General Privacy Policy
1. Protection of your Personal Information: The personal information you provide to Bevshaw Trust. when applying for a position (e.g., resume, certificates, test scores) will be processed exclusively for recruiting and employment purposes. Please do not send sensitive data, as may be defined by your country’s laws (e.g., personal information regarding race, ethnic origin, religion, sexual orientation, political opinions, etc.). The personal information collected for recruiting purposes will be transferred to our U.S. headquarters and may be shared with our affiliates as permitted by law. Companies that are not related to Bevshaw Trust. that perform services on our behalf, such as a third parties that process application information, may have access to your information. When this occurs, Bevshaw Trust. requires the companies to treat your information confidentially. You can have general access to this Site and browse pages without providing personal information about yourself. Bevshaw Trust. may record when you log-on to the Site and the pages you visit. Bevshaw Trust. does not disclose any personal information relating to your activities on the Site, other than to our affiliates, except as permitted by law. Companies that are not related to Bevshaw Trust. that perform services on our behalf, such as a third party that hosts our Site, may have access to your information relating to your activities on the Site. When this occurs, Bevshaw Trust. requires the companies to treat your information confidentially. Bevshaw Trust. does not share any information concerning you or your website usage with third-party tracking services and does not respond to "do not track" signals. See Section II of this Privacy Policy for more information on processing your personal data.
2. Disclosure to other parties: We may share your personal information with our affiliates. We may also share your personal information if compelled to do so pursuant to a subpoena or applicable law, regulation, rule or legal process of a court of law, regulatory authority or other governmental body.
3. Cookies: Like many websites, Bevshaw Trust. may use cookies, which may automatically collect certain non-personal information and data. A cookie is a piece of data stored on a user’s hard drive containing information about a user’s use of a website. As explained below, we may use one or more of the following types of cookies in order to make the Site work, or work more efficiently, as well as to provide information to us:
‘Session based’ cookie. This is essential for parts of the Site to operate and has already been set. It is used to maintain the state of a user’s actions so as not to constantly request the same information from them within a ‘session’.
‘Remember me’ cookie. This is a permanent cookie which can remember who you are once you have logged into the Site so you are not asked to log in again for future visits.
By using this Site you consent to the use of cookies for these purpose.
4. Prohibited Conduct: You warrant and agree that, while accessing or using the Site, you shall not: (a) obtain or attempt to gain unauthorized access to other computer systems, materials, information or any services available on or through the Site through any means, including through means not intentionally made publicly available or provided for through the Site; (b) engage in spidering, “screen scraping,” “database scraping,” or any other automatic or unauthorized means of accessing, logging-in or registering on the Site, or obtaining lists of users or other information from or through the Site, including any information residing on any server or database connected to the Site; (c) use the Site in any manner that could interrupt, damage, disable, overburden or impair the Site or interfere with any other party's use and enjoyment of the Site, including sending mass unsolicited messages or “flooding” servers with requests; (d) use the Site in violation of Bevshaw Trust.'s or any third party's intellectual property or other proprietary or legal rights; (e) use the Site in violation of any applicable law or the Terms; (f) attempt (or encourage or support any one else's attempt) to circumvent, reverse engineer, decrypt, or otherwise alter or interfere with the Site or its services; or (g) delete any Content on the Site.
5. Linking to the Site: You agree not to link directly to any image, graphic, text or other Content on the Site, such as using an “in-line” linking method to cause the Content to be displayed on another website, unless expressly permitted by us in writing. You agree not to download or use images hosted on this Site for any purpose, including posting such images on another website, unless expressly permitted by us in writing. You agree not to link from any other website to this Site in any manner such that the Site, or any page of the Site, is “framed,” surrounded or obfuscated by any third party content, materials, advertising or branding. We may require that any link to the Site be discontinued, and/or revoke your right and ability to link to the Site from any website at any time.
6. Third Party Websites: If there are any links from the Site to third party websites or any third party websites link to the Site (“Linked Sites”), such links do not constitute an endorsement or sponsorship by us of such sites or any of the contents of Linked Sites and we have no responsibility whatsoever for anything on Linked Sites. Any use of or reliance on a Linked Site is done at your own risk and you assume all responsibilities and consequences resulting from such use or reliance.
