Privacy Practices and Cookies Policy (July 2019)

The EWM Group is currently made up of; (i) EXECUTIVE WEALTH MANAGEMENT LIMITED (Guernsey) (ii) EWM LLC (US) , (iii) EXECUTIVE WEALTH MANAGEMENT LIMITED (Guernsey) Zweigniederlassung ZH (Switzerland) and (iv) EWM-UK LIMITED, (UK), together and individually for the purpose of this notice “EWM”.

EWM is committed to protecting your privacy, when you visit our website, provide us with information, submit an enquiry, or when you use our services. EWM seeks to ensure the highest standards of compliance with all relevant data protection laws and regulations.

This privacy notice applies where EWM is the controller of Personal Data. This notice does not apply to the extent EWM processes personal information in the role of a processor on behalf of entities contracted to use our services, (“EWM Customers”).

EWM primarily offers products and services via a private cloud through which EWM Customers (and/or their affiliates) manage their employee’s compensation plan related details, and collect, use, share or process personal information. EWM does not own, control nor direct the use of any of the personal information which is stored or processed by any EWM Customer via the service.

While EWM endeavours to adopt and implement appropriate and robust privacy and data security practices, we are not responsible for the privacy or data security practices of EWM Customers, which may differ from those set forth in this privacy notice. If your personal data has been submitted to EWM by or on behalf of your employer (usually the EWM Customer) and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable employer (EWM Customer) directly. EWM may only access and process an EWM Customer’s data upon instruction from that EWM Customer.  If you wish to make your request directly to us, please provide us with the name of the EWM Customer who submitted your Personal Data to us. We will refer your request to that EWM Customer and will support them as needed in responding to your request in accordance with the Data Processing Agreement between EWM and that EWM Customer.

This policy applies to all personal data (“Personal Data“) in our possession as controller, and specifically may include the following:

• Name, phone number, address, email address, title, job title, IP address of any public website users who have contacted EWM Global to inquire about our services
• Name, phone number, address, email address, title, job title, IP address, birth date, previous job experience, for any individual who has inquired or been recruited for an EWM employment opportunity

Under the GDPR, and in line with existing data protection legislation and ePrivacy any information we give to you about the processing of Personal Data must be:

• Concise, transparent, intelligible and easily accessible;
• Written in clear and plain language, and
• Free of charge

EWM endeavours to meet those obligations

Where you provide us with your Personal Data in any of the ways described below, you agree that we may collect, store and use it:

(a) in order to perform our contractual obligations

(b) based on our legitimate interests for processing (i.e. for internal administrative purposes direct marketing, maintaining automated back-up systems)

(c) based on your consent, which you may withdraw at any time, as described in this Privacy Notice

Definitions:

• Personal data is information about a living individual, which is capable of identifying that individual.
• Processing is anything done with/to Personal Data, including storing it.
• The data subject is the person about whom Personal Data is processed.
• The data controller is the person or organisation who determines the how and what of data processing.

Key Information required in our Privacy Notice under Chapter III of the GDPR

Who this notice applies to.

• Our employees.
• Suppliers and employees of suppliers who provide us with personal data in the course of our business relationship.
• Business and marketing contacts, in the course of providing and marketing our Services, we also collect and use information relating to visitors to our websites and domains, visitors to our offices, event invitees or attendees, blog or other email recipients, and other business and marketing contacts. 

Identify the contact details of the data controller and where applicable the controller’s representative and the data protection officer

Name: Executive Wealth Management Limited

By email: privacy@ewmglobal.com

By post: Data Privacy Committee, Talacker 41, 8001 Zürich, Switzerland

Purpose of the processing and the legal basis for the processing.

We need your Personal Data to; (i) provide information regarding our services to you (ii) engage with you about a potential or existing business relationship; (iii) communicate with you regarding employment opportunities.

The legitimate interests of the data controller or third party (where applicable)

We have a legitimate interest in using Personal Data as part of the operation of our business and the provision of the services, but always balanced with your rights, and only where that legitimate interest is justified. Examples include using Personal Data to fulfil our service contract with you, get paid for the services we provide, for marketing our products and services to you, fraud prevention, intra-group transfers, or IT security. We may also have a legitimate interest in disclosing information about possible criminal acts or security threats to the authorities.

How we collect Personal Data

We may collect Personal Data when you;

1. interact with us using our websites, applications or services;
2. complete online forms (including call back requests), take part in surveys, download information or publications or participate in any other interactive areas that appear on our website or within our application or service;
3. interact with us using social media (including LinkedIn, Instagram, Twitter);
4. provide your contact details to us when registering to use or accessing any websites, applications or services we make available or when you update those details; and
5. contact us offline, for example by telephone, fax, SMS, email or post.
6. submit personal data as part of an application or contract for employment.

