.7. Retention period

Alpha is committed to protecting your personal information and ensuring that we securely store any personal information we collect in accordance with applicable data protection and privacy laws. We may hold your personal information in hard copy (paper) or electronic form.

Your personal information will be retained by Alpha for 3 years from the close of the recruitment process so that we may contact you in the future if there are further opportunities, unless you have informed us that you are no longer interested in a role with Alpha. Alpha may also delete certain records from your recruitment process within this timeframe if we deem that they are no longer required. Records will always be retained, destroyed and/or anonymised in line with relevant statutory retention periods.

3.8. Individual data rights

Depending on which laws apply to your personal information, you may have certain statutory rights in relation to your personal information. Subject to any exemptions provided by applicable law, if your personal information is processed by Alpha, you may have the following rights:

  • to receive confirmation from Alpha as to whether we process your personal information, and where we do, access to that personal information and certain other information;
  • to request the rectification of any inaccurate personal information that we hold about you;
  • to request the erasure of your personal data in certain circumstances;
  • to request the restriction of our processing of your personal data in certain circumstances, for example in certain scenarios where we are unable to comply with a request to erase your personal data;
  • to receive a copy of the personal information that you have provided to Alpha in a structured, machine-readable and commonly-used format and/or, where possible, to request we transmit that personal data to another organisation;
  • to object to certain processing of your personal data and to automated decision making; and
  • where our processing is based on your consent, subject to applicable law, you have the right to withdraw consent at any time by contacting us.

Where you are given the option to share your personal information with us, you can always choose not to do so. If you object to the processing of your personal information, to the extent permitted by applicable data protection and privacy laws, we will respect that choice. This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section 3.3.

3.9. Right to lodge a complaint

If you have any concerns or complaints regarding this privacy statement or our handling of your personal data, you may have recourse to additional remedies under applicable data protection and privacy laws.

You may make a complaint about our privacy practices using contact details set out below. We will investigate and respond to a complaint within any relevant time periods stipulated by applicable data protection and privacy laws.

You also have the right to contact or lodge a complaint with your local data protection authority (as set out at Section 5).

3.10. Contact Us

If you have any questions or comments about this Section 3 or Alpha’s personal information handling practices, please contact us via email at:

Head of Legal

legal@alphafmc.com

60 Gresham Street, London EC2V 7BB

+44 (0) 207 796 9300

enquiries@alphafmc.com

Alternatively, if you have any questions about anything contained within this Section 3 please don’t hesitate to reach out to your contact point at Alpha.

4. Alpha Contractor Privacy Statement

Application

This Section 4 applies to you if you are a contractor engaged by Alpha to perform services.

Personal Information

Alpha is committed to the fair treatment of individuals’ personal information and complies with all applicable data protection and privacy laws and regulations. Alpha is also committed to ensuring the security of individuals’ data and has taken appropriate technical and organisational measures to this end.

This Section 4 explains how we collect, use and otherwise process your personal information. We limit our collection of personal information to what is reasonably required to fulfill the purposes for which it was collected.

You are advised to review this Section 4 periodically as it may change from time to time. You will also receive training on data protection.

4.1. The personal information we collect, hold and otherwise process about you

When we refer to “personal information” or “personal data” we mean any information relating to an identified or identifiable individual. This could include information that could identify an individual, directly or indirectly, in particular by reference to an identifier such as a name, ID number, location data or online identifier. It also includes factors specific to an individual’s characteristics, (however, in some jurisdictions, such as Canada, personal information would not include information that is publicly available in a telephone directory or that is business contact information that enables an individual to be contacted at a place of business).

In respect of our contractors, we typically collect, hold and otherwise process personal information including:

  • your personal contact information, including name, title, addresses, telephone numbers, and personal email addresses;
  • your personal details, including name, title, surname, birth date, government issued national identification or passport number, gender, civil status, beneficiaries and dependents, emergency contact information and photograph;
  • engagement information, including copies of your right to work documentation, background checks, references and other information included in your CV, cover letter or correspondence with us as part of the engagement process (such as information about your qualifications, experience, knowledge, skills and abilities);
  • to the extent necessary, disciplinary and grievance records including details contained in or relating to any disciplinary or grievance investigations or proceedings;
  • information about your engagement terms;
  • bank account details, payroll records and tax status information;
  • records containing information about incidents that involve or relate to you;
  • information about your usage on our information and communications systems or other electronic systems;
  • references or feedback on your performance by colleagues or customers;
  • information about business travel and expenses, including name, address, vehicle registration number (if applicable for company or private car), personal details required for any travel, hotel, insurance, personal or corporate banking details or personal and corporate credit card details;
  • position/role details, work contact details, work history, engagement and termination reasons, and date and length of service;
  • absence and leave records, as they may be agreed to apply to you;
  • CCTV footage and other information obtained through electronic means, such as entry and exit data, if you perform services on Alpha premises; and
  • office data, including workplace telephone numbers, work address and room location, office status and work email address (to the extent such information constitutes personal information under applicable law).

