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Privacy Policy

Effective Date: 13 February 2023

Last updated: 31  May 2023

1. Introduction

The protection and security of your personal data are important to Hartree Partners (“Hartree Partners”, “we” or “us”). The purpose of this Privacy Policy is to outline how we deal with any personal data when you visit this website (“https://www.hartreepartners.com/”) (“Website”) or conduct business with us and tell you about your privacy rights.

Our Website has been developed and is operated by Hartree Partners, LP of 1185 Avenue of the Americas, New York, NY 10036, United States of America who is the controller of your personal data processed in connection with our Website.

Please read this Privacy Policy to understand how we may process your personal data provided via our Website, as our existing or potential customer, and as our service provider or a business counterparty.

2. Types of Information Collected

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

a) Our Website:

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Contact Data includes name, address, email address and telephone number.
  • Employment Data includes the company you work for and job title.
  • Transaction Data includes details about products or services your request from us.
  • Technical Data includes information about how you use our website, internet protocol (IP) address, browser type and version, time zone setting and residency region , browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

b) Existing or Potential Customers:

We may collect, use, store and transfer the following types of personal data when we conduct business with you:

  • Contact Data includes name, address, email address and telephone number.
  • Employment Data includes the company you work for and your job title.
  • Transaction Data includes details about products or services we provide to you or instructions or requests we received from you in relation to such transactions.
  • Financial Transaction Data includes payment details or account information used to pay for the services or products we provide to you.
  • Information collected for compliance with legal obligations, regulatory requirements, policies and procedures including identification documents and proof of residential address, education details, data relating to criminal convictions and offences in relation to an individual’s professional capacity (only as a result of sanctions screening results) for directors, officers and/or representatives of our service providers or counterparties.

c) Service Providers and Counterparties:

We may collect, use, store and transfer the following types of personal data when we conduct business with you:

  • Contact Data includes name, address, email address and telephone number.
  • Employment Data includes the company you work for and your job title.
  • Transaction Data includes details about products or services you provide to us or projects we collaborate on.
  • Financial Transaction Data includes payment details or account information used to pay for the services or products you provide to us or in relation to projects we collaborate on.
  • Information collected for security purposes including technical details about your access to our network and information systems in your provision of services to us, where applicable.
  • Information collected for compliance with legal obligations, regulatory requirements, policies and procedures including identification documents and proof of residential address, education details, data relating to criminal convictions and offences in relation to an individual’s professional capacity (only as a result of sanctions screening results) for directors, officers and/or representatives of our service providers or counterparties.

We may collect the personal data above directly from you, from our system logs, or from third parties, such as your employer, government agencies, a credit reporting agency, publicly available records, or reputable third-party screening service providers.

Where we need to collect personal data as required by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to receive your products or services). In this case, we may have to cancel a product or service we receive from you, but we will notify you if this is the case at the time.

3. Purposes for processing your personal data

a) Our Website:

We may process any personal data you provide to us to enable us to perform the contract entered into between you and us, to ensure our compliance with legal and regulatory requirements or for the purposes of our legitimate business interests, including the following:

  • to enable us to carry out our obligations arising from any contracts and to provide you with the information, products and services that you request from us;
  • to enable us to respond to an enquiry or other request you make when you contact us via our Website, including for customer services support;
  • to comply with our legal obligations, standards, policies and procedures;
  • to notify you about changes to our service;
  • to enable us to issue a notice or corrective action to you in relation to any of our services, if required;
  • to better understand how you interact with our Website, including its functionality and features, and ensure that content is presented in the most effective manner; and
  • to communicate and provide you with the relevant market information you have requested in our newsletters (by email).

b) Existing or Potential Customers

We may process personal data you provide to us to enable us to perform the contract entered into between you and us, to ensure our compliance with legal and regulatory requirements or for the purposes of our legitimate business interests, including the following:

  • to enable us to provide services to you or to carry out our obligations arising from any contracts;
  • to provide you with the information on the products and services that we believe you might be interested in and notifying you about important changes to these services, products or offerings;
  • to manage any complaints or improve our services or products or offerings;
  • to manage and administer your organization’s relationship with us, including payments and complying with your instructions or requests; and
  • to comply with our legal obligations, standards, policies and procedures, including anti-money laundering, financial and credit checks, audit requirements, fraud and crime prevention and detection, sanctions screening, quality checks, due diligence, and record keeping.

c) Service Providers and Counterparties:

We may process personal data you provide to us to enable us to perform the contract entered into between you and us, to ensure our compliance with legal and regulatory requirements or for the purposes of our legitimate business interests, including the following:

  • to enable us to receive services and goods from you, to collaborate on joint projects, or to carry out our obligations arising from any contracts;
  • to provide you with the information on the products and services that you seek to provide to us or our products and services you would like to collaborate on;
  • to manage and administer your organization’s relationship with us, including payments;
  • to comply with our legal obligations, standards, policies and procedures, including anti-money laundering, financial and credit checks, audit requirements, fraud and crime prevention and detection, sanctions screening, quality checks, due diligence, and record keeping; and
  • to protect the security of and manage access to our premises, IT and communication systems, online platforms, and other systems, preventing and detecting security threats, fraud and other criminal or malicious activities.

4. Marketing

We may also use your personal data to send you marketing-related information (such as newsletters) from Hartree Partners where it is linked to the service we are providing you. If you are located in China, we will seek separate opt-in consent from you before we send you marketing-related information. You may unsubscribe at any time by clicking on the “unsubscribe” link at the bottom of each marketing communication.

