Privacy notice and summary

SC Lowy is committed to respecting and protecting your privacy.  This privacy notice sets out how we look after your personal data when you visit our website at www.sclowy.com, and tells you about your privacy rights and how certain laws may apply to you.

If you have any queries about this notice or how we use your personal information, please contact us at info@sclowy.com.

Your privacy is important to us. To protect your privacy and help you to make informed choices, we provide this notice explaining our information practices, how you can choose how we use your data, and your rights in relation to your personal data.

In brief, we will only use your information:

  • to optimise our website performance; or
  • where you have consented to us doing so.

This is explained in more detail below.


 

Contents

  1. About us

  2. This privacy notice

  3. What personal data do we collect via the site?

  4. How we collect personal data

  5. How and why we use personal data

  6. How we share personal data

  7. International transfers

  8. Data security

  9. How long we keep personal data

  10. Third party links

  11. Your rights

  12. Changes to this notice or your data


 

  1. About us

    This website www.sclowy.com  (our “site”) is operated by SC Lowy Financial (HK) Limited, a company incorporated in Hong Kong with its principal place of business at 17th Floor, 8 Queen’s Road Central, Hong Kong (“SC Lowy”, also referred to in this notice as “we”, “us” and “our”).
    SC Lowy is a data controller and is responsible for your personal data collected via this site.

    You can contact us about any queries you have regarding this privacy notice at info@sclowy.com.

  2. This privacy notice

    This privacy notice describes how we collect and use information collected through your use of this site. You can use most of this site without giving us any personal data. However, if you wish to take advantage of some of the more personalised services that we make available (such as signing up to receive our updates, or contacting us), you will need to provide certain information. This privacy notice describes how we collect and use information collected through this site. Please read this privacy notice carefully.

    In certain circumstances (for example, if you become our client), we may provide you with additional privacy notices which are relevant to you.

    This site is not intended to collect data of children under the age of 18.

  3. What personal data do we collect via the site?

    We collect different information depending on how you use the site and how you interact with us. ‘Personal data’ means any data which can be associated with you as an individual, either directly or indirectly.

    The personal data we collect via the site may include:

    • Identity information, such as your name, organisation name and position.
    • Contact data, such as your address and email and telephone details.
    • Technical data, such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the site.
    • Usage data, which includes information about how you use the site, and any communications we may receive from you.
    • Marketing and communications data, including your preferences in receiving marketing and other communications from us.

    We will also collect any personal data that you specifically send to us (for example, if you apply for a position with us and send us your CV).

    Our site is not intended for storing or transmitting ‘special categories’ of personal data, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, or health information.  We do not intentionally collect data about actual or alleged criminal offences via our site.

  4. How we collect personal data

    Different personal data is collected in different ways.

    • Personal data you provide to us
      When you sign up to receive news updates, you will provide us with your email address. You will also provide us with personal data when you contact us via the site (including your name and email address), and if you apply for a position with SC Lowy.
    • Personal data we collect automatically
      As you use the site, we will collect certain technical data including your browser type and the Internet Protocol (IP) address used to connect your computer to the internet.
  5. How and why we use personal data

    We will only use your information where:

    • You have given us permission to do so
      If you sign up to receive news alerts or our other mailing lists, we will send you updates and marketing information that you have consented to receive. Likewise, we may need your contact, identity, technical and/or usage information to respond to a question you have asked us, or to register you for an event that you have requested to attend.
      If you apply for a position with SC Lowy, we treat any information you send to us as strictly private and confidential and will only use it in relation to the application you have submitted.
    • We have a legitimate interest (reasonable business purpose) for doing so
      We will use your information for our legitimate business reasons where our doing so will not unduly affect your rights.
      We will use your identity and contact information to keep our records up to date.
      We will use your technical information to:

      • provide and make improvements to the site, system maintenance, support, reporting and hosting of data, and troubleshooting;
      • ensure that the site is secure;
      • analyse how users interact with the site; and
      • address any issues you may experience with the site.

