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PRIVACY POLICY
ACURIS (TRADING AS MERGERMARKET LTD) PRIVACY NOTICE
* About us
* About this notice
* About the data we hold
* Our security procedures
* Will we disclose person data to anyone else?
* Rights of data subjects
* Complaints or queries
1. ABOUT US
1. This is the privacy notice for the Acuris Group, a group of companies
owned by Mergermarket Limited. Mergermarket Limited is incorporated in
England, with company number 05048084, of 10 Queen Street Place, London,
EC4R 1BE and registered with the Information Commissioner’s Office under
number: Z4836264.
Acuris is part of ION Analytics. You can read more about our affiliated
companies here.
2. We provide a range of research and reporting products relating to fixed
income, transactions & infrastructure, equities, compliance, KYC and due
diligence, as well as hosting events on areas of interest to such sectors
(any such services, our Services). A list of our products (Products) is
set out in the table below.
Debtwire, Xtract Research, Creditflux, Mergermarket, Unquote, AVCJ, Activist
Monitor, Inframation, Wealth Monitor, Hedge Fund Law Report, Anti-Corruption
Report, Cybersecurity Law Report, C6, Capital Profile, Deal Reporter, Parr,
TIM, Acuris Research, Perfect Information
1. Due to its specific nature, the processing activities carried out by C6
Limited are set out in a separate privacy notice which is accessible at
https://www.c6-intelligence.com
2. ABOUT THIS NOTICE
1. This notice explains what personal data we collect in connection with the
provision of our Services, why we need that data, and how we use it.
2. As part of our Services, we will share personal data with third parties
(for more details on this have a look at section 5 below). This notice
only deals with our use of personal data. Any parties with whom we share
personal data (other than our processors) are not bound by this privacy
notice. This notice should make it clear exactly when and to whom data
may be transferred – but if you have any questions feel free to send us
an email at: DPO@acuris.com.
3. Our website provides links to other websites (not run by an Acuris Group
company), which are beyond our control. We encourage you to read the
privacy statements on the other websites you visit.
4. We might need to change this privacy notice from time to time. We will
publish our privacy notice on our website (available at www.acuris.com or
any other website run by us to promote the Products listed above) and
we’ll do our best to update you directly if we think the changes might
materially affect you. Please do keep an eye on our notice before giving
us any personal data.
3. ABOUT THE DATA WE HOLD
1. Visitors to Our Websites
If you visit our websites, we will use cookies: to help us make sure our
website performs correctly; to analyse how visitors use our websites (to
help us make our websites more effective); and to help us make marketing
decisions about how we promote our services online.
Cookies are small data files that websites store on your electronic
device. so that the website can store data and will enable us to collect
information, which is likely to include data from which you can be
identified.
For further details, including the duration that we retain data for,
please see our Cookie Notice https://www.acuris.com/cookie-notice.
Our lawful basis for using cookies to collect and process usage data is
that it is necessary to protect our legitimate interest of promoting our
business.
2. Marketing
The Acuris Group has a team which identifies people who are likely to
find our events or products (or those of our affiliated companies) useful
for their jobs. Our team will look for and source business contact
details and information about an individual’s job role both online (on
publically available resources and business websites), through networking
activities and may also collect details from event attendees, newsletter
subscribers and subscribers of our Products.
Our team will use those business contact details to send event invites
and emails about relevant industry news. We always include an unsubscribe
link at the bottom of any such email which we send, so that you can let
us know if you do not wish to receive any further marketing emails.
Our lawful basis for using personal data in this way is that it is
necessary to protect our legitimate interest of promoting our business.
3. Events
If you sign up to an event:
(a) We will collect the details required to deliver our contractual
obligations, such as payment, accommodation and attendee details. We will
only process such details as necessary to enable us to perform the
contract between you and us.