4.2. Sources of personal information

We collect your personal information during the course of your engagement with us. For example, material submitted during the onboarding process, or records generated when you engage with our internal departments. We gather information about you when you provide it to us, for example your CV and details to arrange payment for your services.

We may also receive information about you from other sources, such as online resources including LinkedIn and other publicly available sources. We combine information about you from various sources, including the information that you have provided to us directly.

4.3. Purpose of processing

Contractor information is collected, held, used and otherwise processed for the following purposes:

  • Background checks and onboarding

    such as assessing your suitability for the engagement, checking you are legally entitled to work in the jurisdiction in which your engagement is based, confirming your fitness for work, establishing a contractual relationship and determining the terms of your engagement.

  • Personnel administration

    , such as invoice administration, general administration of your service contract, facilitating communications, to deploy potential contractors on client projects, supporting any business or administrative function required (e.g. business visas), making business travel arrangements, and administering and managing our business operations;

  • Compliance with legal and regulatory obligations

    , including complying with health and safety obligations, complying with applicable laws and regulations;

  • General business purposes

    , including ensuring business continuity, strategic planning and project management, budgeting and financial management and reporting;

  • Post-engagement relations

    , including to contact contractors about future opportunities;

  • Managing Alpha’s network and IT systems

    , such as operating and managing the information and communications systems to allow you to use them, to confirm you are using appropriately our information and communications systems and other electronic systems such as the internet, and ensuring network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution; and

  • To establish, exercise, or defend legal rights and disputes

    .

Alpha also may require you to submit and periodically update a CV so that we can provide clients with information relevant to our project engagements. This experience, as well as your LinkedIn profile, may also be used by ‘Stitched’, a third party provider we are engaging to create experience profiles. While you work as a contractor for Alpha, you may be asked to participate.

We collect, use, process and disclose personal information only for the purposes outlined in this privacy statement and in accordance with applicable data protection and privacy laws. We do not collect, use, disclose or otherwise process, personal information for any purpose or in any way other than as described in this document (or, to the extent permitted under applicable data protection and privacy laws, any purpose directly related to, or compatible with, such purpose), unless we are required or permitted by applicable data protection and privacy laws to do so, you are so informed at the time of collection, or we have obtained your consent, directly or indirectly, to use or disclose your personal information for another purpose or in another manner.

4.4. Lawful basis for processing

Alpha collects, uses, discloses and otherwise processes personal information in accordance with applicable data protection and privacy laws and regulations. We process personal information on the following bases:

  • for the legitimate interests of Alpha, including administration, conducting onboarding checks, and to enable the functioning of our business;
  • for the performance of our contract with you; and
  • to comply with certain legal and regulatory obligations of Alpha.

Please note that any failure on the part of any contractor to provide information that Alpha requires in order to meet its contractual obligations may result in Alpha being unable to comply with those requirements. This may result in a delay in your start date working for us, delay in the payment of any funds owed to you, or may ultimately prevent us from engaging your services.

4.5. Data recipients

Your personal information will be shared with other entities within the Alpha group (including Alpha entities in Europe, the United Kingdom, the United States, Canada, Singapore and Australia), your Engagement Lead and appropriate levels of your management chain, and personnel and other departments throughout Alpha.

In addition, your personal information will be shared with third parties, including companies that provide products and services to us (such as computer backup services, archival storage services, advisory services, payroll services, pension and benefits administration, human resource management services, recruitment services, termination services, IT systems suppliers and support and/or other third party services related to services rendered by us) and with Alpha’s clients.

From time to time, we may also need to make your personal information available to other third parties, such as legal and regulatory authorities, accountants, auditors, lawyers and other outside professional advisors.

All our third-party service providers and entities in our group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes.

