In this Policy when we refer to the “GWM Group” or “GWM” or “we”/“us”/“our” we mean GWM Group Holding SA and our subsidiaries and also other companies and entities that are associated with us. Our registered office is at 31, Grand rue, L-1661 Luxembourg, Grand Duchy of Luxembourg.
We may revise this Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.
This Policy describes:
• the information that we collect;
• how we use the information we collect;
• how we share information with third parties;
• how long we keep your information;
• your choices and rights;
• how to contact us.
The information that we collect and where we get it from
"Personal information" is any information that can be used to identify you or that we can link to you and which we have in our possession or control. We will collect and process the following personal information about you:
Information that you provide to us
We will process personal information that you give to us including when you email us or contact us through various channels as follows:
• Our products or services: when you contact us with queries or respond to our communications relating to our investment products or services the personal information you provide may include your full name, title, telephone number, email address and content, date and time of your email correspondence and information about your employer or your business.
• As a client: if you are a client of GWM you will provide us with personal information when you or the company you represent becomes a client. If you are not a client, we may collect or receive your personal information because you provide services to or are otherwise connected to one of our clients.
• Recruitment application: when you apply for a role with us you may provide us with your full name, date of birth, nationality, education and qualification details, your gender, your CV, photograph, passport details, marital status, home address and home telephone number, mobile telephone number and other details set out in your application.
Information we otherwise collect about you
We may also collect information about you when you otherwise interact or correspond with us. We use various technologies to collect and store information when you visit our website. We may, for example, collect information about the type of device you use to access our website, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our websites, the web pages and the search terms you enter on our website.
Information we obtain from other sources
• If you apply for a position with us we may collect personal information relating to your past employment, qualifications and education, opinions from third parties about you, past employment history and other details about you, which will be provided to us by a third party that provides background screening services to us.
• If we collect or receive your personal information in the context of our provision of investment products and services we might receive information from third parties such as your employer, other parties relevant to the products or services we are providing (e.g. our counterparties or your advisers or other service providers) and others such as regulators and authorities. That information could include your name, contact details, employment details and other information relevant to the products or services that we are providing to our client.
How we use the information we collect
We may do the following with your personal information:
• use it to provide investment products or services to the relevant client;
• use it to engage in marketing and business development activity in relation to our investment products and services, including sending you investment reports, newsletters, marketing communications and other information that may be of interest to you;
• where you have applied for a position with us, to review and process your job application;
• to comply with legal and regulatory obligations that we have to discharge;
• use it to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
• record and monitor your use of our website or our other online services for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports;
• use it for our legitimate business interests, such as managing the operation and promotion of our business;
• use it to look into any complaints or queries you may have;
• use it to prevent and respond to actual or potential fraud or illegal activities.
Also, we may collate, process and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.
Grounds for using your personal information
We rely on the following legal grounds to process your personal information, namely:
• Consent - we may (but usually do not) need your consent to use your personal information. You can withdraw your consent by contacting us (see below).
• Performance of a contract - we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you.
• Legitimate interest - we may use your personal information for our legitimate interests, some examples of which are given above.
• Compliance with law or regulation - we may use your personal information as necessary to comply with applicable law/regulation.
How we share information with third parties
We share personal information with our subsidiaries and the various companies and entities that are associated with us. As a result, your personal information may be transferred to locations outside Europe as well as within it for the purposes described above.
We may also share your personal information outside GWM. This may include:
• third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers and providers of external payroll services;
• third parties relevant to the investment products and services that we provide. This may include, but is not limited to, counterparties, professional service providers, regulators, authorities, governmental institutions and stock exchanges;
• to the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal information in order to comply with any legal obligation.
In other circumstances, the law may permit us to otherwise transfer your personal information outside Europe. In all cases, however, any transfer of your personal information will be compliant with applicable data protection law.
How long we keep your information
We may also share your personal information outside GWM. This may include:
• the purpose for which we are using your personal information - we will need to keep the information for as long as is necessary for the relevant purpose;
• legal obligations - laws or regulation may set a minimum period for which we have to keep your personal information.
We will ensure that the personal information that we hold is subject to appropriate security measures.
Your choices and rights
You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below.
These rights include:
• Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you.
• Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information.
• Requesting that we correct your personal information if it is inaccurate or incomplete.
• Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information, but we are legally entitled to retain it.
• Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
• In some circumstances, receiving some personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit that information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.
• Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
• Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us.
• We can, on request, tell you which data protection authority is relevant to the processing of your personal information.
Information on our policy in relation to cookies can be found in the Terms and Conditions section of our website: www.gwmholding.com.
How to contact us
If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us. You can do this by writing to us at: firstname.lastname@example.org.