Data Privacy Notice
Introduction and who we are
This Notice describes how each of Titan Advisors, LLC, Saguenay Strathmore Capital, LLC, Titan Co GP, LLC and their affiliates (“Titan”, “we” or “us”) treat personal data collected on the websites and platforms where this Notice is located (each a “website”) in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws. Each website is operated by Titan.
Titan Advisors, LLC is the controller of your information. If you are applying for a job, the company to whom you are applying for a job is the data controller of your personal data.
This Notice does not apply to information that Titan collects other than through websites where it is posted (or provided through a link).
Information that Titan collects
Personal Data
When we refer to “personal data” we are referring to any information about a living individual from which they can be identified such as name, ID number, location data, any online identifier, or any factor specific to the physical, physiological, genetic, mental, economic or social identity of that person. It does not include data where any potential identifiers have been removed (anonymous data) or data held in an unstructured file.
There are “special categories” of more sensitive personal data which are more private in nature and therefore require a higher level of protection, such as genetic data, biometric data for identification purposes, information about sex life or sexual orientation, race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and health.
When we refer to “processing”, this means anything from collecting, using, storing, transferring, disclosing, altering or destroying personal data.
When you visit a website and when you communicate with us, Titan will collect certain personal data about you, such as your name, address, and email address as well as any other personal data that you may provide – for example, through submission of a resume.
In addition, Titan may also collect the following information about your visit(s) to our website(s):
- the IP address and domain name used (the IP address is a numerical identifier assigned either to your Internet service provider or directly to your computer);
- the type of browser and operating system you use; and
- the date, time and duration for which you visit a website, the number of times you have visited a website, and where you come from.
How Titan Uses Information That it Collects and the Legal Basis for Doing So
Titan uses information that it collects in the following ways:
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Purpose for Processing
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Legal Basis for Processing |
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To respond to your requests or questions. For example, Titan might use your information related to employment postings to contact you about current or future opportunities.
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In order to ensure the performance of a contract to which you are a party and to comply with our legal obligations and to pursue our legitimate interests of effectively managing our business operations.
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To inform you about Titan. Titan might send you information about itself, new features or updates about a Website, such as information about career opportunities. |
Your consent when it is required and to pursue our legitimate interests of effectively managing our business operations. |
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To communicate with you about your relationship with us. Titan may contact you about a variety of things, including your use of a website, your relationship with it or about this Notice. |
Your consent when it is required and in order to pursue our legitimate interests of effectively managing our business operations. |
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To improve a website and the services provided. Titan may use your information to try and improve or better customise a website or any services that we may provide in order to better suit your needs. |
In order to pursue our legitimate interests of effectively managing our business operations. |
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For security purposes. Titan may use information to enforce its rights, protect itself, its affiliates, customers or a website. |
In order to pursue our legitimate interests of effectively managing our business operations. |
In addition, Titan may use information as otherwise permitted by law or as we may notify you.
If you fail to provide certain information when requested, we may not be able to perform a contract we have entered into with you (such as providing services in return for payment), or we may be prevented from complying with our legal obligations.
If you wish to obtain further information on the legitimate interests relied on by Titan as a legal basis for processing your personal data, or the balancing test carried out in considering whether Titan may rely on such legitimate interests, please contact us using the information in the “Contact Information” section below.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Titan May Share Your Information in Limited Circumstances
Titan will share information with its employees who need to know such information for purposes of performing their jobs, including to respond to requests or questions that you may have. Titan may also transfer your personal data to other Titan group companies as permitted in this Notice and under applicable data privacy law for the legitimate interests of Titan and to ensure the effective operation of Titan’s business. You can ask for further information in relation to these group companies through the “Contact Information” section below.
In addition, Titan will share information with third parties such as government agencies and regulators (eg tax authorities), social insurance carriers, court and to government authorities for purposes of complying with legal requirements or to respond to legal requests, such as in the case of a court order or subpoena or in connection with a regulatory investigation. Finally, Titan might also share information that it collects with others when it is investigating potential fraud or for other reasons that may be disclosed to you or as permitted by law.
When we disclose your personal data to third parties, we only disclose to them any personal data that is necessary for them to provide their service and where we are sure that they have adequate policies/procedures in place in relation to data security. We have contracts in place with these third parties in receipt of your personal data requiring them to keep your personal data secure and not to use it other than in accordance with our specific instructions.
