Effective Date: 27 August 2015
Except where otherwise expressly stated, the Content on this website (the “Site”) has been approved for issue in the UK and is communicated by Curzon Advisers Limited (“Curzon”). This Site refers to Curzon Advisers Limited and to the website www.curzonadvisers.com only.
References on this Site to the “Firm”, “Company”, “Curzon” or “us”, “we” “our” refer to Curzon Advisers Limited. The Content is intended to describe the activities of Curzon only. For the purposes of these Terms and Conditions, “Curzon” and “Curzon Advisers” shall mean collectively Curzon Advisers Limited and its directors, officers and employees, as the context requires.
Curzon is committed to protecting the security of your personal information. Curzon recognizes that in using parts of this Site you may be required to entrust important personal information to us, and we wish to assure you that we take seriously our responsibilities in protecting and safeguarding this information.
Curzon respects your privacy and is committed to protecting it through our compliance with this Policy. This Policy describes the type of information we may collect from you or that you may provide when you visit the Site and our practices for collecting, using, maintaining, protecting and disclosing that information. This Policy applies to information we collect:
- On this Site.
- In e-mail, text and other electronic messages between you and this Site.
It does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by Curzon or any third party (including our affiliates and subsidiaries).
We will retain, where applicable, your personal information in accordance with the relevant data protection laws for so long as it is needed.
By using this Site you agree and consent to the processing, disclosure and transfer (and international transfer, where applicable) of your personal data by Curzon for the purposes set out in this Policy.
Please read the Terms and Conditions of Website Use (“Terms and Conditions”) together with this Policy carefully before using this Site. These Terms and Conditions set forth the legally binding terms and conditions that govern your access to and use of this Site. Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site. If you wish to access or browse the remainder of this Site, then you are reminded that your proceeding to do so constitutes a binding legal agreement to the Terms and Conditions and this Policy on your own behalf and where applicable, on behalf of any client or investor that you represent, for whom you act as agent or with whom you are associated.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Site, including information:
- By which you may be personally identified, such as name, postal address, e-mail address or telephone number ("personal information"); and/or
- About your internet connection, the equipment you use to access our Site and usage details.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses and information collected through cookies and other tracking technologies.
The technologies we use for this automatic data collection may include:
We may collect information about you when you use this Site or when you apply for or use other services offered by Curzon in the following ways:
- Cookies (or browser cookies):
Curzon may, in certain circumstances, use “Cookies” to make sure your access and use on this Site is secure.
A “Cookie” is a small piece of data, file or message that is sent from a web server to your browser and may be placed and stored on the hard drive of your computer. A Cookie cannot read data off your hard disk or read Cookie files created by other sites. Cookies do not damage your system.
- Flash Cookies:
Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices about How We Use and Disclose Your Information below.
If you turn off the Cookie function you may not receive all the information on this Site.
Any information collected is primarily for purposes of administering this Site, compiling demographic information and monitoring usage and performance of the Site. Your attention is drawn to the fact that with the use of the Cookies set out in the Table below and any embedded pixel technology, the information that we may collect is anonymous and does not contain your specific details, including but not limited to your email address.
Changes in EU legislation require us to inform you of what Cookies we may set. In particular the Site relies on Cookies specified in the Table below.
Information You Provide to Us.
The information we collect on or through our Site may include:
- Information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site. We may also ask you for information when you report a problem with our Site.
- Records and copies of your correspondence (including e-mail addresses), if you contact us.
- Your search queries on the Site.
Usage Details, IP Addresses, Cookies and Other Technologies.
As you navigate through and interact with our Site, we may automatically collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Site, including traffic data, location data, logs and other communication data and the resources that you access and use on the Site.
- Information about your computer and internet connection, including your IP address, operating system and browser type.
The information we collect automatically is statistical data. It helps us to improve our Site and to deliver a better and more personalized service by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Site according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Site.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Site and its contents to you.
- To provide you with information, products or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your investments with us.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Site or any products or services we offer or provide though it.
- To allow you to participate in interactive features on our Site.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
For more information, see Choices About How We Use and Disclose Your Information below.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this Policy:
- To our subsidiaries and affiliates.
- To contractors, service providers and other third parties we use to support our business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Curzon's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Curzon about our Site users is among the assets transferred.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms and Conditions of Use http://www.curzonadvisers.com/Terms.html and other agreements, including for billing and collection purposes.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising.
We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
Data Protection Act
To comply with the requirements of the Information Commissioner under the United Kingdom Data Protection Act 1988 (“‘DPA”’), we must give you the following details about the way in which we look after your personal information. You should ask us if you require any further explanation.
By accessing and continuing to access our Site, you may provide us with your personal information, which would comprise all the details we hold about you and where applicable your transactions, and may include information obtained from third parties.
We do not disclose your information to anyone except where we have your written permission; or where we are required or permitted to do so by law; or to credit reference and fraud prevention agencies and other companies that provide a service to us or you; or where we may transfer rights and obligations.
We may transfer your information to other countries on the basis that anyone to whom we pass it provides an equivalent level of protection in that jurisdiction. However, such information may be accessed by law enforcement agencies and other authorities to prevent and detect crime and comply with legal obligations.
If you would like a copy of the information that we may hold about you, please write to:
The Data Protection Officer, Curzon Advisers Limited, 105 Wigmore Street, 5th Floor, London, W1U 1QY, United Kingdom, at email@example.com
Your attention is drawn to the point that a fee may be payable on the receipt of such requests.
We may make periodic searches at credit reference agencies and may provide information about you to such agencies that may make this information available to other organizations so that they can take decisions about you, your associates and members of your household. The information may also be used for tracking purposes.
If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies; and law enforcement agencies may access and use this information. We and other organizations may also access and use this information to prevent fraud and money laundering, for example when checking applications for, and managing credit or other facilities and recovering debt; checking insurance proposals and claims; and checking details of job applicants and employees.
We, and other organizations that may access and use information recorded by fraud prevention agencies, may do so from other countries.
We can provide the names and addresses of the credit reference and fraud prevention agencies we use if you would like a copy of your information held by them. For further details, please contact:
The Data Protection Officer, Curzon Advisers Limited, 105 Wigmore Street, 5th Floor, London, W1U 1QY, United Kingdom, at firstname.lastname@example.org
Your attention is drawn to the point that the agencies may charge a fee on the receipt of such requests.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. We maintain physical, electronic and procedural safeguards, including (where appropriate and applicable) firewalls, individual passwords and encryption and authentication technology for any personal information that we might collect through the Site. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security and/or confidentiality of any communication or material or your personal information transmitted via open networks to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. When disclosing any personal information via an open network, you should remain mindful of the fact that it is potentially accessible to others, and consequently, can be collected and used by others without your consent. Your data may be lost during transmission or may be accessed by unauthorized parties. Curzon does not accept any liability for direct or indirect losses as regards the security of your data during its transfer via the Internet. Please use other means of communication if you think this is necessary or prudent for security reasons.
It is our policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by e-mail to the primary e-mail address specified in your account or through a notice on the Site home page or on this page. The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Site and this Policy to check for any changes.