Portal Privacy Notice
This privacy notice describes how the Asset Management Exchange (“AMX”) generally collects and processes personal information collected through the AMX Portal.
The Asset Management Exchange and AMX are trading names of (1) The Asset Management Exchange (Ireland) Limited (“AMX Ireland”) registered in Ireland, No. 632258, authorised and regulated by the Central Bank of Ireland, (2) The Asset Management Exchange (UK) Limited (“AMX UK”), registered in England, No. 11555138, authorised and regulated by the Financial Conduct Authority No. 823316) and (3) The Asset Management Exchange (IP Co.) Limited (registered in England, No. 11686713).
This privacy notice may be revised from time to time to reflect changes in law or changes in AMX’s business operation. This privacy notice was last updated on 27 June 2019.
SCOPE OF THIS PRIVACY NOTICE
This privacy notice only applies to the AMX Portal and any other AMX website where a link to this privacy notice is provided. These websites are controlled by AMX, part of the Willis Towers Watson group (“Willis Towers Watson”), whose ultimate holding company is Willis Towers Watson plc, a company incorporated in the Republic of Ireland.
When we refer to “Personal Information” we mean information that identifies you as an individual or relates to an identifiable individual.
THE AMX PORTAL
The AMX Portal is a platform designed for AMX investors and investment managers. If you are given access to the AMX Portal:
- We will use the personal information you have provided to us through your subscription application form to create a profile for you on the AMX Portal and to facilitate your access to the AMX Portal; and
- Any additional personal information that you submit to us through the AMX Portal in connection with our professional services will be processed in accordance with the privacy notice we have supplied to you with respect to those services.
INFORMATION WE MAY COLLECT FROM YOU
The Personal Information we may collect through our websites includes:
- your name, address, occupation and other contact information;
- information regarding your dealings with us;
- any interest you have in relation to our services or our practice areas (including job openings);
- any information you may voluntarily submit to us by completing any form on our websites; and
- details of your visits to and usage of our website including the date and time of your visit, the internet address from which you visited and the resources on our website that you viewed.
We collect Personal Information in various ways:
- from any form you may complete and submit through our websites, for example information collected from the “Contact Us” page of our website;
- from the content of surveys that you may complete on our website;
- from ‘cookies’ and other similar tools deployed on our websites (for further information regarding cookies used on our websites, please see Section 8 below); and
- when you provide information as a client of a Willis Towers Watson entity in connection with it providing professional services to you. Such information may be collected through www.theAMX.com when clients access AMX client links within this website. Access will be subject to the terms of business Willis Towers Watson has with clients and any additional terms and conditions of use attached to those sites.
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
We must have a legal basis to process your Personal Information. In most cases the legal basis will be one of the following:
- for our legitimate interests, for example to provide services to our clients, to ensure that the services we provide are appropriate for our clients’ requirements, to improve our services, to operate and improve the websites and enable interactive features on the websites, and to manage our business in an efficient way;
- for the legitimate interests of our clients and other third parties, for example to ensure that any financial services we provide to clients are suitable, to verify that our services are only made available to certain categories of investor and to provide a high quality of service;
- to comply with our legal obligations, regulatory requirements and governance procedures; and
- (when we provide access to the AMX Portal or other client areas) to perform a contract that we have entered into with you.
When we process Personal Information to meet our legitimate interests or those of a third party, we put in place robust safeguards to ensure that the privacy of individuals is protected and to ensure that those legitimate interests are not overridden by the interests or fundamental rights and freedoms of individuals.
WHAT WE MAY DO WITH YOUR PERSONAL INFORMATION
We may use your Personal Information in the following ways and for purposes specified in the relevant parts of the website:
- to facilitate your participation in interactive features you may choose to use on our websites;
- to correspond with you, notify you of events or changes to our services, or otherwise to respond to your queries and requests for information, which may include marketing to you;
- for the purposes of Willis Towers Watson providing professional services to you via the AMX Portal or other Willis Towers Watson applications; such services may be subject to additional terms and conditions of use and privacy notices;
- for data analysis, audits, fraud monitoring and prevention,
- to enable us to comply with our legal obligations; and
- to monitor website usage to help us enhance, improve or modify our website and to identifying usage trends that help us determine the effectiveness of our promotional campaigns and help us to develop new products and services.