4.6. Third country transfers

Alpha may process your personal information outside of country in which you are resident or the country in which your personal information was collected, where data protection and privacy laws may not offer the same level of protection available in your home country or the country where your personal information was collected. Your personal information may be shared overseas with certain third parties located throughout the world (including in Europe, the United Kingdom, the United States, Canada, Singapore and Australia). For example, the hosting locations of our IT infrastructure may be outside of the jurisdiction where we collected your personal information. Alpha maintains a list of the locations of its sub-processors which is available on request. Where your personal information is transferred overseas by us or on our behalf, we use appropriate safeguards to protect your personal information to a standard essentially equivalent to the law applicable to the country in which you are resident. These safeguards include implementing applicable standard contractual clauses for transfers of personal information between our group companies, which require group companies to protect personal information they transfer from the jurisdiction in which it was collected in accordance with applicable data protection and privacy laws and take reasonable steps to ensure that the overseas recipient does not breach applicable data protection laws in relation to your personal information. You may obtain information and a copy of the relevant safeguard relied on for the transfer of your personal data by contacting us via the details set out in the “Contact us” Section.

4.7. Retention period

Alpha is committed to protecting your personal information and ensuring that we securely store any personal information we collect in accordance with applicable data protection and privacy laws. We may hold your personal information in hard copy (paper) or electronic form.

Alpha will only hold your personal information for as long as required to undertake the purposes of our processing, plus a prescribed period of time as required or permitted by applicable laws in your jurisdiction.

We hold personal information about contractors for the following periods:

  • contractor contact and CV data will be held by Alpha for up to 3 years following termination or expiration of your engagement by us, at which point we contact individuals to ask whether they would still be interested in offering contractor services to Alpha and update our records accordingly.
  • Finance and certain other records will be retained for as long as necessary for Alpha’s accounting purposes and to ensure that contractors are correctly remunerated for their time and expenses, plus a period of 7 years in case any legal action arises relevant to this information.

We will also retain your personal information for as long as it is required in connection with legal action or any investigations involving Alpha.

We take steps to destroy or anonymise data that we no longer require or as required by applicable data protection and privacy law.

4.8. Individual data rights

Depending on which laws apply to your personal information, you may have certain statutory rights in relation to your personal information. Subject to any exemptions provided by applicable law, if your personal information is processed by Alpha, you may have the following rights:

  • to receive confirmation from Alpha as to whether we process your personal information, and where we do, access to that personal information and certain other information;
  • to request the rectification of any inaccurate personal information that we hold about you;
  • to request the erasure of your personal data in certain circumstances;
  • to request the restriction of our processing of your personal data in certain circumstances, for example in certain scenarios where we are unable to comply with a request to erase your personal data;
  • to receive a copy of the personal information that you have provided to Alpha in a structured, machine-readable and commonly-used format and/or, where possible, to request we transmit that personal data to another organisation;
  • to object to certain processing of your personal data and to automated decision making; and
  • where our processing is based on your consent, subject to applicable law, you have the right to withdraw consent at any time by contacting us.

4.9. Right to lodge a complaint

If you have any concerns or complaints regarding this privacy statement or our handling of your personal data, you may have recourse to additional remedies under applicable data protection and privacy laws.

You may make a complaint about our privacy practices to us at the contact details set out below. We will investigate and respond to a complaint within any relevant time periods stipulated by applicable data protection and privacy laws.

You also have the right to contact or lodge a complaint with your local data protection authority (as set out at Section 5).

4.10. Contact Us

If you have any questions or comments about our privacy statement or practices, please contact us at:

Head of Legal

legal@alphafmc.com

60 Gresham Street, London EC2V 7BB

+44 (0) 207 796 9300

enquiries@alphafmc.com

5. Data protection authorities

UK

– Information Commissioner’s Office (ICO). Information on raising a complaint is available on the ICO’s website (https://ico.org.uk/concerns/)

EU

– A list of EU data protection authorities by jurisdiction is available at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Canada

– Federal Privacy Commissioner or your provincial Privacy Commissioner, as applicable

Australia

– The Office of the Australian Information Commissioner, which can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au

Switzerland

– Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

6. Relevant Alpha entities

The list below details the Alpha entities which may act as a controller for your data in conjunction with Alpha Financial Markets Consulting PLC.

