Praexo Technology serving issuers (“Praexo”) is responsible for ensuring that it uses your personal data in compliance with data protection law. The purpose of this notice (the “Privacy Notice”) is to explain what personal data Praexo collects and how Praexo uses it.
For the purposes of data protection law, Praexo is a data controller in respect of your personal data. “Personal data” is any data that can be used to identify you or that Praexo can link to you and which Praexo has in its possession or control.
In this Privacy Notice when we refer to “Praexo” or “we”/“us”/“our” we mean Praexo and our Associates.
Personal data that Praexo collects
Praexo will collect and process the following personal data:
Information that you or someone acting on your behalf provides to Praexo.
This includes information about you that you give Praexo by filling in forms, answering to questionnaires or surveys on our website, signing up for services on our website or by communicating with Praexo, whether face-to-face, by phone, e-mail or otherwise.
Information Praexo collects or generates about you.
We will also collect information about you when you use our services or when we otherwise interact or correspond with you. We use various technologies to collect and store information when you visit our websites. We may, for example, collect information about the type of device you use to access the websites, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our websites, the web pages and the search terms you enter on our websites.
If you are a client, this information may include information about you, your transactions, financial information and relationship to others; and data that Praexo collects about your use of Praexo’s IT systems.
Information Praexo obtains from other sources.
If we collect or receive your personal data in the context of our provision of services, we might receive information from third parties such as other parties relevant to the services we are providing (e.g. counterparties in transactions), data suppliers such as Pitchbook Data, Inc. and Ipreo LLC, and others such as regulators and authorities. We may also obtain information from your employer’s website, and from your public profile on LinkedIn. That information could include your name, contact details, employment details and other information relevant to the services that we are providing to our client.
Uses of your personal data
Personal data may be stored and processed by Praexo in the following ways and for the following purposes:
provide, manage and improve the Website and our Services;
personalise our service to you;
administer and operate your account;
verify your identity (including for fraud prevention purposes), assess your ability to meet your financial commitments (if any) and manage Praexo’s relationship with you and/or the client to whom you are connected;
contact you in connection with your work with Praexo and the products and services that Praexo provides to you or a client to whom you are connected;
to perform the contract with you or a client/supplier to whom you are connected (including performing Praexo’s obligations and exercising Praexo’s rights);
process your requests ;
improve and enhance the Services and for other development, diagnostic and corrective purposes in connection with the services and other Praexo offering;
train machine learning algorithms and any other data processes deployed by Praexo;
convey feedback provided by you or in relation to you;
provide reports, analytics and benchmarking to you and other users of the Website and our services;
contact you about our products, services, service updates and alerts, offers which we think may be of interest to you and for market research purposes;
maintain a register of users or our services, and to allow our clients to send communications to you;
conduct research, analysis and risk management;
engage in marketing and business development activity and to advise you or a client to whom you are connected of other products and services similar to those which you or a client to whom you are connected receive from Praexo;
notify you about changes to Praexo’s service;
comply with Praexo’s legal and regulatory obligations. This includes reporting to the relevant authorities, complying with anti-money laundering obligations and tax reporting obligations;
use it to prevent and respond to actual and potential fraud or illegal activities; or
use it to look into any complaints or queries you or a client/supplier to whom you are connected may have.
Praexo is entitled to use personal data in these ways because:
Consent – we may (but usually do not) need your consent to use your personal data. You can withdraw your consent by contacting us (see below).
Performance of a contract – we may need to collect and use your personal data to enter into a contract with you or to perform our obligations under a contract with you or a client to whom you are connected.
Legitimate interest – we may use your personal data for our legitimate interests, some examples of which are given above.
Compliance with law or regulation – we may use your personal data as necessary to comply with applicable law/regulation.
Disclosure of personal data to third parties
Praexo may disclose personal data to its Associates in the circumstances described below:
to provide the services or perform its obligations in connection with your contract or the contract of a client/supplier with whom you are connected;
for the management and administration of the Praexo business;
for the management and administration of internal policies and procedures within Praexo.
Where personal data is disclosed to its Associates, Praexo will take steps to ensure that the personal data is accessed only by those persons who need to do so for the purposes described in this Privacy Notice.
Praexo may also disclose personal data outside of Praexo and its Associates, as follows:
to third party agents, service providers or contractors, bound by obligations of confidentiality, who will only use personal data on Praexo’s behalf for the purposes described in this Privacy Notice;
to third parties relevant to the services outlined in the contract with you or the contract of a client/supplier with whom you are connected. This may include for example counterparties to transactions, professional advisers, stock exchanges or regulators;
to the extent required by law, regulation or court order for example if Praexo is under a duty to disclose personal data in order to comply with any legal or regulatory obligation; and
in order to establish, exercise or defend Praexo’s legal rights, for example if Praexo needs to obtain external legal advice or provide personal data in connection with judicial proceedings.
Storage and Security
The data that we collect from you is stored within the European Economic Area (“EEA”), and will be accessed by our staff in EEA and in the United Kingdom. Such staff may be engaged in, among other things, the provision of support services.
Where we have provided you (or where you have chosen) a password that enables you to access certain parts of the Website or our services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Please remain guarded against phishing emails. Phishing is a method used by fraudsters to deceive someone into giving sensitive information. Most of the time, phishing will take the form of emails, which purport to be from well-known companies and ask recipients to send their private information. This information is then used for identity theft and fraud. We will never ask you for your account password. If you have any suspicions or doubts whether any email or communication that purports to come from us is genuine or not, please check with us first.
Transfers of personal data outside the European Economic Area
Personal data may be transferred to, and stored at, a destination outside the UK or the EEA. It may also be stored and processed by staff operating outside of the UK or the EEA, who work for Praexo’s Associates or Praexo’s third party agents, service providers or contractors.
Where Praexo transfers personal data outside the UK or the EEA, Praexo will ensure that it is protected in a manner that is consistent with how personal data will be protected by Praexo in the UK and the EEA. This may be achieved in one of the following ways:
the country that Praexo sends the data to might be approved by the European Commission or by a relevant data protection authority; or
the recipient might have signed a contract based on “model contractual clauses” approved by the European Commission or by a relevant data protection authority, obliging them to protect the personal data that they receive.
In other circumstances the law may permit Praexo to otherwise transfer personal data outside the UK or the EEA. In all cases, however, Praexo will ensure that any transfer of personal data is compliant with applicable data protection law.
Retention of personal data
How long Praexo holds personal data for will vary. The retention period will be determined by various criteria including:
the purpose for which Praexo is using it – Praexo 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 Praexo has to retain personal data.
To determine the appropriate retention period for 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.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you
Rights in relation to personal data
You have a number of legal rights in relation to the personal data that Praexo holds about you. These rights include:
The right to access – You have the right to request Praexo for copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that Praexo corrects any information you believe is inaccurate. You also have the right to request Praexo to complete the information you believe is incomplete.
The right to erasure – You have the right to request that Praexo erases your personal data, under certain conditions.
The right to restrict processing – You have the right to request that Praexo restricts the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to Praexo ‘s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that Praexo transfers the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you.
You can exercise your rights by contacting Praexo using the details set out in the “Contacting Praexo” section below.
If you would like further information about Praexo’s processing of your personal data or the exercise of any of the rights referred to above, please address questions, comments and requests to firstname.lastname@example.org.