Privacy Policy
We appreciate your interest in ExpertBridge.co (“Site”). We at ExpertBridge, recognize and
appreciate the importance of respecting the privacy of our customers and are committed to
safeguarding against unauthorized disclosure of, or access to, personal information of our
customers. This Privacy Policy sets forth ExpertBridge’s current policies and practices with
respect to non-public personal information of our customers. By using this Site, you agree to
this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Site.
What information is collected Personal Information
We only collect the personally identifiable information that you provide to us.
If you register for certain Services on this Site, you will be asked to provide certain
personally identifiable information as part of the registration process. This may include:
We may Process the following categories of Personal Data about you:
1. Personal details including given name(s) and preferred name, if any
2. Demographic information: date of birth; salutation; title; and language preferences.
3. With respect to CoE Members (in addition to any other applicable category set out in
this Privacy Policy), we also collect wireless device addresses (including text message
addresses), payment information, professional biography, and other profiling
information pertaining to your experience and expertise.
4. Contact details: address; telephone number; email address; and details of your public
business networking profile(s) or online biographies.
5. Consent records: records of any consents you may have given, together with the date
and time, means of consent and any related information (e.g., the subject matter of the
consent).
6. Payment details: invoice records; payment records; billing address; payment method;
bank account number; card or account security details; BACS details; SWIFT details;
IBAN details; payment amount; and payment date.
7. Data relating to our Sites: device type; operating system; browser type; browser
settings; IP address; language settings; dates and times of connecting to a Site;
username; password; security login details; usage data; aggregate statistical
information; internet service provider (ISP) details; referring and exit pages; and
clickstream data.
8. Employer details: where you interact with us in your capacity as an employee, the
name, address, telephone number and email address of your employer, to the extent
relevant.
9. Views and opinions: any views and opinions that you choose to send to us, or publicly
post about us on social media platforms.
We may use personally identifiable information in order to develop, offer, and deliver
products and services; respond to inquiries from you or your representative; or to fulfil legal
and regulatory requirements. ExpertBridge may collect non-public personal information
about you from any of the following sources:
1. From you or your representative on applications, registrations, or other forms (for
example, your name, address, assets and income);
2. From you or your representative regarding your preferences (for example, based on
your activity on our website);
3. From other sources with your consent or with the consent of your representative (for
example, from other institutions such as credit reporting agencies);
4. From investment activity (for example, your investments in private placements);
5. From other interactions with ExpertBridge (for example, discussions with our
customer service staff or your entry of information into our interactive tools).
6. From email correspondence from you (we may gather the information in a file
specific to you).
Non-Personal Information
We also may collect certain non-personally identifiable information when you visit the Site.
This information includes the type of Internet browser and operating system you are using,
the domain name of your Internet service provider, the URL that you visited before you came
to our Site, the URL to which you next go, and your IP (Internet Protocol) address, pages
visited, and average time spent on our Site. This information may be used, for example, to
alert you to software compatibility issues, or it may be analysed to improve our Site design
and functionality. When you use the contact features of the Site, you consent to the review
and internal use of your communication by ExpertBridge. We also may use non-personally
identifiable information in the aggregate to analyse Site usage and to gather broad
demographic information.
Cookies
Like most major websites, ExpertBridge uses cookies on our Site. Cookies are pieces of
information that a website transfers to a user’s hard drive for record-keeping purposes while
visiting a Site. Cookies make using the Internet easier by, among other things, saving your
passwords and preferences for you. For example, a cookie lets the Site remember that you’ve
registered, which allows us to speed up your future activities on our Site, and which allows
you to enter your password/log in ID less frequently while visiting our Site. Our cookies do
not contain any personally identifying information although cookies may enable us to relate
your use of our Site to personally identifying information that you previously submitted. For
example, it enables us to enhance personalization on the Site, such as calling you by name
when you return to our Site. We will always give you the choice of opting out of receiving a
cookie by checking the appropriate box. However, if you decide to opt out, your use of the
Site may be slowed because you will have to enter your log in ID and password at every
session.
How we use and disclose the information
Disclosure of Information: As a general rule, ExpertBridge will not share, rent, sell or
otherwise disclose any of your personal information except with your permission. However,
ExpertBridge may disclose personal information in the following ways:
1. In using certain of the services, some of your personal information will be displayed
either to other persons or entities whom you designate, or to the public. You may
modify the settings on your account to designate to whom certain information is
disclosed.
2. Affiliates, including affiliated services providers;
3. We may disclose your personal information to our third-party contractors, service
providers, and agents who perform services for ExpertBridge. These contractors and
service providers are permitted to use the personal information only for the purposes
of such services.
4. We may be legally obligated to disclose personally identifiable information to the
government, law enforcement officials or third parties under certain circumstances,
for example, in response to legal process, court order or a subpoena and tax reporting.
We also may disclose such information where we believe it is necessary to
investigate, prevent, or take action regarding illegal activities, suspected fraud,
situations involving potential threats to the physical safety of any person, violations of
our Website Terms of Use, abuse of this Site, security breaches of this Site, or as
necessary to protect our systems, business, users or others or as otherwise required by
law.
5. We may disclose and transfer your information as part of a merger, acquisition or
other sale or disposition of our assets or business.
6. Other organizations, with your consent or as directed by your representative; and
7. Other organizations, as permitted or required by the laws that protect your privacy
(for example, for fraud prevention).
In addition, we may disclose aggregated information to advertisers and for marketing or
promotional purposes. In these situations, we do not disclose to these entities any information
that could be used to personally identify you.
We require each of the above parties to adhere to our privacy standards and to use this
information only for the limited purpose for which it was shared. Individuals interact with us
in a variety of ways, and under some of these variations, we may exchange information with
parties in addition to those described above.
