Under data protection laws and regulations in the territories where we operate, we have a legal duty to protect any personal data we collect from you. We are committed to protecting your information and strictly adhere to the requirements of such data protection legislation.
What is personal data?
Personal data means any information relating to an individual person who can be identified, directly or indirectly, by reference to a particular identifier, for example, name, email address, date of birth.
What personal data do we collect?
On our contact page, when you make a general inquiry, we ask you for your name, email address and a message. If you inquire about employment, we may ask you to submit a resume and cover letter.
We may collect payment data, such as data necessary for processing payments and fraud prevention, including bank account details and other billing information when you seek financial advisory services from us or one of our business partners.
We may also collect personal data regarding your preferences where it is relevant to services that we provide.
How is your personal data collected?
We use different methods to collect data from and about you, including the following:
- When you or your organization seek financial advisory services from us; When you or your organization subscribe to our services or publications or sign up to receive our marketing communications or to attend a Snowbridge event;
- When you provide us with feedback or use the “Contact” section of our website;
- When you or your organization offer to provide services to us.
- The types of personal information that we collect may vary depending on how you use our website and/or Services. In some rare circumstances, we might also gather other, special categories of personal information or sensitive personal information because you voluntarily provide that data to us.
What is the basis for using your data?
We will only use your personal data when we are allowed to do so by law.
The lawful grounds on which we will use your data, most commonly, will be in the following circumstances:
- The information is necessary to perform the contractual obligations in agreements with you to provide financial products or services you have requested or to fulfill other contractual obligations with you;
- Where it is necessary for our legitimate interests (or those of a third party) and those interests do not override personal rights as indicated by law);Where we need to comply with a legal or regulatory obligation (e.g. anti- money laundering regulations, a court order or to exercise or defend a legal claim;
- Where we provide you with financial advisory services and need to perform on our contract with you; or
- Where you have expressly given us your consent.
For which purposes will we use your personal data?
Your data is collected in our Client Relationship Management (CRM) system when you register to receive news updates or we otherwise receive your contact details to provide you with financial services or products. In addition:
- We may use your personal data to provide financial services and products in accordance with your agreement with you to provide these products and services. We will use your Billing and Usage information, as applicable, to bill you for products and services to provide you with technical and billing support.
- We may use third party providers and subcontractors to process your orders, to support features and services offered through our website or our business partners, and for internal, administrative, and tracking purposes. Service through these providers may necessarily include providing them with some or all of your personal information, Billing Information (for credit card processing, collections, and related matters), and your usage information (for subcontracted services and features), but we will use diligent efforts to restrict use of this information by these third parties to the specific purpose for which the third party has been engaged.
- Your personal information may be used for maintenance and enhancement of the security of the digital information we collect and use to pursue the legitimate business interest in protecting our customers and website visitors against malware, cyber-attack and other crime and security risks;
- Where you have provided us with consent if required (or we have other lawful grounds), we will keep you up to date with transaction announcements, market commentary, relevant sector briefings, Snowbridge announcements and details of events. You may elect not to receive these items (“opt out”) or withdraw your consent to receive them if your consent was required by contacting us at firstname.lastname@example.org or use the “unsubscribe” link at the end of the email or publication you receive from us.
- Snowbridge specifically reserves the right, to the maximum extent permitted by law, to use or disclose any personal information (a) for the purposes of enforcing our user agreements, use policies and the like or (b) when requested by law enforcement agencies as permitted by applicable law, if we reasonably suspect a violation of our user agreements, use policies or any applicable law
How long will we keep your personal data?
We will hold your personal information on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity or Services; (ii) any retention period that is required by laws and regulations (iii) the end of the period in which litigation or investigations might arise in respect of the services and which law requires us to maintain your personal information. We may also retain log files for internal analysis purposes, though we would retain them for only a brief period except in cases where we are legally required to retain them for longer periods, and in cases where they are used for site safety and security or to improve website functionality.
When it is no longer necessary trust to retain your personal data, we will delete or destroy it.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and applicable legal requirements.
Will we share your personal data?
We may share your personal data within Snowbridge on a confidential and secure basis where necessary for the purpose of us providing our services to you.
We may use third party providers and subcontractors to process your orders, to support features and services offered through our website or our business partners, and for internal, administrative, and tracking purposes. Service through these providers may necessarily include providing them with some or all of your personal information, Billing Information (for credit card processing, collections, and related matters), and your usage information (for subcontracted services and features), but we will use diligent efforts to restrict use of this information by these third parties to the specific purpose for which the third party has been engaged
We may need to share your personal data with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also share your personal data with our financial auditors, our insurers and insurance brokers and other professional advisers in the course of the advice we provide to you.
