Disclosures

BACKGROUND

Squarepoint Foundation does not collect Personal Data, except that provided via cookies, when you visit our Website. We may collect and use Personal Data you decide to send us, for example via email or other communications. We may also collect some limited Personal Data through other means, for example from publicly available sources and third parties. Such Personal Data will be collected and used in accordance with this Privacy Policy. Squarepoint Foundation is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.

At Squarepoint Foundation, we respect privacy and we are committed to keeping your Personal Data secure. This Privacy Policy governs the handling of Personal Data by Squarepoint Foundation in connection with interactions and communications with us.

We use the following definitions in this Privacy Policy:

“Personal Data” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with, directly or indirectly, a particular living individual or household, and other personal information which is in the possession of, or is likely to come into the possession of, Squarepoint Foundation. In addition to factual information, it includes any expression of opinion or intentions with respect to an individual.

“Squarepoint Foundation”, “we” or “us” means Squarepoint Foundation, an entity registered by the Charity Commission for England and Wales, with registered charity number 1195690.

“Website” means www.squarepoint-foundation.com.

THE TYPES OF PERSONAL DATA WE COLLECT

In relation to the use of our Website and other communications and interactions with us, we may collect and process the following Personal Data about you:

• Information that you provide to Squarepoint Foundation. This includes information about you that you give to us by filling in forms or by communicating with us. Such information may include (by way of a non-exhaustive list):
  • your name, postal address, e-mail address, telephone number; and
  • records and copies of your correspondence with us, if you contact us.
• Information that we collect or generate about you. Such information may include (by way of a non-exhaustive list):
  • a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the responses which we have provided to you;
  • certain information that is provided by the cookies that we use; and
  • other information you or others may provide to us during your communications or relationship with us.
• Information we obtain from other sources. Such information may include limited publicly available information we collect directly or indirectly. We also collect some data from third party vendors.
• Anonymized data. In addition to the categories of Personal Data described above, Squarepoint Foundation may also process anonymized information and data that is not processed by reference to a specific individual.

HOW WE USE YOUR INFORMATION

Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

• to allow you to use and access the functionality provided by the Website;
• in order to respond to your queries;
• for in-depth threat analysis;
• for in-depth statistical report about Website usage;
• in order to comply with, and in order to assess compliance with, applicable laws, rules and regulations;
• for the administration and maintenance of databases storing Personal Data; or
• for our general operational or business purposes.

We use Personal Data for a variety of reasons. These include:

• we may need to do so in order to perform our contractual obligations with third parties;
• we may have legal and regulatory obligations;
• we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; and
• the use of your Personal Data as described may be necessary for our legitimate business interests, such as:
• allowing us to effectively and efficiently manage and administer the operation of our business (including our Website);
• monitoring the use of our copyrighted materials;
• monitoring Website usage;
• responding to correspondence that we receive via our Website;
• enabling quick and easy access to information about Squarepoint Foundation; and
• maintaining the security of our networks, IT systems and physical premises.

We take steps to ensure that the Personal Data is accessed only by employees of Squarepoint Foundation that have a need to do so for the purposes described in this Privacy Policy.

DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

We may also share your Personal Data outside of Squarepoint Foundation for the following purposes:

• with our partners. We take steps to ensure that Personal Data is only transferred to partners that are contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
• with third party agents and contractors for the purposes of providing services to us (for example, Squarepoint Foundation’s professional advisors, and IT and communications providers). We take steps to ensure these third parties are contractually obliged to comply with appropriate data protection obligations and to only use your Personal Data as described in this Privacy Policy;
• to the extent required by law, for example, if we are under a duty to disclose your Personal Data in order to comply with any legal obligation, or to establish, exercise or defend our legal rights;
• police and law enforcement in the event of a security or other investigation that necessitates their involvement; or
• if Squarepoint Foundation or a component thereof has management or control changes, in which case we may need to disclose your Personal Data for due diligence and other purposes.

INTERNATIONAL TRANSFERS OF PERSONAL DATA

Squarepoint Foundation is a globally active organisation. Our operations and partners are spread around the world. As a result, we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your country.

Where we transfer your Personal Data to another jurisdiction, we take steps to ensure that it is protected and transferred in a manner consistent with legal requirements.

For example, in relation to data being transferred out of the European Economic Area, this may be done in one of the following ways:

• the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;
• the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
• where the recipient is located in the US, such transfer might be pursuant to the EU-U.S. Data Privacy Framework; or
• applicable law might otherwise permit us to transfer your Personal Data outside the European Economic Area.

You can obtain more details of the protection given to your Personal Data when it is transferred to another jurisdiction by contacting us as described below.

HOW WE SAFEGUARD YOUR INFORMATION

We have certain controls in place designed to maintain the security of our information and information systems, including controls designed to protect Personal Data with safeguards according to the sensitivity of the relevant information and controls (such as restricted access) placed on our computer systems.

If you contact a Squarepoint Foundation employee about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.

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 of your personal information transmitted to our Website. 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 Website.

HOW LONG WE KEEP YOUR PERSONAL DATA

How long we will hold your Personal Data for will vary and will be determined by the following criteria:

• the purpose(s) for which we are using it – Squarepoint Foundation will need to keep the data for as long as is necessary therefor; and
• legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

YOUR RIGHTS

In certain of the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
• the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so;
• in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit that data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Squarepoint Foundation;
• the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
• the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
• the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request;
• the right to object to the use of your Personal Data for direct marketing purposes; and
• the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details listed below.

Your California Privacy Rights. California Civil Code Section 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to .

DESIGNATED REPRESENTATIVE

Squarepoint Foundation's registered office and designated representative in the EU may be contacted using the following contact information:

QUESTIONS AND CONCERNS

If you have any questions or concerns about Squarepoint Foundation's handling of your Personal Data, or about this Privacy Policy, please contact our Data Protection Team using the following contact information:

We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, Squarepoint Foundation's will provide you with the contact information for that regulator.