Your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Ignatious, LLC, Ignatious II, LLC, Ignatious Parent, Inc., and our affiliates (“Ignatious,” “we,” “us,” “our”), and sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal information (as defined below) of our current, prospective and former clients, customers and partners.
This Privacy Notice is being provided in accordance with the requirements of data protection laws, such as the Gramm-Leach-Bliley Act of 1999, as applicable, and any other law relating to privacy or the processing of personal information and any statutory instrument, order, rule or regulation implemented thereunder, each as applicable to us (collectively, “Data Protection Laws”). References to “you” in this Privacy Notice mean any individual, or any individual connected with legal entity who is a natural person (each such individual, an “individual), as applicable.
“Personal information” means any information identified under applicable Data Protection Laws as “personal information,” “personal data,” “personally identifiable information” or similar terms, which may include, as applicable, any information relating to an identified or identifiable individual.
The categories of personal information we may collect and process include: names, residential addresses or other contact details, signature, nationality, social security number, tax identification number, date of birth, place of birth, photographs, voice and video recordings, email and other communications, copies of identification documents, financial account details, information about assets or net worth, credit history, source of funds details or other information about you. It may include certain sensitive or special categories of personal information that you disclose including financial account information, certain governmental identifiers (e.g., social security number, driver’s license), email and other communications, citizenship and immigration status, and family information.
We may collect personal information about you through: (i) information provided directly to us by you, or another person on your behalf; (ii) information that we obtain in relation to any transactions between you and us; and (iii) recording and retention of electronic communications with you as described below.
In addition to the information that you provide to us, we also may receive your personal information from third parties or other sources, such as our affiliates, publicly accessible databases or registers, tax authorities, governmental authorities, credit agencies, fraud prevention and detection agencies, anti-money laundering and know-your-customer services, or other publicly accessible sources, such as the Internet.
We may process your personal information for the purposes of administering the relationship between you and us (including communications and reporting), performing our obligations to you, operating our business, marketing our products and services, monitoring and analyzing our business activities, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from governmental authorities with competent jurisdiction over our business). Your personal information will be processed for the above purposes in accordance with Data Protection Laws and this Privacy Notice, and as necessary in the context of our relationship, or to pursue our legitimate interests in managing and operating our business or facilitating the applicable transactions, including where our third-party agents, counterparties or other contracting parties involved in these activities have a legitimate interest in processing personal information.
We may also need to process your personal information to satisfy a statutory obligation (including compliance with applicable client identification, anti-money laundering or sanctions requirements) or so that we can meet our contractual requirements to you (or enter contracts on your behalf). Where there is reasonable suspicion of unlawful activity, we may be required to submit a report to the relevant law enforcement agency or supervisory authority, based on information you have provided or where you have failed to provide required information.
We may monitor and retain electronic communications with you in the course of our relationship for the purposes of: (i) ensuring compliance with our regulatory obligations; (ii) training and service improvements; and/or (iii) detecting and preventing the commission of financial crime.
We may disclose information about you to our affiliates or third parties providing services to or doing business with us, for our everyday business purposes, such as to facilitate transactions, or respond to court orders and legal investigations. It may also be necessary, under anti-money laundering and similar laws, to disclose information you.
We may share personal information with our service providers, who handle that data on our behalf and in accordance with our instructions under contract. These include IT suppliers, data hosting providers, or agencies we use to conduct fraud checks and anti-money laundering verification. We or our affiliates may contact you about offers of products and services related to our services. You may withdraw your consent to us doing this by contacting info@ignatious.com.
In the event we experience a change of control or other transaction such as a merger, acquisition, bankruptcy or insolvency, consolidation or other restructuring, we may disclose your personal information to the entity that succeeds or replaces us, or acts on our behalf, and that party may modify or replace this Privacy Notice with its own or another privacy notice, in accordance with the change provisions below.
We will not retain personal information about you for longer than is necessary in relation to the purpose for which it is collected, subject to Data Protection Laws. Personal information will be retained for the duration of the applicable transaction and, in most instances, for a minimum period of seven years thereafter. We may retain personal information for a longer period as permitted or required by applicable law, based on various criteria including guidance issued by governmental authorities and the need to hold data for overriding legitimate business needs, such as potential or actual litigation. From time to time, we will review the purpose for which personal information has been collected and decide whether to retain it or to delete if it no longer serves that purpose.
To protect your personal information from unauthorized access and use, we apply organizational and technical security measures in accordance with Data Protection Laws intended to protect your personal information from unauthorized or unlawful access or accidental loss or destruction, including by using reasonable efforts to require our service providers to safeguard your personal information against unauthorized or unlawful access or accidental loss or destruction. We will notify you of any material personal information breaches affecting you in accordance with the requirements of Data Protection Laws.
We may occasionally update or change this Privacy Notice to deal with new or amended Data Protection Laws, changes in our structure or practices, or for other legitimate reasons. Written notice of these updates will be given to you.
Please contact us at info@ignatious.com for any questions about this Privacy Notice or requests with regards to the personal information we hold.
Last updated: [____________ __, 2022]
Securities are offered through Finalis Securities LLC Member FINRA / SIPC. Ignatious is not a registered broker-dealer, and Finalis Securities LLC and Ignatious are separate, unaffiliated entities.
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