(b) We will publish an attendance list (including your name and company
name) which will be available to other attendees and event sponsors. We
will provide you with the name of any event sponsors to which we are
transferring any data about you. We will provide you with the name of any
sponsors of the event once they are confirmed. We consider the processing
to be necessary to protect our legitimate interest of running an
effective event. We will not share your details with the venue or other
third parties for marketing purposes unless you provide your consent.
(c) We will also request and if you provide it, collect, information
about your relevant interests and preferences. We will use this
information to help us make decisions about the kind of events and any
services or products you might be interested in hearing about from us and
will use this information for marketing purposes (as set out in section
3.2 above).
If you are speaking at one of our events:
(a) We will use the details you provide us with to contact you in
connection with the event and, if relevant, process any payment or
facilitate any obligations or rights set out in agreement between you and
us. Any such processing will be carried out on the basis that it is
necessary to facilitate the contract between you and us. We will retain
details of transactions for a between you and us in accordance with our
retention policy (a link to which is included at the bottom of this
section 3). We will only use the retained information to comply with
regulatory requirements or in the event of a dispute between you and us –
which processing would be carried out on the basis that it is necessary
to protect our legitimate interest of protecting our business.
(b) We will publicise the bio that you provide, on the basis that such
processing is necessary to achieve our legitimate aim of running a
successful event and we will retain both the bio and details relating to
the talk you give after the event for our internal records as well as for
marketing purposes for future events.
(c) We will also use the information you provide us with for marketing
purposes (as set out in section 3.2 above).
4. Subscription Services
We will use personal data that we collect from clients (which may include
details of our clients’ staff) who have subscribed to receive our
Services, in the following ways:
(a) To fulfil the contract: which includes setting you up as a client,
providing you with updates relating to our Products and processing your
user ID, password and contact details and any payments to be made. Any
such use will be on the basis that the processing is necessary to perform
the contract between you and us.
When you terminate your subscription, we will keep full records about
your subscription for two years in case you want to reactive your
account.
We will also retain details of transactions for a period of up to 6 years
for our internal records. Any further use of the retained information
will only be to comply with regulatory requirements or in the event of a
dispute between the recipient and us – which processing would be carried
out on the basis that it is necessary to protect our legitimate interest
of protecting our business.
(b) We use automated tools to monitor website access using your account
details, to identify and manage potential security issues and to keep
your account safe. Any such usage data shall be processed to the extent
necessary for our legitimate interest of ensuring our Products are
secure. We will retain usage data for a period of up to 6 years for our
internal records. Any further use of the retained information will only
be to comply with regulatory requirements or in the event of a dispute
between you and us – which processing would be carried out on the basis
that it is necessary to protect our legitimate interest of protecting our
business.
(c) We may also use corporate contact details for marketing purposes (as
set out in section 3.2 above).
5. Information Databases - news
Our internal Acuris team of journalists will collect, use and store data
relating to third parties (such as directors, shareholders, PSCs and
their advisors). They will do this to draft reports, profiles, articles
and blogs which are then published for the benefit of our subscribers
(who may be based outside the EEA) or included in the newsletters which
we circulate or blogs which we post. Typically, our subscribers for this
type of service include private banks, banking and finance and
professional services firms, such as law firms, tax advisors,
accountancies and consultancy firms.
Our lawful basis for such processing is that it is necessary to protect
our legitimate interest, which is to provide journalistic services in the
public interest.
Any such processing will take into consideration the relevant codes of
conduct, including the BBC Editorial Guidelines, the Ofcom Broadcasting
Code and the Editors’ Code of Practice.
We work hard to maintain the quality of that information and amend
information if we believe it to be incorrect or no longer relevant.
6. High Net Worth Individuals Profiles
We collect, use and store in our searchable database, data relating to
high net worth individuals which we provide to our subscribers (some of
which may be based outside the EEA). Typically, our subscribers for this
Product include private banks, professional services firms, such as law
firms, tax advisors, accountancies and consultancy firms, as well as
luxury retail and service companies such as private jet charter firms or
jewellers. How a subscriber uses any information obtained from our
database is the responsibility of the subscriber – and might include
using the data to increase its knowledge of its existing clients, to make
business development decisions and/or to contact the individual in
question. Please note that subscribers are not bound by the terms of this
privacy notice – which deals only with our use of personal data.