Where Snowbridge Advisors or an affiliated organization is sold or acquired or a share of Snowbridge Advisors LLC is purchased we may share your personal information with the purchaser, acquirer or investor. If Snowbridge winds up its business we may transfer any personal information collected to courts, acquirers, creditors or others as part of that process.
We do not sell, rent or exchange your personal data with any third party for commercial reasons.
Privacy of Minors and Children: COPPA
Snowbridge complies with the Children’s Online Privacy Protection Act, (COPPA) which requires the consent of a parent or guardian for the collection of personally identifiable information from children under 13 years of age. Snowbridge does not knowingly collect, use or disclose personal information from children under 13, or equivalent minimum age in the relevant jurisdiction, without verifiable parental consent. However, it is possible that we may inadvertently receive information pertaining to children under 13. If you believe that we have received information about your child who is under the age of 13, please do not hesitate to notify us at email@example.com. When we receive your notification, we will obtain your consent to retain the information or will delete it permanently.
How do keep your personal data secure?
We will take appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way. These measures include information security processes as well as organizational policies and procedures. We endeavor to protect personal information, but we cannot guarantee the security of data transmitted to us or by us. If you do not wish to take on the risk of having your personal information collected, used and disclosed by electronic means over the Internet you should terminate your visit to this Website and should not create an account or use the services.
Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, or to share your information with certain third parties. we will only provide you with such marketing materials or share such information only where we have obtained such consent from you. You may revoke this consent at any time, but please note that information shared after the consent has been revoked may not be retrievable (please also see certain rights that pertain to you if you are a resident of the European Union, below).
Opt-Out: You may opt out from emails, publications or other communications about our products and services by notifying us at firstname.lastname@example.org.
While many browsers permit you to send a signal about your Do Not Track (“DNT”) preferences, we do not respond to DNT signals sent from browsers.
Your personal information that may be protected pursuant to the Personal Information Protection and Electronic Data Act (“PIPEDA”) or provincial laws and regulations may be stored outside Canada and may be stored in jurisdictions in which governmental entities, including law enforcement, may have access to it.
If you reside in a country within the European Union or in a country with similar levels of data protection, please note that some of the recipients of your personal information referenced above may be based in countries outside of the European Union, including the United States whose laws may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your personal information and that comply with our legal obligations. These adequate safeguards may comprise a data transfer agreement with the recipient based on Standard Contractual Clauses approved by the European Commission for transfers of personal information to third countries.
We may also need to disclose your personal information if required to do so by law, by a regulator or during legal proceedings in the country in which your personal information is hosted.
What are your rights? Choice and Control
You can ask us to stop sending you marketing messages at any time by emailing email@example.com at any time.
Subject to certain legal conditions, you are entitled at any time to ask us for a copy of the personal data which we hold about you to the extent provision of a copy is permitted by applicable law. You are also entitled to ask that any information we hold about you is updated or rectified and to object to or restrict our using your personal data, as permitted by applicable law. You can make any of these requests free of charge by contacting us at firstname.lastname@example.org; however, we reserve the right to charge a reasonable fee to the extent permitted by applicable law.
If you are a resident of a Member State of the European Union or a country that permits access to and certain rights relating to your personal information, you have various rights in relation to your personal information. In particular, you have a right to:
- obtain confirmation that we are processing your personal information and request a copy of the personal information we hold about you in a form you can read and provide to another organization electronically.
- ask that we update the personal information we hold about you, or to correct such personal information that you think is incorrect or incomplete.
- ask that we delete personal information that we hold about you, or to restrict the way in which we use such personal information.
- withdraw consent or otherwise object to our processing of your personal information.
Your right to have your personal information deleted does not apply, however, where the information is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by European Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the area of public health in accordance with applicable laws;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- for the establishment, exercise or defense of legal claim
You also have the right to have Snowbridge cease processing your personal information, for reasons that include: (i) you state that the personal information Snowbridge has about you is incorrect; but Snowbridge may retain the information for as long as it requires to check the accuracy of the relevant personal information; (ii) you believe there is no legal basis for Snowbridge’ s processing of your personal information and you demand that Snowbridge restrict your personal information from further processing,; (iii) you contend that Snowbridge no longer requires your personal information but you claim that you require such data in order to claim or exercise legal rights or to defend against third party claims; or (iv) in case you object to the processing of your personal information by Snowbridge on another basis, Snowbridge may retain and process the information for as long as it is required to review as to whether Snowbridge has a prevailing interest or legal obligation in continuing to process your personal information.
You may inquire about the exercise of these rights and, if the laws of your jurisdiction permit, exercise them as permitted by law by contacting email@example.com.