Numeus, (together with its subsidiaries and affiliates the “Numeus Group”) (we or “Company”) is committed to protecting visitors’ privacy and maintaining the confidentiality and security of visitors’ personal information. In accordance with its legal obligations, the Company is required to inform visitors how it treats certain information concerning visitors to aid their understanding in how it handles visitors’ personal information and how such information is used to service visitors.

Protecting visitors’ personal information is an important priority for the Company. Accordingly, it uses the personal information collected about visitors in order to provide better service.  The Company does not sell personal information. 

The Company only discloses nonpublic personal information to nonaffiliated third parties who assist the Company in providing services (for example, administrators, accountants and attorneys), each as permitted by law or as otherwise required by law.  We do not sell your personal information. 

The Company considers the protection of sensitive information to be a sound business practice and a foundation of customer trust and protects investors’ personal information by maintaining physical, electronic, and procedural safeguards that meet or exceed applicable legal requirements. The Company restricts inter-company access to visitors’ nonpublic personal information to those employees who need to know that information to provide products or services.

For purposes of this site, personal information and personal data (information or data that can be linked to a person) are used interchangeably to refer to an identifiable person. 

 

Your data controller

Our products and services may be provided through local operating entities that are subsidiaries or affiliates of Company.

We collect personal information on individuals only as allowed by law.

We limit the collection of personal information to what is relevant and necessary to accomplish a lawful purpose in this instance the maintenance, functionality and usage of our website.

When visitors submit information on this website via the Get In Touch button, we collect the data provided in the form, and also the visitor’s IP address and browser user agent string.

Information we collect about you automatically.

We collect limited personal information from persons who simply browse our Internet Web sites. The information that we automatically collect includes your domain name or Internet Protocol address, the type of browser and operating system you used, date and time you visited the site, Web pages you visited, and any forms you downloaded. Cookies are simple text files stored on your computer by your Web browser. We do not use such cookies to collect or store personal information. We collect personal information about you through our Web site only if you provide it to us voluntarily through comments, e-mail, registration forms, or surveys.

Browser Information – Information that is automatically collected via analytics systems providers from your browser, including your IP address and/or domain name and any external page that referred you to us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.

Log Information – Information that is generated by your use of our website that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity  and any internal and external information related to pages that you visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Data analysis – Our website pages may contain web beacons or pixel tags or any other similar types of data analysis tools that allow us to track receipt of correspondence and count the number of users that have visited our webpage or opened our correspondence. We may aggregate your personal information with the personal information of our other clients on an anonymous basis (that is, with your personal identifiers removed), so that more rigorous statistical analysis of general patterns may lead us to providing better products and services.

If your personal information is completely anonymized, we do not require a legal basis as the information will no longer constitute personal information. If your personal information is not in an anonymized form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market.

Internal business purposes and record keeping – We may need to process your personal information for internal business and research purposes as well as for record keeping purposes. Such processing is in our own legitimate interests and is required in order to comply with our legal obligations. This may include any communications that we have with you in relation to the products and services we provide to you and our relationship with you. We will also keep records to ensure that you comply with your contractual obligations pursuant to the agreement (‘Terms of Service”) governing our relationship with you.

Legal Notifications

Often the law requires us to advise you of certain changes to products or services or laws.  We may need to inform you of changes to the terms or the features of our products or services. We need to process your personal information to send you these legal notifications. You will continue to receive this information from us even if you choose not to receive other correspondence from us.

Sharing of information

Except as discussed below, the Company will not disclose any of its clients’ confidential information to a third party, except: (a) to the extent that it is required to do so pursuant to any applicable laws, rules or regulations; (b) if there is a duty to disclose; (c) if our legitimate business interests require disclosure; (d) in line with our Terms of Service; (e) at your request or with your consent or to those described in this Privacy Notice. The Company will endeavor to make such disclosures on a “need-to-know” basis, unless otherwise instructed by a regulatory authority. Under such circumstances, the Company will notify the third party regarding the confidential nature of any such information. 

As part of using your personal information for the purposes set out above, the Company may disclose your personal information to the following:

Any members of the Company, which means that any of our affiliates and subsidiaries may receive such information; any of our service providers, for business purposes, such as specialist advisors who have been contracted to provide us with administrative, financial, legal, tax, compliance, insurance, IT, analytics, research or other services. If the Company discloses your personal information to service providers, in order to perform the services requested by visitors, such providers may store your personal information within their own systems in order to comply with their legal and other obligations.  We require that service providers who process personal information acknowledge the confidentiality of this information, undertake to respect any visitor’s right to privacy and comply with all relevant privacy and data protection laws and this Privacy Notice.

