Privacy notice

Introduction 

Club Vita, U.S., LLC is committed to protecting and respecting your privacy. This includes any personal information or data that we collect, use and disclose in the course of providing professional services. We operate our firm in accordance with all applicable regulatory requirements, including applicable privacy legislation. This privacy policy supplements our professional obligations of client confidentiality and sets out in general terms how we collect, use, disclose and protect the personal information for our website users (“you”).

This notice explains what personal information we collect about you, how and why we use it, who we disclose it to, and how we protect it. 

It applies to you if you use our website, sign up for events, subscribe to our publications or contact us with an enquiry using the forms on our website or by email. It also applies to you if we have a professional or business relationship or connection with you. 

Our website is directed to, and for use by, our clients, prospective clients and professional and business contacts in the United States. It does not concern the provision of scheme membership data through the ‘Members Area’ of this website. 

What is personal information?

Personal information broadly means information about a living individual who can be identified from that information directly, or indirectly (for example, if it is combined with other available information).

Content

  • What personal information do we collect?
  • Cookies
  • Using your personal information
  • Sharing your personal information with others
  • How we protect your personal information
  • How long we keep your personal information
  • Third Parties
  • Contacting us
  • Changes to this privacy notice

1. What personal information do we collect?

We will collect the following information about you:

  • Visitors to our website. We use Google Analytics to collect information about visitors to our website. This information won’t be used to identify you unless you submit your contact details via the website, where we may then connect your prior activity on our website with your personal information.
  • People who use our services (for example registering for events or downloading publications) or contact us with an enquiry. We’ll collect the information you submit via our website or when you contact us, for example your name, contact details, details about the service you’re interested in or your enquiry.
  • Business contacts. We’ll collect your contact details, information about your work or personal circumstances and your interests, where you disclose them to anyone who works for us in a professional or business setting, for example at networking events. We’ll also collect information from social media that is available publicly or if you connect with anyone who works for us.
  • Clients, prospective clients and related persons. We’ll collect information about the identity of clients and prospective clients and (where relevant) shareholders, beneficial owners, management, directors, officers and trustees and other related persons for verification and anti-money laundering purposes. This information will be collected from you or online sources or both.

We will always try to keep the amount of personal information we collect to the minimum needed.

Club Vita U.S., LLC is based in the U.S. and the information we collect is governed by U.S. law.  If you are accessing the Sites from outside the U.S., please be aware that information collected through the Sites may be transferred to, processed, and stored in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Sites, and providing information through the Sites, constitutes your consent to the transfer, processing, usage, sharing, and storage of your information, including Personal Information, in the U.S. as set forth in this Privacy Policy. 

2. Cookies

We use cookies to analyze trends, statistics and patterns; to help provide better customer service; and monitor the regions from which visitors may access our site. Cookies are small data files that are sent to your browser and stored on your computer's hard drive when you visit certain websites in order to "track" your visit to the site. Club Vita U.S., LLC may, from time to time, collect non-personal information about you and your use of this site using cookies. We do not match or correlate this information with any personal information that you submit via this website. Cookies may be used to customize this site according to visitor preferences, e.g., preferred language. They may also be used to analyze website usage. If you do not want your details used in this way, you are able to control the use of cookies at an individual browser level. Please note that if you choose to disable cookies, it might limit the use of certain features or functions on this website.

3. Using your personal information

We use your personal information for the following purposes:

  • Providing website features. We’ll use information we collect to help ensure that content from our site is presented in the most effective manner for you and for your computer, allow you to participate in interactive features of our website, and monitor how our website is used to improve it.
  • Providing our services or responding to your enquiry. We use the information you provide for the service you’ve requested, for example to process your registration for an event, so that we can contact you about the event you have registered for, or to send you a link to, or copy of the publication that you’ve requested. If you send us a general inquiry, we’ll forward it to the relevant department who will use your information to respond to you about your inquiry.
  • Direct marketing. If you are a professional or business contact, client or prospective client, we’ll use your business contact details to send you direct marketing communications which you have subscribed to or which we feel may be relevant and of interest you, as well as information about events, thought leadership and topical updates. You can update your preferences or unsubscribe from our communications at any time. To do so, simply:
  • get in touch with us via our website or the contact details below.
  • visit our preference center and confirm your preferences, or
  • click the “update your preferences” or “unsubscribe” link in the communication that you’ve received from us.

We may also contact you by post or phone, unless you ask us not to.

We are obliged to verify the identity of prospective and (in some circumstances) existing clients. This involves checking the identity and good standing of clients and related persons.

4. Sharing your personal information with others

We may share your personal information with the following:

  • with any member of our group, for the purposes of providing information or services and developing our business relationship with you;
  • our event or service partners, so that they can contact you about the event you've registered for or the service you're interested in;
  • our service providers, for example those providing support, maintenance and troubleshooting services for our IT services and platforms or who assist in maintaining the security and performance of our websites, so that we can run our business; and
  • regulators, ombudsmen, dispute resolution bodies, government bodies or the courts, where we are under a legal obligation to do so, or to protect our rights or property, or the safety of our people, clients or others, so that we can meet our legal obligations.

Some of these may be located within the United Kingdom or the European Economic Area, where data protection laws are stricter. As always, we will ensure that adequate safeguards are in place (for example, robust contracts) to make sure your personal information is protected.

5. How we protect your personal information

We employ up to date technologies and systems to protect your personal information from unauthorized disclosure or damage or misuse.  We ensure that our staff receive regulation training about information security and data protection. We meet the ISO27001:2013 standard for information security management systems.

We regularly review all our systems, policies and technologies to ensure that these continue to work effectively to protect your personal information.

6. How long we keep your personal information

We will keep your personal information for as long as we are using it for the purposes explained in this notice.

When we no longer need it, we will archive your personal information after a certain period (usually 7 years), and then delete it permanently after an additional period (usually 13 years).

We may in certain circumstances need to hold your personal information for longer, for example in relation to a legal dispute or because of regulatory requirements.

7. Third Parties

The Sites may include hyperlinks to other websites, online locations, platforms, or services for your convenience and information. Such linked websites may be operated by third parties that are not owned or controlled by Club Vita U.S., LLC. They may use their own cookies, web beacons, and other technologies to collect information about you, and they may solicit Personal Information directly from you. If you follow links from the Sites to other websites, we encourage you to familiarize yourself with their privacy policies and terms of use. We are not responsible for the content or privacy practices of websites that we do not control.

8. Contacting Us

If you have any queries about how we use your personal information you can contact the Data Protection Officer through any of the following means:

By Post: Club Vita LLP, Exchange Place One, 1 Semple Street, Edinburgh, EH3 8BL

By email: [email protected]

By phone: 0131 656 50009.

9. Changes to this privacy notice

This privacy notice is current as at December 2018.  We may make changes from time to time and you should regularly check for updates.

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