7. DISCLAIMER OF WARRANTIES: THE SITE IS PROVIDED “AS IS,” “AS AVAILABLE”, WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING ANY WARRANTIES OF TITLE, NON-INFRINGEMENT, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE, OR WARRANTIES ARISING FROM COURSE OF DEALING OR USAGE OF TRADE AND WE HEREBY DISCLAIM ANY AND ALL SUCH WARRANTIES. WE DO NOT WARRANT THAT THE SITE WILL BE TIMELY, SECURE, UNINTERRUPTED, COMPLETE OR ERROR FREE OR WILL MEET USERS' REQUIREMENTS, OR THAT DEFECTS WILL BE CORRECTED. NO RESULTS OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM US OR THROUGH THE SITE SHALL CREATE ANY WARRANTY NOT EXPRESSLY MADE HEREIN. Bevshaw Trust. ALSO ASSUMES NO RESPONSIBILITY, AND SHALL NOT BE LIABLE FOR, ANY DAMAGES TO, OR VIRUSES THAT MAY INFECT, YOUR COMPUTER EQUIPMENT OR OTHER PROPERTY ON ACCOUNT OF YOUR ACCESS TO, USE OF, OR BROWSING IN THE SITE OR YOUR DOWNLOADING OF ANY MATERIALS, DATA, TEXT, IMAGES, VIDEO, AUDIO OR OTHER CONTENT FROM THE SITE.
8. LIMITATION OF LIABILITY: IN NO EVENT WHATSOEVER SHALL WE, OUR AFFILIATES, OUR CLIENTS OR ANY OF OUR OR THEIR DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, CONTRACTORS, SUPPLIERS OR LICENSORS (ALL THE FOREGOING COLLECTIVELY, THE “PROTECTED PERSONS”) BE LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES INCLUDING LOST BUSINESS, SALES, SAVINGS OR PROFIT (WHETHER IN CONTRACT OR TORT, INCLUDING NEGLIGENCE OR OTHERWISE), IN EACH CASE, ARISING FROM, OR DIRECTLY OR INDIRECTLY RELATED TO, YOUR ACCESS TO OR USE OF, OR THE INABILITY TO ACCESS OR USE, THE SITE OR THE CONTENT, MATERIALS AND FUNCTIONS RELATED THERETO, EVEN IF SUCH PROTECTED PERSON HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. SOME JURISDICTIONS DO NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY FOR CERTAIN TYPES OF DAMAGES SO SOME OF THE ABOVE LIMITATIONS MAY NOT APPLY TO CERTAIN USERS. THE PARTIES ACKNOWLEDGE THAT THE LIMITATIONS OF LIABILITY SET FORTH ABOVE ARE TO SURVIVE AND REMAIN IN FORCE NOTWITHSTANDING ANY REMEDY’S FAILURE OF ITS ESSENTIAL PURPOSE
9. Contacting the Site: If you have any questions relating to the Site, or if you would like to submit a complaint or other report to us, please contact us at: legal@bevshaw.com.com.
10. Collection and Processing of Personal Data
This section of the Privacy Policy explains how we use the personal information that Bevshaw Trust. collects or generates both in relation to this website and our products and services.
The list below sets out what is covered in this section of the Privacy Policy.
- BACKGROUND
- THE PRODUCTS AND SERVICES WE PROVIDE
- THE TYPES OF PERSONAL DATA WE COLLECT
- HOW WE USE YOUR INFORMATION
- DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
- INTERNATIONAL TRANSFERS OF PERSONAL DATA
- HOW WE SAFEGUARD YOUR INFORMATION
- HOW LONG WE KEEP YOUR PERSONAL DATA
- YOUR RIGHTS
- DESIGNATED REPRESENTATIVE
- QUESTIONS AND CONCERNS
- BACKGROUND
- Bevshaw Trust. and other companies in the Bevshaw Trust. group collect and use certain Personal Data. Bevshaw Trust. is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.
