In the ordinary course of business, Moelis Asset Management, and all of its affiliates (“Moelis”) collect, use, and share personal information pertaining to its partners, employees, investors, and others. Obtaining this information is important to our ability to conduct our operations and to deliver the highest level of service, but we also recognize that you expect us to treat this information appropriately.
This policy describes the types of personal information that a relevant Moelis entity may collect about you in compliance with applicable legal and regulatory requirements, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy.
HOW WE COLLECT INFORMATION ABOUT YOU
There are parts of this Site where we may need to collect personal information from you for a specific purpose, such as to provide you with certain information you request. If you voluntarily submit information to our Site (for example, in a request for general information or through the submission of a business proposal), we may record and use any personally identifiable information, such as your name, phone number, fax number and e-mail address, for reasonable business purposes including, but not limited to, fulfilling your request and marketing and business communications and you expressly agree with the collection, use, storage and handling of your personal information as set out in these terms. If you do not provide all the information we need, we may not be able to give you the information you request.
When you contact us by email or phone about or in relation to our services or to respond to our communications we may record and use the personal information you provide, such as your name, title, telephone number, email address and content, date and time of your email correspondence and information about your employer or your business.
Please also note we may have responsibilities under certain rules and regulations, to verify the identity of individuals and may need to make certain inquiries and obtain certain information from you for that purpose. You confirm that all information you supply will be accurate and that we may disclose such information as we consider necessary to comply with any reporting or legal and regulatory requirements.
What are cookies?
Cookies are small text files that are stored in your computer’s memory and hard drive, in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website, or other third parties who receive data obtained from that website.
When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience.
- Analytical purposes: Analytical cookies allow us to recognize measure and track visitors to our Site and compile a record of this usage information. This helps us to improve and develop the way our Site works, for example, by determining whether visitors to the Site can find information easily, or by identifying the aspects of Site that are of the most interest to them.
Your cookie preferences
Cookies are necessary in order for you to be able to make full use of our Site. If you chose to disable cookies, some of our Site’s functionality might be impaired.
Third party cookies
For more information about how Google Analytics collects and processes your data, please visit www.google.com/policies/privacy/partners.
Amending cookie preferences
The site www.allaboutcookies.org includes instructions for managing cookies on many commonly used browsers, or you may consult the vendor documentation for your specific software.
USES OF COLLECTED INFORMATION
The principal purposes for which we process and store your personal information are, or may in the future be:
- to monitor, improve and administer the Site and the information and services provided on the Site;
- to provide you with information on selected services that you request;
- for the management and administration of our business;
- in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
- to set you up as an investor;
- to provide you with our services;
- to understand feedback on our services 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 Moelis and our products and services; or
- to understand your needs and interests.
However we use personal information we make sure that the usage complies with applicable law and the law allows us and requires us to use personal information for a variety of reasons. These include where:
- we need to do so in order to perform our contractual obligations with our investors;
- 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; or
- the use of your personal information as described is necessary for our legitimate business interests, such as (i) allowing us to effectively and efficiently manage and administer the operation of our business; (ii) maintaining compliance with internal policies and procedures; and/or (iii) promoting our business and services.
DISCLOSURES OF YOUR PERSONAL INFORMATION WITHIN MOELIS
In order to provide efficient and reliable services and to improve service options available to you, we may share your personal information with our subsidiaries or affiliates. We have taken certain measures outlined below to try to ensure the security of your information.
DISCLOSURES OF YOUR PERSONAL INFORMATION TO THIRD PARTIES
We may share your personal information with other companies we have hired to provide services for us. These companies – our vendors – are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only on our behalf for the purposes that Moelis has hired them and for which it has instructed them. These service proviers may transfer the information you provide outside your country to a contractor in another country that does not have similar data protection legislation and may provide a lower level of protection for your information. By submitting any information you consent to these transfers.
We may also release information about you if you direct us to do so, or if we are required or authorized by law to make disclosures to the government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding, or to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities.
Where you have provided personal information to us, you expressly consent to the sharing of such personal information with third parties for the purposes set out in this section.
SECURITY OF COLLECTED INFORMATION
We use reasonable efforts to maintain physical, electronic, and administrative safeguards to protect your personal information from unauthorized or inappropriate access but we note that the Internet is not a secure medium. We restrict access to information about you to those Moelis personnel who need to know the information to respond to your inquiry or request.
Although Moelis endeavors to take steps to provide a secure environment for users accessing the Site, due to the nature of the Internet, Moelis cannot guarantee confidentiality or security of the personal and other information being provided. Moelis makes no warranty whatsoever to you, express or implied, regarding the security of the Site, including with respect to the ability of unauthorized persons to intercept or access information transmitted by you through the Internet.
Moelis welcomes your e-mail correspondence. However, it is possible that information transmitted to Moelis may be read or obtained by other parties. Messages sent over the Internet cannot be guaranteed to be completely secure or error free as they are subject to possible interception, corruption, delay, loss or possible alteration. Moelis is not responsible for them and will not be liable to you or anyone else for any damages or otherwise in connection with any messages sent by you to Moelis or any message sent by Moelis to you over the Internet. If you send e-mail (encrypted or not) to Moelis over the Internet, you are accepting the associated risks, including lack of confidentiality.
Further, despite all possible security measures that Moelis would take to keep this Site free from hacking and other interference, this Site like any other website is not free from such risks. Moelis disclaims all liability on account of any loss or damage that any user may suffer or incur on account of any alteration or manipulation of any data or information accessed or downloaded from this Site.
Whilst Moelis endeavors to take every reasonable precaution to ensure accuracy, security and confidentiality of information available through / on the Site, Moelis cannot be held responsible for any consequence of any action(s) carried out by any authorized or unauthorized user.
EU PRIVACY NOTICE
For the purposes of this section of the policy “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 any Moelis entity based in Europe (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 Moelis or any other person in respect of an individual.
Disclosure of your Personal Data outside of the US
If we transfer your Personal Data to another country outside the European Economic Area (“EEA”), we will ensure that it is protected and transferred in a manner consistent with legal requirements. We will protect the Personal Data being transferred outside of the EEA 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.
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 – Moelis 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.
If you are an EU-based individual, in all the above cases in which we collect, use or store your Personal Data, 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 Moelis;
- 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 below.
If you have any questions about Moelis’ handling of your personal information (including Personal Data), or about this policy, or if you wish to access your personal information, request its deletion or make a complaint about the way we have collected, used, held or disclosed your personal information, please contact us at 917-719-5700 or firstname.lastname@example.org.
If you are not satisfied with the response you receive from us, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, Moelis will provide you with the contact information for that regulator. We welcome your questions and suggestions about our Privacy and Cookies Policy.