Privacy Policy | IR & Marketing Solutions 

 MJ Hudson Meyler provides investor relations and marketing solutions including perception studies, advice in relation to fundraising and marketing materials, branding and communications to support Fund Managers and other clients (IR & Marketing Solutions).

The kind of information we hold about you

If you engage us to provide IR & Marketing Solutions to you, we may collect, store, and use the following categories of personal data about you:

a)     name;

b)     business postal address;

c)      business email address;

d)     telephone number;

e)     date of birth/age;

f)      job title;

g)     company;

h)     corporate bank details;

i)       whether you are a politically exposed persons;

j)       whether you are on a sanctioned or watch list;

k)     other information about you which you may provide to us in the course of us providing IR & Marketing Solutions. 

In certain circumstances, the information we hold about you may include special category data (as defined in the GDPR), including data which reveals your ethnicity, your political opinions, your health or your criminal convictions

How your data is collected

We collect your data from the following sources:

a)     directly from you during our client inception and on-boarding process and our ongoing client relationship;

b)     background check providers, from which we collect the following categories of data:

i.         whether you are on a sanctioned or watch list;

ii.        details of criminal convictions; and

iii.       whether you are a politically exposed persons

c)      publicly available sources such as electronic databases and lists.

What we use your data for

We use your data for the following purposes:

a)     in order to provide IR & Marketing Solutions pursuant to our contract with you;

b)     in order to provide marketing communications to you (but only where we have obtained your consent to do so).  Please see here for further details of how we use your data for marketing purposes; and

c)      for our legitimate business interests such as for internal record keeping purposes or to manage our client relationship with you.

Any special category data we hold about you will only be processed so far as necessary in order to comply with our legal requirements.

Who we share your data with

  1. We will never sell your data and we will only disclose your data to other parties where necessary in order to provide our services or where we are legally obliged to do so.  Details of the organisations we may share your data with are set out below:

  2. MJ Hudson Group Companies

    We may share your data with other members of MJ Hudson for the purposes set out in this Policy.  All members of MJ Hudson will process your data in accordance with this privacy policy and subject to the requirements of Applicable Local Laws or the GDPR, as applicable.

  3. Third party service providers

    We use carefully selected third parties to provide certain services to us, such as our IT Infrastructure or document management systems. By the nature of the service they provide, some such third party service providers may have limited access to your data for support purposes.  All of our service providers have entered or will shortly enter into contracts which contain strict confidentiality and data processing provisions.  A full list of all of the third party service providers we use is available on request.

  4. Auditors

    We may need to share limited information regarding our clients with our auditors, including, in some instances, your data. Our auditors are subject to strict confidentiality provisions in their contract with us.

  5. Regulatory Bodies/Government Agencies

    We may disclose your data to certain regulatory bodies or government agencies where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your data where such disclosure is necessary for the establishment, exercise or defence of legal claims.

In relation to any other categories of recipients not listed above, we will only disclose your information in the following circumstances:

i.  where you have given your consent;

ii.  where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights; and

iii.  if we sell our company, go out of business, or merge with another company.

International Transfers

In certain circumstances, we may transfer your data to countries outside the EEA, which may not adhere to the same levels of data protection to which countries within the EEA are subject.  Any such transfers are, at all times, made in accordance with the Applicable Local Laws and the GDPR.  Details of the circumstances and mechanisms in place to ensure compliance are set out below:

  1. MJ Hudson Group Companies in the Channel Islands, Switzerland, Canada and the USA.

    We have offices in Jersey, Guernsey and Switzerland.  Our central servers are located in London. The European Commission has ruled that Jersey, Guernsey and Switzerland offer adequate levels of data protection in their domestic legislation and transfers to these jurisdictions are, therefore, permitted under the GDPR and/or Applicable Local Laws.

    We also have operations in the USA and Canada, we have put in place our Group Standard Contractual Clauses between us and our American and Canadian employees to safeguard EU data subject’s rights under the GDPR.  All personal data used by staff in these locations is held on MJ Hudson’s central servers located in London. Emails are stored within London based Microsoft servers. 

  2. Your other advisors

    In some instances, you may have instructed other advisors or service providers who are based outside the EEA and who we need to share information with, in order to provide our services to you. In these circumstances, we ensure that any personal data transferred is limited to that which is required for us to perform our contract with you and the transfer is made in accordance with the GDPR and/or Applicable Local Laws.

  3. SurveyMonkey in the United States

    We use SurveyMonkey to carry out our online surveys.  SurveyMonkey stores survey data on its servers in the United States.  If you participate in one of our surveys, your personal data will be transferred to the United States.  SurveyMonkey Inc. (and its subsidiary company, Infinity Box Inc.) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework.  Transfers of Personal Data to SurveyMonkey in the United States are therefore made subject to appropriate safeguards in accordance with the GDPR and Applicable Local Laws. We have also put in place a Data Processing Agreement based on the Standard Contractual Clauses approved by the European Commission to provide enhanced protection for Your data. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield website: https://www.privacyshield.gov/welcome.  SurveyMonkey’s privacy policy can be viewed here.

    We may also transfer your data to such other service providers as may be necessary for the execution of the work you have contracted us to perform. In these circumstances, we ensure that any personal data transferred is limited to that which is required for us to perform our contract with you and the transfer is made in accordance with the GDPR and/or Applicable Local Laws.

  4. DocSend

    We use DocSend to send and store some of our documents and this may include your data. DocSend is operated in the United States.  DocSend participates in and has certified its compliance with both the EU-U.S. and the Swiss-U.S Privacy Shield Framework.  Transfers of Personal Data to DocSend in the United States are therefore made subject to appropriate safeguards in accordance with the Applicable Local Laws and the GDPR. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield website: https://www.privacyshield.gov/welcome. 

DocSend’s privacy policy can be viewed here.