- At Bevshaw Trust. we respect the privacy of our clients and we are committed to keeping all your Personal Data secure. This Privacy Policy governs the handling of Personal Data by Bevshaw Trust. in the course of carrying on commercial activities.
- We use the following definitions in this Privacy Policy:
- “Bevshaw Trust.”, “we” or “us” means Bevshaw Trust. and other companies in the Bevshaw Trust. group.
“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Bevshaw Trust. (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Bevshaw Trust. or any other person in respect of an individual.
- THE PRODUCTS AND SERVICES WE PROVIDE
- This Privacy Policy concerns the following categories of information that we collect about you when providing the following products and services:
- Information we receive through our websites ("Bevshaw Trust. Websites");
- Information we receive through the course of providing our investment management services and offering funds managed by Bevshaw Trust. (such services and funds being “Bevshaw Trust. Products");
- Information we receive through our support, mobile security solution or cloud-based services ("Bevshaw Trust. Services").
- This Privacy Policy concerns the following categories of information that we collect about you when providing the following products and services:
- THE TYPES OF PERSONAL DATA WE COLLECT
- Many of the services offered by Bevshaw Trust. require us to obtain Personal Data about you in order to perform the services we have been engaged to provide. In relation to each of the services described at paragraph 2.1 above, we will collect and process the following Personal Data about you:
- Information that you provide to Bevshaw Trust.. This includes information about you that you provide to us, including information that you send to us via emails which are subsequently collected and stored in BAM systems. The nature of the services you are requesting will determine the kind of Personal Data we request from you. Information you provide to Bevshaw Trust. may include (by way of a non-exhaustive list):
- basic Personal Data (such as first name; family name; position in your company; your company name; email address; business phone number; business address; city; postcode; country);
- if provided by you via a Bevshaw Trust. Website for recruiting or employment purposes, Personal Data regarding your candidacy for employment, including but not limited to your resume/CV, certifications, and test scores;
- any information that you choose to share on Bevshaw Trust. internet forums and portals, such as our Investor Portal or administrative sections of the website, which may be considered Personal Data.
- Information that we collect or generate about you. This includes (by way of 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 services which we have provided to you, or to assist us in providing you with the Bevshaw Trust. Products;
- if you create a user account with respect to the Bevshaw Trust. Websites, either for administrative purposes or via our Investor Portal, information regarding your account, such as your user name and ip address and what pages you visit;
- through our cloud security services, traffic and security reports that include information on the internet usage of the organisation’s computer users (e.g. what websites were visited by each user, any documents downloaded, security incidents, prevention measures taken by the gateway, etc.); and
- for users accessing the administrative section of the Bevshaw Trust. Websites, activity data relating to the use of protected documents, such as altering a document’s permissions and information regarding the individual that performed the activity.
- Cookies.
- When you visit Bevshaw Trust. Websites, cookies are used to collect technical information about the services that you use, and how you use them.
- Please see Section I.10 of this Privacy Policy for more information regarding Bevshaw Trust.’s use of cookies.
- Anonymized data
- In addition to the categories of Personal Data described above, Bevshaw Trust. will also process further anonymized information and data that is not processed by reference to a specific individual.
- Information that you provide to Bevshaw Trust.. This includes information about you that you provide to us, including information that you send to us via emails which are subsequently collected and stored in BAM systems. The nature of the services you are requesting will determine the kind of Personal Data we request from you. Information you provide to Bevshaw Trust. may include (by way of a non-exhaustive list):
- Many of the services offered by Bevshaw Trust. require us to obtain Personal Data about you in order to perform the services we have been engaged to provide. In relation to each of the services described at paragraph 2.1 above, we will collect and process the following Personal Data about you:
- HOW WE USE YOUR INFORMATION
- Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
- for ongoing review and improvement of the information provided on Bevshaw Trust. Websites to ensure they are user friendly and to prevent any potential disruptions or cyber attacks;
- to allow you to use the Bevshaw Trust. Products;
- to assess your subscription agreement for Bevshaw Trust. Products, where applicable;
- to set up users to use the Investor Portal;
- to set up users to access the administrative portion of the Bevshaw Trust. Websites;
- to conduct analysis required to detect malicious data and understand how this may affect your IT system;
- for statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
- to understand feedback on Bevshaw Trust. Products and to help provide more information on the use of those products and services quickly and easily;
- to communicate with you in order to provide you with services or information about Bevshaw Trust. and Bevshaw Trust. Products;
- for in-depth threat analysis;
- to understand your needs and interests;
- for the management and administration of our business;
- for recruiting or employment purposes;
- in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
- for the administration and maintenance of databases storing Personal Data.