Any recipients or categories of recipients of the Personal Data

Recipients of Personal Data may include EWM Group companies, outsourced IT or other service regulators and law enforcement agencies.

Details of international data transfers

Executive Wealth Management Limited is incorporated in Guernsey (which has been recognized by the European Commission as providing an adequate level of protection for free flow of personal data into Guernsey (Opinion 02072/07/EN WP 141 and Opinion 10595/03/ENWP 79).

From time to time, we may transfer your personal information to our Group companies, suppliers or service providers based outside of the EEA for the purposes described in this privacy notice. Currently this includes transfers to the USA.

When we do this, your personal information will continue to be subject to one or more appropriate safeguards set out in the law. We ensure that the recipient of your Personal Data; (i) offers an adequate level of protection, for instance by being located in a territory the subject of an adequacy decision (like Guernsey), (ii) enters into the appropriate back-to-back agreements and, (iii) if required, standard contractual clauses for the transfer of data as approved by the European Commission.

Retention period or criteria used for determining the retention period

We will keep your personal information for the purposes set out in this privacy notice and in accordance with the law and relevant regulations. We will never retain your personal information for longer than is necessary.

Disposal of personal information

If we no longer need to retain your personal information, we will dispose of it safely in a manner that prevents loss, theft, misuse, or unauthorized access to the information.

The various rights of the data subject

Where EWM is a Data Controller, the following applies;

• You have the right to apply for a copy of the information we hold about you. This is called a data subject access request and you can make a request by writing to us using the contact details above. We may require further information from you in order to verify your identity before disclosing any Personal Data to you.
• You also have the right to have any inaccurate information about you corrected. We want to make sure that your information is accurate and up to date. You may ask us to correct or remove any information that you think is no longer up to date. Please contact us using the contact details below if you would like any corrections made to your information.
• You have the right to object to the processing of your information. You also have the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”).

The right to withdraw consent at any time, where relevant

Where you have given your consent to the processing of your of Personal Data, you may withdraw that consent in writing at any time, by notification to the address above. Note in addition to, or instead of your explicit consent, we may also rely on our legitimate interest as a lawful basis for processing your Personal Data, and that legitimate interest may survive the withdrawal of consent. At a minimum, while you are an EWM Customer, (or while we are owed outstanding payments), we will need to provide the service, attend to faults, and invoice and collect payment for the service.

The right to lodge a complaint with a supervisory authority

If you consider that the processing of Personal Data infringes the GDPR, you believe that we have not been able to assist with your complaint or concern, and you are located in the EEA you have the right to lodge a complaint with the with the competent supervisory authority.

The existence of automated decision making, including profiling and information about how decisions are made, the significance and consequences

To qualify under this heading, the processing must (i) be a decision taken using Personal Data processed solely by automatic means, and (ii) the decision must have a significant effect on the individual concerned. EWM does not use automated decision making to take material decisions about you or your Personal Data.

We Use Cookies!

“Cookies” are small text files sent from a website to the hard drive of a user’s computer to store bits of information related to that user. Cookies can store information about users, including IP addresses, navigational data, server information, data transfer times, user preferences, and passwords needed to access the special areas on our site.

EWM uses cookies for the purpose of storing and retrieving session information in our on-line systems, storing user preferences and for analysing traffic on our site. Third party cookies are used to measure the effectiveness of our online advertising campaigns. No Personal Data or Sensitive Data is stored in these cookies. The data collected using these cookies does not identify individual users.

There are four types of cookies used on the EWM websites:

1. Strictly Necessary Cookies

   These cookies are essential in order to enable you to move around the website and use its features.

2. Performance Cookies

   These cookies collect information about how visitors use the EWM website. EWM uses Google Analytics to track anonymized usage statistics for the site. This data is used to analyse how frequently people visit the site, how the website is found and which pages are most frequently viewed. These cookies don’t collect information that identifies a visitor. This information is combined with data from thousands of other users to create an overall view of website use, and is never identified individually or personally. These cookies are only used to identify ways to improve the website.

   To opt out of being tracked by Google Analytics across all websites please visit:gaoptout

   For more information about Google Analytics, and the cookies it sets, visit:

   gaConceptsCookies

3. Functionality Cookies

   These cookies allow us to remember choices you make (such as mobile device preferences).

4. Targeting Cookies

   To measure the effectiveness of our online advertising campaigns we use 3rd party cookies. For example, for measuring how many unique browsers have seen a particular advertisement and how many of those subsequently visit our website. The data we or our agents collect using cookies does not identify individual users.

   For more information about cookies and how to stop cookies being installed visitallaboutcookies