      We may also use any or all of the information above to administer and manage our business in general. If you feel that your interests and fundamental rights outweigh our business purposes, and that we should therefore stop processing your data, please let us know.

    • We need to comply with a legal or regulatory obligation
      In certain circumstances, we may need to retain or use your data to comply with regulations and/or the law.
    • SC Lowy needs it to perform a contract or provide a service that you or your organisation has asked for
      For example, SC Lowy may need your contact, identity and technical information to respond to a question you have asked us via the site.
      Likewise, we may need your contact, identity, technical and/or usage information if you have subscribed to one of our events, or requested our services, we will need your contact and identity data to be able to provide that service to you.
  6. How we share personal data

    We share personal information collected via this site with our offices in Italy and the United Kingdom (together with us, our “Group“). Their details are:

    • SC Lowy UK
      3F
      28-29 Dover St, London
      W1S 4NA,
      United Kingdom
    • SC Lowy Italy
      Office 301 Via Monte di Pietà, 21
      20121 Milano
      Italia

    We may share your information with our trusted third party service providers. When we share your information with our service providers, we will ensure that your data is kept secure and used only in accordance with this notice.

    On rare occasions, we may share personal data when we believe it is necessary to comply with the law, regulation or legal request (including a court order or government inquiry); to enforce or apply our terms of use or other agreements; in the context of a firm reorganisation or restructuring exercise; or to protect the rights, property, or safety of SC Lowy, our employees, our users, or others.

  7. International transfers

    This site is hosted on servers located outside of the European Union.

    When we transfer your data outside of the European Economic Area to a country which the European Commission does not deem to have adequate data privacy laws, we will ensure that such transfer(s) are in accordance with applicable data privacy laws. In respect of transfers within our Group, we have executed a data transfer agreement giving effect to the Model Clauses pursuant to Commission decision 2004/915/EC.

    You can obtain further information in this respect (including a copy of the Model Clauses) by contacting us.

  8. Data security

    The safety of your personal data is important to us, and we use various technical and organisational measures to ensure that your data is secure.

    SC Lowy employs industry standard technologies to protect and secure all personal information in our possession. However, the transmission of information via the Internet is not completely secure. Although we take appropriate measures to safeguard against unauthorised disclosures of information, we cannot guarantee the security of your data.

  9. How long we keep personal data

    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    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 unauthorised 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 the applicable legal requirements.

    For example, the Hong Kong Securities and Futures Commission (SFC) requires us to retain all data for a minimum period of 6 years, while the United Kingdom Financial Conduct Authority (FCA) requires us to retain data in certain circumstances for at least five years.  To find out more about how long we retain personal data, please contact us at please contact us at info@sclowy.com.

  10. Third party links

    This site may contain links to other sites whose information practices may be different than ours. Please consult all third party sites’ privacy notices as we have no control over information that is submitted to, or collected by, third parties.

  11. Your rights

    You have certain rights over your personal data. If the GDPR applies, you may:

    • require us to rectify the personal data we hold about you, where that data is incorrect;
    • require that we restrict the processing of your personal information in certain circumstances;
    • request access to the personal data that we hold about you;
    • require that, in certain circumstances, we delete the personal information we hold about you;
    • require that we provide you with the information that we hold about you in a structured, commonly used and machine-readable format; and/or
    • withdraw your consent to our using your data for marketing purposes at any time.

    You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”), which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, be grateful if you would contact us in the first instance so we can endeavour to deal with your concerns direct.

    If you wish to exercise any of these rights, please contact us at info@sclowy.com or by writing to one of our addresses listed above.

    To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.

  12. Changes to this notice or your data

    We may amend or modify this privacy notice from time to time. We will post any revised notice on this site and notify you of any changes to this privacy notice if you are a client or have subscribed to our news alerts or mailing lists. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

    This privacy notice was last updated in May 2018.

    © SC Lowy 2018