International Transfers
The personal data we collect from you may be used, stored or accessed by staff working for us, other members of our group or suppliers, operating in countries which are not within the European Economic Area (“EEA”), such as the United States, Canada and the Cayman Islands. If you are based in the EEA and we transfer any of your personal data to non-EEA entities, we will take appropriate measure to ensure the recipient provides an adequate level of protection for your personal data. To ensure that your personal data receives an adequate level of protection, we will put in place appropriate measures for any international transfers, as provided for under applicable data protection laws, in order to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects EU data protection laws.
Protection of Information
Titan is strongly committed to protecting any personal data collected through a website against unauthorised access, use or disclosure. Titan will not sell or otherwise disclose any personal data collected from a website, other than as described herein.
In addition, Titan has implemented procedures to safeguard the integrity of its information technology assets, including but not limited to, authentication, monitoring, auditing and encryption. These security procedures have been integrated into the design, implementation and day-to-day operations of a website as part of a continuing commitment to the security of electronic content as well as the electronic transmission of information.
Any personal data that Titan collects will be stored within the United States. If you live outside of the United States, Titan may transfer your information to the United States.
Retention of Information
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
For further information on the length of time in which we may retain your personal data, please contact us using the details contained below in the “Contact Information” section.
Your Rights
If you are located in the EEA, you have certain rights under data protection legislation as summarised below:
- Right of access: You have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, to request access to the personal data, as well as certain information on how we are processing such data.
- Right to rectification: You have the right to obtain from us the rectification of inaccurate personal data concerning you. Considering the purpose of the processing, you may also, in some cases, be entitled to supplemental information regarding incomplete personal data.
- Right to erasure (right to be forgotten): You may, in certain circumstances, have your personal data deleted, for example if your personal data is no longer necessary in relation to the purpose for which it was collected, if you have objected to the processing of personal data and we do not have a legitimate interest which outweighs your interest, if the personal data has been processed unlawfully, or if the personal data must be deleted to comply with a legal obligation.
- Right to restriction of processing: You may require that we restrict the processing of your personal data in certain cases, for example where we no longer need your personal data but you need it to determine, enforce or defend legal claims or you have objected to processing based on our legitimate interest in order to enable us to check if our interest overrides your interest.
- Right to data portability: In some circumstances, you may be entitled to receive the personal data concerning you which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit those personal data to another controller.
- Right to object: You have the right to object to the processing of your personal data in certain circumstances, for example where the processing is based on our legitimate interest. If so, in order to continue processing, we must be able to show compelling legitimate grounds that override your interests, rights and freedoms.
In any case where Titan is relying on consent to process your personal data, you have the right to change your mind and withdraw consent by contacting us using the information contained in the “Contact Information” section below.
Your rights will in each case be subject to the restrictions set out in applicable data protection laws. Further information on these rights, and the circumstances in which they may arise in connection with our processing of your personal data, can be obtained by contacting us using the details in the “Contact Information” section below. If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us using the details in the “Contact Information” section below.
Cookies and Tracking Tools
Titan does not currently collect personal data on its websites through the use of tracking tools, such as browser cookies. If this changes in the future, we will update this policy accordingly.
Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. Titan does not currently respond to those signals.
Children and Websites
Each website is meant for adults. Titan does not knowingly collect personally identifiable information from children under 16 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 16 has given information to Titan, please contact the address below.
Links to Other Sites or Third-Party Services
If a link to a third-party site is included on a website and you click on it, you will be taken to websites Titan does not control. This Notice does not apply to the privacy practices of that website. Read the privacy notice of other websites carefully. We are not responsible for these third party sites.
Disclaimer and Policy Updates
This Notice should not be construed as giving business, legal, or other advice, or warranting as fail-proof, the security of information provided through the website. The Internet is not 100% secure and Titan cannot promise that your use of a website or software will be completely safe. Titan disclaims any liability with respect to any information obtained by a third-party through illegal entry into or breach of a website.
Titan will notify you of any material changes to this Notice by posting an updated copy on the applicable websites. Please check the applicable website periodically for updates.
Contact Information
For questions regarding this privacy Notice, to avail of your data protection rights or for any other reason related to this privacy Notice, please contact us using the following information:
Titan Advisors LLC, 750 Washington Blvd, 10th Floor, Stamford, CT 06901, United States
Tel: +1(203) 327 8600
Email: compliance@titanadvisors.com and TitanIR@titanadvisors.com
If you are based in the EEA and you have any grievance, issue or problem in respect of our handling or processing of your personal data in any way, you have the right to lodge a complaint to your local supervisory authority.