We will only transfer such data outside the EEA if it is to a territory
which the European Commission has found to have adequate safeguards in
place or if we have implemented appropriate safeguards.
The data that we collect and include in a report is likely to include:
* Name and contact details
* Date of birth
* Gender
* Number of children
* Civil status (married/single/divorced/widowed)
* Links to social media accounts (such as LinkedIn, Xing, Twitter,
Facebook) and information publicly available on such pages Names of
other family members and relatives (excluding minors)
* Education and details of former and current job positions
* Details of companies and/or entities with which the Third Party may be
associated, or in which they may hold a directorship or have a
shareholding;
* Details of wealth accumulated through liquidity events (selling equity
in businesses), potential liquidity events, emoluments and assets (if
publicly available)
* Information in news articles such as interests and/or other
biographical information
* Details of corporate advisors
* Interests and hobbies
We do not envisage that we will collect any special categories of data -
that is data relating to an individual’s race or ethnicity, religious or
philosophical beliefs, sex life, sexual orientation, political opinions,
trade union membership, information about health and genetic and
biometric data; or data relating to criminal offences, for the purpose of
such services. We have implemented safeguards to minimise the risk that
such data is collected indirectly.
Our internal researchers will source such data from publically available
sources which is likely to include public registries such as Companies
House as well as business websites and other online resources.
Our lawful basis for such processing is that it is necessary to protect
our legitimate interest of providing an efficient and effective wealth
profiling service to our subscribers. In order to ensure that the rights
and fundamental freedoms of those individuals profiled are protected,
provided we have the correct contact details, we will try to notify them
upon obtaining their data from a third-party source.
We retain profiles on High Net Worth Individuals for no longer than 35
years, subject to the rights of the relevant data subjects.
7. Job Applicants
If you contact us about a job, we will use the information you provide us
with to assess your suitability for the role and progress your
application. Data we will require includes contact details, your
curriculum vitae, your previous experience, education and answers to
questions relevant to the role you have applied for. Our HR team and the
hiring manager for the role will have access to this data.
If you contact us about a job, we will use the information you provide us
with to assess your suitability for the role and progress your
application. Data we will require includes contact details, your
curriculum vitae, your previous experience, education and answers to
questions relevant to the role you have applied for. Our HR team and the
hiring manager for the role will have access to this data.
We will also ask about equal opportunities data. We use this data to
produce and monitor equal opportunities statistics for legal reasons.
There is no obligation to provide this data and it will not affect your
application if it is not provided. This data will not be made available
to any staff outside of our HR team, including hiring managers.
We will only share your data with contracted third parties if it is
necessary for the recruitment process, and will notify you at the time.
We will never sell your data or use it for marketing purposes. If we need
to securely process the data in another country, we will let you know
before the transfer happens.
If your application is not successful, unless you ask us to retain your
data for other opportunities in the future, we will store your details
for six months to help with any questions, before securely deleting or
anonymising the data.
If your application is successful, we will need to complete employment
checks for legal reasons, to verify your right to work in the country and
to verify your previous employment references.
We will only process such data to the extent required to achieve our
legitimate interest of maintaining a workforce for our business
8. A copy of our retention policy in respect of all of the personal data we
hold can be accessed here.
4. OUR SECURITY PROCEDURES
Security of personal data is very important to us. Our business operates
under the ISO 27001 International Security Standard. We use a wide range of
organisational, technical, physical and operational controls, which are
assessed for effectiveness on a regular basis.
5. WILL WE DISCLOSE PERSONAL DATA TO ANYONE ELSE?
1. We will disclose any personal data that we hold to our employees,
affiliated companies and third parties who are contracted to help us
provide our Services (some of whom may be based outside the EEA). Any
such third parties will be acting as processors on our behalf and will be
contractually bound only to use the data in accordance with our
instructions and to implement adequate security measures. The data will
only be transferred in these circumstances if appropriate safeguards are
implemented between us and the processor.