COMPANY NAME

COMPANY NUMBER

REGISTERED ADDRESS

AIVIQ Limited (11480862) 60 Gresham Street, London, EC2V 7BB, UK
Alpha Financial Markets Consulting (Luxembourg) S.A. (B137955) 19/21 route d’Arlon – bloc B, L-8009 Strassen, Luxembourg
Alpha Financial Markets Consulting Australia PTY Limited (631221862) 383-385 George Street, Sydney NSW 2000
Alpha Financial Markets Consulting Group Limited (07160664) 60 Gresham Street, London, EC2V 7BB, UK
Alpha Financial Markets Consulting Hong Kong Limited (2549029) 22/F., Neich Tower, 128 Gloucester Road, Wanchai, Hong Kong
Alpha Financial Markets Consulting Netherlands BV (61668451) Strozzilaan 101, Amsterdam, 1083 HN, The Netherlands
Alpha Financial Markets Consulting S.A.S. (523666063) 6 Square de l’Opera Louis Jouvet, 75009 Paris, France
Alpha Financial Markets Consulting Singapore Pte Ltd (201629440W) OUE 6A Shenton Way, Level 04-01, Singapore, 068815
Alpha Financial Markets Consulting Switzerland S.A. (CHE-432.187.554) Bleicherweg 10, 8002 Zürich, Switzerland
Alpha Financial Markets Consulting UK Limited (04710715) 60 Gresham Street, London, EC2V 7BB, UK
Alpha Financial Markets Consulting, Inc. (26-4822447) 575 Fifth Avenue, New York, NY 10017, USA
Alpha FM Consulting Canada Inc (BC1275236) Suite 1700, Park Place, 666 Burrard Street, Vancouver, BC V6C2X8, Canada
Alpha  Financial  Markets  Consulting (Insurance)  France SAS (907780217) 6 Square de l’Opéra Louis Jouvet, 75009 Paris, France
Alpha FMC Bidco Limited (9928343) 60 Gresham Street, London, EC2V 7BB, UK
Alpha FMC Group Holdings Limited (08555831) 60 Gresham Street, London, EC2V 7BB, UK
Alpha FMC Group Limited (08506571) 60 Gresham Street, London, EC2V 7BB, UK
Alpha FMC Group Nominees Limited (08936452) 60 Gresham Street, London, EC2V 7BB, UK
Alpha FMC Midco 2 Limited (9963816) 60 Gresham Street, London, EC2V 7BB, UK
Alpha FMC Midco Limited (9928345) 60 Gresham Street, London, EC2V 7BB, UK
Alpha FMC Trustee Limited (10773199) 60 Gresham Street, London, EC2V 7BB, UK
Alpha Technology Services Consulting Limited (09244222) 60 Gresham Street, London, EC2V 7BB, UK
Alpha Technology Services Consulting S.A.S. (881001267) 6 Square de l’Opera Louis Jouvet, 75009 Paris, France
Axxsys Danmark ApS (40121757) Flaesketorvet 68, DK-1711 Copenhagen, Denmark
Axxsys Financial Software Consulting Canada Ltd (BC0956822) 1800-13401 108th Avenue, Surrey, British Columbia V3T 5T3
Axxsys UK (04967647) New Broad Street House, 35 New Broad Street, London, EC2M 1NH, UK
Axxsys USA, Inc (5349312) Incorp Services Inc One Commerce Center,1201 Orange Street #600,Wilmington, Delaware 19899
Lionpoint GmbH (Cologne: # HRB 107306) (Munich: # HRB 265516) c/o KUNZ Rechtsanwälte, Antoniterstraße 14-16, Köln, 5066
Lionpoint Group (UK) Limited (09869494) 5 Upper St. Martin’s Lane, London, WC2H 9EA
Lionpoint Group Pty Limited (635 472 383) Ground Floor, 123 Walker Street, North Sydney NSW 2060
Lionpoint Group SA (CHE-305.144.702) Rue d’Italie 11, 1204 Geneva, Switzerland
Lionpoint Group, LLC (5522271) 8 The Green, Suite A, Dover, Delaware 19901, United States of America
Lionpoint Holdings, Inc. (7186662) 251 Little Falls Drive, Wilmington, DE 19808-1674, United States Of America
Obsidian Alpha Data Solutions LLC Belgrade (11480862). Serbia
Obsidian Solutions Ltd (09737564) 60 Gresham Street, London, EC2V 7BB, UK
Track Two GmbH (HRB 108642) Mergenthalerallee 73-75, 65760 Eschborn, Germany