Former customers
If you are a former customer, your information is treated in the same manner as the
information of current customers. If you have any questions or concerns regarding your
privacy with ExpertBridge, please contact us at teams@expertbridge.co
Data retention and minimization
We take every reasonable step to ensure that your Personal Data are only retained for as long
as they are needed in connection with a lawful purpose.
We take reasonable step to limit the volume of your Personal Data that we Process to what is
necessary and is reasonably necessary in connection with the purposes set out in this Privacy
Policy.
We take every reasonable step to ensure that your Personal Data are only Processed for the
minimum period necessary for the purposes set out in this Privacy Policy. The criteria for
determining the duration for which we will retain your Personal Data are as follows:
1. we will retain copies of your Personal Data in a form that permits identification only
for as long as:
a. We maintain an ongoing relationship with you (e.g., where you are a user of our
services, are a COE Member (or have applied to become one), or you are lawfully included in
our mailing list and have not unsubscribed);
a. Should you cease being a COE Member, six (6) years from your most recent
interaction with any ExpertBridge client; or
a. Your Personal Data are necessary in connection with the lawful purposes set out in
this Privacy Policy, for which we have a valid legal basis (e.g., where we have a legitimate
interest in processing your data for the purposes of operating our business and fulfilling our
obligations under a contract), and
2. The duration of:
a. Any applicable limitation period under applicable law (i.e., any period during which
any person could bring a legal claim against us in connection with your Personal Data, or to
which your Personal Data may be relevant); and
a. An additional two (2) month period following the end of such applicable limitation
period (so that, if a person brings a claim at the end of the limitation period, we are still
afforded a reasonable amount of time in which to identify any Personal Data that are relevant
to that claim), and:
3. In addition, if any relevant legal claims are brought, we may continue to Process your
Personal Data for such additional periods as are necessary in connection with that
claim.
During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our
Processing of your Personal Data to storage of, and maintaining the security of, those data,
except to the extent that those data need to be reviewed in connection with any legal claim, or
any obligation under applicable law.
Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have
concluded, we will either: permanently delete or destroy the relevant Personal Data; or
anonymize the relevant Personal Data.
Your rights
Under applicable law, you may have a number of rights, including: the right not to provide
your Personal Data to us; the right of access to your Personal Data; the right to request
rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of
your Personal Data; the right to object to the Processing of your Personal Data; the right to
have your Personal Data transferred to another Controller; the right to withdraw consent; and
the right to lodge complaints with Data Protection Authorities. We may require proof of your
identity before we can give effect to these rights.
Subject to applicable law, you may have a number of rights regarding the Processing of your
Relevant Personal Data, including:
The right not to provide your Personal Data to us (however, please note that we may
be unable to provide you with the full benefit of our Sites, or our services, if you do
not provide us with your Personal Data – e.g., we may not be able to process your
orders without the necessary details);
The right to request access to, or copies of, your Relevant Personal Data, together
with information regarding the nature, Processing and disclosure of those Relevant
Personal Data;
The right to request rectification of any inaccuracies in your Relevant Personal Data;
The right to request, on legitimate grounds:
Erasure of your Relevant Personal Data; or
Restriction of Processing of your Relevant Personal Data;
The right to object, on legitimate grounds, to the Processing of your Relevant
Personal Data by us or on our behalf;
The right to have certain Relevant Personal Data transferred to another Controller, in
a structured, commonly used and machine-readable format, to the extent applicable;
Where we Process your Relevant Personal Data on the basis of your consent, the right
to withdraw that consent (noting that such withdrawal does not affect the lawfulness
of any Processing performed prior to the date on which we receive Privacy Policy of
such withdrawal, and does not prevent the Processing of your Personal Data in
reliance upon any other available legal bases); and
The right to lodge complaints regarding the Processing of your Relevant Personal
Data with a Data Protection Authority (in particular, the Data Protection Authority of
the EU Member State in which you live, or in which you work, or in which the
alleged infringement occurred, each if applicable).
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other
provision of this Privacy Policy, or about our Processing of your Personal Data, please use
the contact details provided in Section (R) below.
Please note thatwe may require proof of your identity before we can give effect to these
rights; and where your request requires the establishment of additional facts (e.g., a
determination of whether any Processing is non-compliant with applicable law) we will
investigate your request reasonably promptly, before deciding what action to take.
Security
Except as described above, we do not reveal information about you to third parties. We
restrict access to non-public personal information about you to those employees who need to
know that information to provide products or services to you. We maintain reasonable
physical, electronic, and procedural safeguards to guard your non-public personal
information. With respect to information given on the Internet, ExpertBridge India uses a
variety of proven protections to maintain the security of your online session. This may
include the use of firewall barriers, encryption techniques and authentication procedures.
Linked sites and other third parties
This Privacy Policy only addresses the use and disclosure of information we collect from
you. The Site, or services on the Site, may contain links to other sites whose information,
security, and privacy practices may be different than ours. You should consult the other sites’
privacy policies and terms of use since we do not control information that is submitted to, or
collected by, these third parties or the content of those linked sites. Once you access another
website, you are subject to the privacy policy and terms of use of that site.
Modifications
From time to time, we may modify this Privacy Policy. We will notify you about material
changes in the way we treat personally identifiable information by placing a notice on our
Site. We encourage you to periodically review our Privacy Policy so that you always will
know what information we collect, how we use it, and to whom we disclose it. However, we
will only use personally identifiable information in accordance with the Privacy Policy that
was in effect at the time the information was collected. If at any point we should decide to
use that information differently, we will notify users by way of e-mail so that users can
approve or disapprove of such use.
We may also share all individual investor information, under joint marketing agreements with
non-affiliated financial services business partners, in order to offer discounts or other special
access to products and services.