2. We may share personal data with third parties (which will also be acting
as controllers in respect of that personal data) in the following
circumstances:
* If we are under a legal duty to do so or if it is required to enforce
or apply our contracts or to protect the operation of our website, or
the rights, property or safety of us or others.
* If we sell, transfer or merge parts of our business or our assets. If a
change happens to our business, then the new owners will only be
entitled to use personal data in accordance with the provisions set out
in this privacy notice.
* Between companies within the Acuris Group (provided that in each case
such use is restricted to the provisions set out in this privacy
notice). Some of those entities may be based in or have offices outside
the EEA. Any such transfers shall be subject to appropriate safeguards
and the receiving entities shall be bound by the provisions set out in
this privacy notice. For more details about the Acuris Group, click
here.
6. RIGHTS OF DATA SUBJECTS
Individuals have certain rights under the applicable data protection
legislation in respect of the personal data which we hold relating to them.
This includes:
(a) Right to be informed: the right to be informed about what personal data
we collect and store about you and how it’s used.
(b) Right of access: the right to request a copy of the personal data held.
(c) Right of rectification: the right to require us to correct any personal
data held about you which is inaccurate or incomplete.
(d) Right to be forgotten: in certain circumstances, the right to have the
personal data held about you erased from our records.
(e) Right to restriction of processing: the right to request us to restrict
the processing carried out in respect of personal data relating to you. You
might want to do this, for instance, if you think the data held by us is
inaccurate and you would like to restrict processing until the data has been
reviewed and updated if necessary.
(f) Right of portability: in certain circumstances, the right to have the
personal data held by us about you transferred to another organisation, to
the extent it was provided in a structured, commonly used and
machine-readable format.
(g) Right to object: the right to object where processing is carried out,
including for direct marketing purposes.
(h) Right to object to automated processing: the right not to be subject to
a decision based solely on automated processing (including profiling) which
produces legal effects (or other similar significant effects) on you.
7. COMPLAINTS OR QUERIES
1. If you wish to exercise any of your rights set out in section 6 above or
contact us about any another matter, please contact our Data Protection
Officer at:
* Call us on +44 (0)20 3741 1000
* Send an email to Data.Subject.Request@acuris.com
* Send a letter to Data Protection Officer, 10 Queen St Place, London,
EC4R 1BE, UK.
2. When we receive a request, we will try to verify your identity and the
request, before responding to you within 28 days.
3. Given the nature of the Services we provide, in certain situations, we
may be able to rely on certain exemptions under the General Data
Protection Regulation and the Data Protection Act 2018. These exemptions
may enable us to resist the disclosure of information, erasure requests
and rectification requests in certain circumstances, and exempt us from
some notification obligations.
4. We will confirm to you in writing to acknowledge receipt of any request
we receive relating to your rights as a Data Subject, and we will let you
know if we have complied with your request. If having, carried out an
assessment, we believe we have an overriding reason for resisting your
request, we will let you know why we have reached that conclusion.
5. We will retain details of your request for two years, for quality
assurance purposes, and may retain request relating to marketing
preferences or restricted use for a longer period to ensure that we can
comply with your request and to help if you have any further questions
about the matter. Any such processing will be limited to the extent
strictly necessary to achieve our legitimate interest of providing a
robust and secure data management procedure.
6. Please let us know if you are not happy about how we are handling your
data. We will do our best to resolve the matter, but if you have further
concerns it is your right to make a complaint to our Data Protection
Officer (dpo@acuris.com) or the UK Information Commissioner’s Office at
https://www.ico.org.uk
THIS PRIVACY NOTICE WAS DRAFTED WITH BREVITY AND CLARITY IN MIND. IF YOU WOULD
LIKE MORE DETAILS, PLEASE LET US KNOW.
THIS NOTICE WAS LAST UPDATED ON 16 JUNE 2021.
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