DISCLOSURE OF YOUR INFORMATION
AMX may disclose your Personal Information to any company affiliated or associated with Willis Towers Watson for the uses and purposes set out above. We may also disclose your Personal Information to independent third parties as follows:
- to third party service providers such as entities providing customer service, email delivery, auditing, hosting our website, our marketing activities and other services. The AMX Portal is operated by the third party provider InvestCloud;
- to third parties involved with events that you register for, to facilitate your participation in those events;
- if we are obliged to disclose your Personal Information under applicable law or regulation, which may include laws outside your country of residence;
- in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
- in accordance with the separate terms and conditions of use that may attach to Willis Towers Watson website links.
CROSS BORDER TRANSFER
In connection with the above purposes we may transfer your Personal Information outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include: (a) entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission; (b) in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework; or (c) transferring your personal data pursuant to binding corporate rules.
Further details of the measures that we have taken in this regard and the territories to which your Personal Information may be transferred are available by contacting us via one of the methods set out at the end of this notice.
COOKIES AND INFORMATION COLLECTED FROM YOUR COMPUTER
When you visit our website, our server may record your IP address for the purposes of systems administration. In most cases, your IP address is not linked to any of your Personal Information, but in limited circumstances (e.g. if you log into restricted parts of our website), your IP address can be linked to your Personal Information. AMX may also gather other non-personal information from you (from which AMX cannot identify you), such as the type of your internet browser, which AMX uses to provide you with a more effective service.
Additionally, when you visit our websites, AMX may store a ‘cookie’ on the hard drive of your computer.
Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of websites, such as time spent on websites, pages visited, language preferences, and other traffic data. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using our websites and to recognize your computer in order to assist your use our websites. We also gather statistical information about use of our websites in order to improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.
There are different types of cookies, for example:
- Cookies served directly by AMX (‘first party cookies’) and cookies served on our behalf, for example by advertisers and data analytics companies (‘third party cookies’)
- Cookies which endure for different periods of time, including those that only last only as long as your browser is open (referred to as ‘session cookies’) These are deleted automatically once you close your browser. Other cookies are ‘persistent cookies’, meaning that they survive after your browser is closed. For example, they recognise your device when you open your browser and browse the internet again
In order to help us improve our websites and the services we provide and to improve your experience of using our websites, our websites use two types of cookies:
- Session cookie.
This type of cookie is used only on those parts of our websites that are restricted and can only be accessed by authorized users who typically authenticate themselves through their user IDs and passwords (e.g. our online client/carrier tools). This type of cookie is essential to keep authenticated users logged into our websites and to enable them to visit different parts of our websites. It will be stored on your computer for a short period (typically 48 hours) and the information held in it will be accessed automatically to authenticate you when you visit the website again. Otherwise, this cookie will be deleted
when you log out and close the browser.
- Google Analytics.
This cookie is provided by Google, and we use them on our websites in order to analyze how visitors use our websites, thereby helping us to improve our websites. Google Analytics collects information in an anonymous form, including the number of visitors to our websites, how visitors have arrived to our websites, and which pages on our websites
the visitors have viewed.
You have the right to choose whether or not to accept cookies. You can control the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. Information about the procedure to follow in order to enable or disable cookies can be found on your Internet browser provider’s website via your help screen. Go to the ‘options’ or ‘preferences’ menu on your browser to change your settings. – 6 –
However, if you choose not to accept cookies, this may affect the functioning of our websites.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org, www.allaboutcookies.org, or www.youronlinechoices.eu.
SECURITY AND RETENTION
AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.
We will retain your Personal Information for as long as is necessary for the provision of any services we provide to you. When we no longer need your Personal Information in connection with any services, we will retain your Personal Information for a period of time that reasonably allows us to comply with our regulatory obligations or governance requirements and to defend legal claims. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.
CHOICE AND ACCESS
The Asset Management Exchange (Ireland) Limited is the controller responsible for the Personal Information we collect and process.
If you would like to review, correct, update, suppress, object to or restrict the processing of your Personal Information or request a copy of Personal Information about you, you may contact us using the details found in the “Contact” section below.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to undertake any services or requests that you initiated prior to requesting a change or deletion.
There may also be residual information that will remain within our databases and other records, which will not be removed. Where that is the case, we will implement reasonable measures to ensure that this data remains secure and is not accessed or used in any way. – 7 –
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the Information Commissioner’s Office, at www.ico.org.uk/concerns .
From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.
If you have any questions or comments regarding this privacy notice, please contact our Global Privacy Office, at The Willis Building, 51 Lime St, London EC3M 7DQ or at email@example.com.
You can also contact AMX at:
The Asset Management Exchange (Ireland) Limited, Riverside One, Sir John Rogerson’s Quay, Dublin 2, D02 X576 or
The Asset Management Exchange (UK) Limited, The Willis Building, 51 Lime St, London EC3M info@theAMX.com.