- However we use Personal Data we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons. These include:
- we need to do so in order to perform our contractual obligations with our customers;
- we have obtained your consent;
- we have legal and regulatory obligations that we have to discharge;
- we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
- the use of your Personal Data as described is necessary for our legitimate business interests, such as:
- allowing us to effectively and efficiently manage and administer the operation of our business;
- maintaining compliance with internal policies and procedures;
- monitoring the use of our copyrighted materials;
- enabling quick and easy access to information on Bevshaw Trust. Products;
- offering optimal, up-to-date security solutions for mobile devices and IT systems; and
- obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market.
- We will take steps to ensure that the Personal Data is accessed only by employees of Bevshaw Trust. that have a need to do so for the purposes described in this Privacy Policy.
- Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
- DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
- We may share your Personal Data within the Bevshaw Trust. group of companies for the purposes described above.
- We may also share your Personal Data outside of the Bevshaw Trust. group for the following purposes:
- with our business partners. For example, this could include our partners to whom you or your company or your organisation submit your subscription for Bevshaw Trust. Product(s). Personal Data will only be transferred to a business partner who is 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, Bevshaw Trust.’s accountants, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations and they will 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 (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;
- if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
- if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer.
- INTERNATIONAL TRANSFERS OF PERSONAL DATA
- Bevshaw Trust. is a Trust business. Our customers and our operations are spread around the world. As a result we collect and transfer Personal Data on a Trust basis. That means that we may transfer your Personal Data to locations outside of your country.
- Personal Data collected for recruiting or employment purposes, regardless of where collected, may be transferred to our U.S. headquarters and may be transferred outside of the EEA (or your home country, if not in the EEA) to our affiliates or third parties that process application information for the purposes described above. When this occurs, Bevshaw Trust. requires such companies to treat your information confidentially.
- Where you are in the EEA and we transfer your Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe, for example, 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, it might be a certified member of the EU-US Privacy Shield scheme; or
- in other circumstances the law may permit us to otherwise transfer your Personal Data outside Europe.
- If you are in the EEA, you can obtain more details of the protection given to your Personal Data when it is transferred outside Europe by contacting us as described in paragraph 11 below.
- HOW WE SAFEGUARD YOUR INFORMATION
- We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where particularly sensitive Personal Data (for example, resumes/CVs submitted for recruiting purposes) is gathered, processed or stored is limited to authorised employees.
- Bevshaw Trust. employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by a Bevshaw Trust. employee is prohibited and may result in disciplinary measures.
- When you contact a Bevshaw Trust. 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.
- 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 for which we are using it – Bevshaw Trust. will need to keep the data for as long as is necessary for that purpose; and
- legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
- How long we will hold your Personal Data for will vary and will be determined by the following criteria:
- EEA DATA SUBJECTS: YOUR RIGHTS
- In all the above cases in which we collect, use or store your Personal Data and you are in the EEA, 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. For example, we may need to retain Personal Data to comply with a legal obligation;
- 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 those 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 Bevshaw Trust.;
- 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; 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 in paragraph 11 below.
- In all the above cases in which we collect, use or store your Personal Data and you are in the EEA, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
- QUESTIONS AND CONCERNS
- If you have any questions or concerns about Bevshaw Trust.’s handling of your Personal Data, or about this Policy, please contact our EU designated representative using the contact information above.
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our designated representative, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, Bevshaw Trust.'s designated representative will provide you with the contact information for that regulator.