Alchemy Properties Inc. and our affiliates (together, “Alchemy,” “we,” “us” and “our”) are committed to respecting the privacy of visitors to our website (https://alchemy-properties.com), contacts for our clients, investors and prospects, contacts for our vendors of goods and services, candidates for employment, and any other individuals about whom Alchemy obtains personal information (each, “you”). This includes dealing with your personal information (as defined below) responsibly and in accordance with the requirements of applicable data protection laws, and employing appropriate security measures to protect your personal information.
This privacy notice (this “Privacy Notice”) describes the ways in which we collect, use and share the personal information you provide to us, or that we otherwise collect or receive in the course of operating our business and our website. It also sets out how we store and protect such information, and describes certain rights you may have with respect to the personal information that we hold about you.
Personal information that we collect about you and how we obtain it
“Personal information” is any information in our possession or control (either in isolation or in combination with other information held by us) that can be used to identify you or that we can link to you.
We may collect the following categories of personal information from you in the course of business, including through your use of our website, when you contact or request information from us, or when we provide services to you or receive services from you:
- Identification data, such as name, gender, title, job title, or address;
- Contact information, including your phone number(s), your email address and social media account or handle where appropriate;
- Financial data, such as bank account information and invoicing details;
- Event registration or mailing list data, such as dietary requirements (which may reveal information about your health or religious beliefs), preferences and interests, subscriptions, downloads, and username/passwords;
- Job applicant data, such as identification data and contact information, resumé and other data provided by you or third parties (e.g. recruiters) on our website, online recruitment portal (where applicable) or offline in connection with job openings, which may be subject to additional local requirements based on the jurisdiction for which the position is advertised;
- Legal and regulatory compliance data as required for purposes such as know your client, anti-money laundering, and market abuse regulations requirements, or as part of our onboarding process, which may include social security number, driver license, passport or other identification data, date of birth, home address, and other due diligence data;
- Other service data, such as personal information relevant to the provision or receipt of services; and
- Cookie and device data, such as information about your visit of our website, IP address, device identifier, browser type and version, operating system and network, location and time zone setting.
We may supplement the information that you provide to us with information that we receive or obtain from other sources, such as from our staff or personnel, clients, investors, professional advisers, partners, and agents, third parties with whom we interact, and publicly available sources.
Uses of your personal information
We may use your personal information in a number of ways, including:
- to manage our business and commercial relationships with our clients, investors and vendors;
- to engage in marketing and business development activities in relation to the services we provide, including sending you newsletters, marketing communications and other information that may be of interest to you (you may choose at any time not to receive marketing materials from us by emailing us at privacy@Alchemy-properties.com);
- to review and process your job application when you have applied for a position with us;
- to comply with our legal and regulatory obligations, or to establish, exercise or defend our legal rights;
- to manage and analyze usage and performance of our websites or our other online services;
- to improve the services we offer;
- to respond to any of your requests, investigate any complaints you may have, or to notify you about any changes to our services or our website; and
- to prevent and respond to actual or potential fraud or illegal activities.
We rely on one or more of the following legal grounds for using your personal information in these ways:
- we have your consent;
- we need to in order to take steps to enter into a contract with you or to perform our obligations under a contract with you;
- we need to in order to comply with our legal and regulatory obligations, or to establish, exercise or defend our legal rights; or
- it is required for our legitimate business interests, some examples of which are listed above in this “Uses of your personal information” section.
Sharing of your personal information
We share personal information among our affiliates, including affiliates we may establish or acquire in the future.
We may also share your personal information with third parties outside of Alchemy, including:
- third party agents or contractors that are subject to confidentiality requirements, in connection with the processing of your personal information for the purposes described in this Notice (this may include, for example, IT and communications service providers, or vendors who provide support services to us);
- third parties relevant to the services that we provide or projects in which we are involved, including counterparties to transactions, other professional service providers, regulators, authorities, governmental institutions and stock exchanges;
- regulatory authorities, courts, tribunals, government agencies or law enforcement agencies in connection with any inquiry, subpoena, court or administrative order, or other legal or regulatory procedures with which we need to comply, or where we need to establish, exercise or defend our legal rights; and
- any third party connected with a proposed business transfer by or to Alchemy, including a reorganization, restructuring, merger, acquisition, or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Notice.
We will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. However, this Notice covers the Alchemy website only. We are not responsible for the data policies or procedures or content of any linked websites. We recommend that you check the privacy and security policies of each website you visit.
Retention of your personal information
How long we retain your personal information will vary depending on a number of factors, including:
- the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose;
- legal obligations – laws or regulations may set a minimum period for which we have to keep your personal information.
Protecting your personal information
We have implemented technical and organizational security measures in an effort to safeguard the personal information in our custody and control. Such measures include, for example, limiting access to personal information only to staff and authorized service providers on a need-to-know basis for the purposes described in this Notuce, as well as other administrative, technical, and physical safeguards.
We endeavor to take all reasonable steps to protect your personal information, but cannot guarantee the security of any data you disclose online. Please note that email is not a secure medium and should not be used to send confidential or sensitive information. By providing information online, you accept the inherent security risks of providing information over the Internet and will not hold us responsible for any breach of security, unless it is due to our negligence or willful default.
Your rights regarding your personal information
Subject to the provisions of local laws and regulations from time to time, you have, or may have, certain legal rights in relation to the personal information that we hold about you, which you can exercise (to the extent applicable) by contacting us as set out below.
As such, you may be entitled, in certain circumstances:
- to request details regarding our processing of your personal information, and access to the personal information that we hold about you;
- to withdraw your consent to our processing of your personal information;
- to receive certain personal information;
- to request that we correct your personal information if it is inaccurate or incomplete;
- to request that we erase your personal information;
- to request that we restrict our processing of your personal information;
- to stop unauthorized transfers of your personal information to a third party, or to have your personal information transferred to a third party; and
- to lodge a complaint with the relevant data protection authority if you think that any of your rights have been infringed by us.
Please note that these rights may not be absolute. For example, if you withdraw your consent to our processing of your personal information, or request that we restrict such processing, we may still be entitled to process your personal information if we have other legal grounds for doing so. We may also be entitled to refuse certain requests for access to copies of personal information, or requests to erase your personal information if we are otherwise legally entitled or required to retain it.
Changes to our privacy notice
We reserve the right to review and change this Privacy Notice. Any future changes will be reflected with an updated version of this Privacy Notice as available on our website. The last update date is posted below, and we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.
How to contact us
If you have any comments or questions in connection with this Privacy Statement, or for further information on our processing activities and your rights in relation to your personal information, please contact us via email at email@example.com or by post to Data Protection, Alchemy Properties Inc., 800 Third Avenue, 22nd Fl, New York, NY 10022.
Last updated: April 2019