Please note that Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

We tell people who provide personal information to us the purpose for which the information is collected. We tell persons who are asked to provide personal information about the general uses that we will make of that information. We do this at the time of collection; please see sections above regarding comments and embedded content.

We tell people who provide personal information about their opportunity to review that information. We allow individuals who provide personal information to review the information and contest its accuracy or completeness.

We will provide additional explanations of our privacy policy if requested. If you have further questions about our privacy policy, you may contact us at the mailing address provided below or via the Get In Touch button on this website.

How we protect personal data or personal information.  The Company respects the privacy of any users who access its website, and it is therefore committed to taking all reasonable steps to safeguard any existing or prospective clients, applicants and website visitors.  We have the necessary and appropriate technical and organisational measures and procedures in place to ensure that your information remains secure at all times. We regularly train and raise awareness for all our employees to the importance of maintaining, safeguarding and respecting your personal information and privacy. We regard breaches of individuals’ privacy very seriously and will impose appropriate disciplinary measures, including dismissal from employment.

Where we store your personal data.  Our operations are supported by a network of computers, servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers may store and process your personal data in the European Union, the United Kingdom, the United States of America and elsewhere in the world.

Data Retention

Safeguarding the privacy of your personal information is of utmost importance to us, whether you interact with us personally, by phone, by email, over the internet or any other electronic medium. We will hold personal information, for as long as we have a business relationship with you, in secure computer storage facilities, and we take the necessary measures to protect the personal information we hold from misuse, loss, unauthorized access, modification or disclosure.

When we consider that personal information is no longer necessary for the purpose for which it was collected, we will remove any details that will identify you or we will securely destroy the records.

 

What rights you have over your data

You can request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

 

Links and Access to third-party and affiliated sites

LINKS FOUND ON THE SITE MAY LET YOU LEAVE THIS SITE TO ENTER OTHER SITES. YOU ACKNOWLEDGE THAT SUCH LINKED SITES ARE NOT UNDER THE CONTROL OF COMPANY, AND COMPANY IS NOT RESPONSIBLE FOR THE CONTENTS OF ANY LINKED SITE OR ANY LINK CONTAINED IN A LINKED SITE, OR ANY CHANGES OR UPDATES TO SUCH SITES. COMPANY IS NOT RESPONSIBLE FOR WEBCASTING OR ANY OTHER FORM OF TRANSMISSION RECEIVED FROM ANY LINKED SITE. COMPANY IS PROVIDING THESE LINKS TO YOU ONLY AS A CONVENIENCE, AND THE INCLUSION OF ANY LINK DOES NOT IMPLY ENDORSEMENT OF THE SITE BY COMPANY.

Transfers of personal information outside of the European Economic Area (EEA) and the United Kingdom (UK)

We may transfer your personal information outside the EEA and UK to other Company subsidiaries, service providers and business partners (i.e Data Processors) who are engaged on our behalf. To the extent that we transfer your personal information outside of the EEA and UK, we will ensure that the transfer is lawful and that Data Processors in third countries are obliged to comply with the European Union (EU) General Data Protection Act 2016 and the UK Data Protection Act 2018. If transfers of personal information are processed in the US, we may in some cases rely on standard contractual clauses.

Transfers of personal information outside of your country

By using our products and services, and by visiting our website, you consent to your Personal Data being transferred to other countries, including countries that have differing levels of privacy and data protection laws than your country. In all such transfers, we will protect your personal information as described in this Privacy Notice, and ensure that appropriate information sharing contractual agreements are in place.

Your rights

The rights that are available to you in relation to the personal information we hold about you are outlined below.

Information Access

If you ask us, we will confirm whether we are processing your personal information and, if so, what information we process and, if requested, provide you with a copy of that information.

Rectification

It is important to us that your personal information is up to date. We will take all reasonable steps to make sure that your personal information remains accurate, complete and date. If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have disclosed your personal information to others, we will let them know about the rectification where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom, if any, we have shared your personal information so that you can contact them directly.

You may inform us at any time that your personal details have changed by contacting us at the mailing address provided below or via the Get In Touch button on this website. The Company will change your personal information in accordance with your instructions. To proceed with such requests, in some cases we may need supporting documents from you as proof (i.e. personal information that we are required to keep for regulatory or other legal purposes).

Erasure

You can ask us to delete or remove your personal information in certain circumstances such as if we no longer need it, provided that we have no legal obligation to retain that data. Such requests will be subject to the contract that you have with us, and to any retention limits we are required to comply with in accordance with applicable laws and regulations. If we have disclosed your personal information to others, we will let them know about the erasure request where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your personal information so that you can contact them direct.

