1 Information we may collect about you
1.1 Appian is an investment advisor to third party funds. As such it receives limited personal information relating to the investors in those third party funds (the fund administrator dealing with know your client and anti-money laundering checks and administration of the investors’ holdings and other rights, although exceptionally such information may be provided to Appian). Appian collects information about individuals in the following circumstances (although this list is not exhaustive):
(a) where you seek to be employed by Appian, Appian will collect your contact details, details about your previous employment, references and the output of background checks (such as criminal records checks) where appropriate;
(b) where you are an employee or contractor of a service provider to Appian, Appian will collect your contact details and any other information necessary to administer the sale or delivery of such services;
(c) where you are an employee or a contractor of a third party fund that Appian provides services to, Appian will collect your contact details and any other information necessary to administer the sale or delivery of such services; and
(d) where you are an employee or a contractor of a business that Appian is evaluating for investment purposes, Appian may collect your contact details, references and the output of background checks (such as criminal records checks) where appropriate.
1.2 The Appian website does not collect information about you and does not deploy cookies or other tracking technologies.
2 Uses made of your personal information
2.1 We may use your personal information in the following ways:
(a) to decide whether to recommend investment into the business that you work for or to enter into any proposed agreement with you or the business that you work for including, in certain circumstances, disclosing such information to third party anti-fraud and money laundering agencies for the purposes of detecting and preventing fraud and crime (as further set out in paragraph 3 below);
(b) to identify you and to carry out any identity checks as may be required by applicable law and regulation and best practice at any given time;
(c) to recover any payments due to us and where necessary to enforce such recovery through the engagement of debt collection agencies or taking other legal action (including the commencement and carrying out of legal and court proceedings);
(d) to analyse it in order to understand the service we provide and in order to improve our business;
(e) to monitor calls and transactions to ensure service quality, compliance with procedures and to combat fraud; and/or
(f) to notify you about changes to our services and products.
2.2 We may also use your information for marketing our own and selected third parties' products and services to you by post, email, SMS, phone and fax and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing.
2.3 We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in paragraph 5.4 below.
3 Disclosures to third parties
3.1 We may also permit selected third parties and agents to use your personal information, for the purposes set out in paragraph 2 above who will be subject to obligations to process such information in compliance with the same safeguards that we deploy. Specific examples are set out in paragraphs 3.2 to 3.6 below. All such disclosures will only be made in accordance with applicable laws.
3.2 If false or inaccurate information is provided and/or fraud is identified or suspected, details may be passed to fraud prevention and anti-money laundering agencies, law enforcement agencies or other investors and may be recorded by us or by them.
3.3 We and other organisations may also access and use this information to prevent fraud and other crime, for example when:
(a) evaluating an investment decision;
(b) taking steps to recover payments due (as outlined in paragraph 2 above); and
(c) checking details of job applicants and employees.
3.4 We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or in order to enable us to comply with its regulatory requirements or dialogue with its regulators as applicable.
3.5 In the event that we buy or sell any business or Assets, or Appian undergoes a re-organisation, you agree that any of your personal information which it holds may be disclosed to such party (or its advisors) as part of any due diligence process or transferred to that re-organised entity or third party and used for the same purposes or for the purpose of analysing any proposed sale or re-organisation.
4 Transmission, storage and security of your personal information
4.1 No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with applicable data protection legislative requirements.
4.2 All your information is stored on our secure servers (or secure hard copies) and accessed and used subject to our security policies and standards.
4.3 Your personal information may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the European Economic Area (EEA) in which data protection laws may be of a lower standard than in the EEA. Regardless of location or whether the person is an employee or contractor we will impose the same data protection safeguards that we deploy inside the EEA and only export such personal information in accordance with UK data protection laws.
4.4 We will retain your personal information for as long as is necessary for the processing purpose for which they were collected. Certain correspondence may be retained in order to comply with regulatory requirements regarding the retention of such data. Information may also be retained for or included in analysis carried out by Appian with respect to its own business.
5 Your rights & contacting us
5.1 Applicable data protection laws may give you the right to access certain personal information held about you. We will comply with our obligations to provide you with access to this personal information we hold about you and to rectify any inaccuracies we are informed of in accordance with applicable data protection laws. Where permitted to do so, complying with your request may be subject to a fee as permitted by law.