Processing restrictions

You can ask us to block or suppress the processing of your personal information in certain circumstances such as if you contest the accuracy of that personal information or object to us processing it. It will not stop us from storing your personal information. We will inform you before we decide not to agree with any requested restriction. If we have disclosed your personal information to others, we will let them know about the restriction of processing if possible. If you ask us, if possible and lawful to do so, we will also inform with whom we have shared your personal information so that you can contact them directly.

Data portability

In certain circumstances you might have the right, to obtain personal information you have provided us with (in a structured, commonly used and machine-readable format) and to re-use it elsewhere or ask us to transfer this to a third party of your choice.

Objection

You can ask us to stop processing your personal information, and we will do so, if we are:

Relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing; or

Processing your personal information for research unless we reasonably believe such processing is necessary or prudent for the performance of a task carried out in the public interest (such as by a regulatory or enforcement agency).

Our products and services are not available to children

Our products and services are not directed to persons under the age of 18, hereinafter “Children”, “Child” and we do not knowingly collect personal information from Children. If we learn that we have inadvertently gathered personal information from a Child, we will take legally permissible measures to remove that information from our records. If you are a parent or guardian of a Child, and you become aware that a Child has provided personal information to us, please contact us at the mailing address provided below or via the Get In Touch button on this website and you may request to exercise your applicable access, rectification, cancellation, and/or objection rights.

Notice to California consumers

California consumers and households have the following rights:

  • To request that a business disclose what personal information (about you) the business collects, uses, discloses, shares and sells (and to opt out of such sales, if any);
  • To request deletion of Personal Information (as defined in the CCPA) a business collects or maintains. This right is subject to a verifiable request.
  • To opt-out of a sale of Personal Information. A “sale” occurs when your Personal Information is exchanged with a non-service provider, third party in exchange for valuable consideration. It is not a “sale” when you intentionally interact with a third party.
  • To not receive discriminatory treatment by the business for exercising any of the privacy rights conferred under the CCPA. Please note that all services are provided without charge; consequently, there is no differential pricing among consumers/visitors for the use of services. 

Exercising Your Rights Under the CCPA

Right to Know

  • To exercise your rights under the CCPA, you may contact us using the contact information at the bottom of this policy or the Get In Touch button on the site. Pursuant to the law, we will honor any verifiable request. You have the right to make a free request two times in any 12-month period. We will make the disclosure within 45 days of receiving your request unless we require an extension. In the event that we reasonably need a 45-day extension, we will notify you of the extension within the initial 45-day period.

CCPA Right to delete

  • California consumers and households have the right to request that a business delete any personal information, subject to certain exceptions. After we receive and validate your request, we will delete the related personal information, as well as direct our service providers, if any, to delete your personal information, unless an exception applies.
  • The CCPA permits using a designated authorized agent to make a request on a consumer’s behalf. Both the designated agent and the consumer are subject to verification before accepting a consumer rights request.
  • California residents may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by writing to them at 400 R Street, Sacramento, CA 95814, or by telephone at 800.952.5210. For other states, please check with your state’s consumer protection authority.
  • Residents of the state of California have the right to request certain information from us with respect to the types of personal information we share with third parties for their direct marketing purposes, as well as the identities of the third parties we have shared such information with during the immediately preceding calendar year. To exercise your choices, please contact us using the contact information at the bottom of this Privacy Policy.
  • If you have any questions about this Policy, the practices of the Service, your dealings with the Service, or wish to update us with your preferences, you may contact us using the information below.

Notice for non-US residents:

If you are not satisfied with our response to your complaint, you have the right to submit a complaint with a regulator. You can contact the appropriate regulator direct from the details below:

For residents of Canada:
Office of the Privacy Commissioner of Canada
30, Victoria Street
Gatineau, QC K1A 1H3, Canada

For residents of the United Kingdom:
The Information Commissioner’s Office
Wycliffe House, Water Ln
Wilmslow SK9 5AF, UK

For residents of Europe:
Irish Data Protection Commission
21 Fitzwilliam Square South
Dublin 2

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We may amend this Privacy Notice at any time by posting the amended version on this site including the effective date of the amended version. We will announce any material changes to this Privacy Notice on our website.

Any questions, complaints, comments and requests regarding this Privacy Notice are welcome and may be sent to the mailing address provided below or submitted via the Get In Touch Button on this website:

Mailing Address:

Numeus Research, LLC
757 3rd Avenue, 20th Floor
New York, NY 10017

 

LAST UPDATED:  June 16, 2022

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