Please note that where you opt-out of receiving marketing communications, we may still send you certain necessary communications relating to your use of our service, such as service announcements, notices about information on the service and administrative messages, which would or may impact our existing service provided to you.

5. Sharing your personal data

We may share your personal data with:

  • our affiliated companies;
  • Government bodies and agencies in your jurisdiction and overseas (for example, the UK Financial Conduct Authority) to comply with our legal and regulatory obligations;
  • third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy; and
  • our service providers that we engage to provide services for us. Where we provide your personal data to third party services providers (if any), they are required to keep your personal data confidential and secure, and must only use your personal data as instructed by us.

We may also disclose your personal data where required to respond to authorized requests from government authorities or where required by law, including for national security. Where required by law, we may also disclose your personal data where necessary to enforce or apply our Website Terms or other agreements, to investigate or protect the rights, property or safety of Hartree Partners and our group companies, our products and services and our personnel, customers, distributors or business partners or to prevent or take action regarding illegal activities or fraud, situations involving potential threats to the safety of any person or as evidence in litigation or investigations.

6. Keeping your Personal Data Secure

We will take all reasonable steps (including appropriate technical and organizational measures) to ensure your personal data is processed securely to protect the confidentiality, integrity and availability of your personal data and in accordance with this Privacy Policy.

The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet and any transmission is at your own risk.

7. Storing your Personal Data

Your personal data collected via our Website will be stored on servers located in the United Kingdom. It may also be processed by, and transferred to, Hartree Partners staff or by one of our service providers operating in the United States, India or Singapore. This includes individuals engaged in, among other things, administration of an enquiry or request you make via our Website or the provision of support services.

We have implemented appropriate safeguards in accordance with our obligations under applicable data protection laws, to protect your personal data when it is transferred. Please contact our Hartree Data Protection Group by email at GDPR@hartreepartners.com if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom or European Economic Area or by mail at Hartree Partners, LP of 1185 Avenue of the Americas, New York, NY 10036 for the attention of Hartree Legal (Data Protection Group).

If you want further information on the specific mechanism used by us when transferring your personal data out of Singapore, you may contact us by email at dpoAPAC@hartreepartners.com or by mail at Hartree Partners Singapore Pte. Limited of 501 Orchard Road, #20-02, Wheelock Place, Singapore 238880 for the attention of Hartree Legal (Data Protection Group).

We follow the transfer mechanisms as allowed under applicable data protection laws in China for the transfer of your personal data outside China if you are located in China. If you want further information on the specific mechanism used by us when transferring your personal data out of China, you may contact us by email at dpoAPAC@hartreepartners.com or by mail at 501 Orchard Road, #20-02, Wheelock Place, Singapore 238880for the attention of Hartree Legal (Data Protection Group).

We will only retain your personal information for as long as necessary or reasonable to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

8. Your Rights

You may inform us of any changes to your personal data, and in accordance with our obligations under applicable data protection laws we will update or delete your personal data accordingly. To find out what personal data we hold about you or to have your personal data updated, amended or removed from our database, please contact us using our contact information below.

Residents of the United Kingdom, European Economic Area and China:

You may have the right to: request (a) access the to your personal data we hold about you; (b) request we correct any inaccurate personal data we hold about you; (c) request we delete any personal data we hold about you; (d) restrict the processing of personal data we hold about you; (e) object to the processing of personal data we hold about you; and/or (f) receive any personal data we hold about you in a structured and commonly used machine-readable format or have such personal information transmitted to another company. You also have the right to lodge a complaint about how we process your personal data with the supervisory authority for data protection issues in your country.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing information you request to you.

To exercise any of your rights in connection with your personal data, please contact our Hartree Data Protection Group by email at GDPR@hartreepartners.com or by mail to Hartree Partners, LP of 1185 Avenue of the Americas, New York, NY 10036 for the attention of Hartree Legal (Data Protection Group) if you are located in the United Kingdom or European Economic Area, or if you are located in China, by email at dpoAPAC@hartreepartners.com or by mail to 501 Orchard Road, #20-02, Wheelock Place, Singapore 238880for the attention of Hartree Legal (Data Protection Group). We will process any request in line with any local laws and our policies and procedures.

We will process any request in line with any local laws and our policies and procedures.

Residents of Singapore:

You may have the right to: (a) request access to your personal data we hold about you; (b) request we correct any inaccurate personal data we hold about you; (c) withdraw your consent to the collection, use, or disclosure of certain personal data we hold about you; and/or (d) receive certain personal data we hold about you in a structured and commonly used machine-readable format or have such personal information transmitted to another company.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing information you request to you.

To exercise any of your rights in connection with your personal data, please contact our Hartree Data Protection Group by email at dpoAPAC@hartreepartners.com or by mail to Hartree Partners Singapore Pte. Limited of 501 Orchard Road, #20-02, Wheelock Place, Singapore 238880, for the attention of Hartree Legal (Data Protection Group).

We will process any request in line with any local laws and our policies and procedures.

9. Third-Party Links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

10. Changes to this Privacy Policy

Any changes to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

11. Contact Us

If you have any questions about the processing of personal data via this Website, please contact our Hartree Data Protection Group at:

Residents of the United Kingdom and European Economic Area:

Hartree Partners, LP

1185 Avenue of the Americas, New York, NY 10036

GDPR@hartreepartners.com

For the attention of Hartree Legal (Data Protection Group)

Residents of Singapore and China:

Hartree Partners Singapore Pte. Limited

501 Orchard Road, #20-02, Wheelock Place, Singapore 238880,

dpoAPAC@hartreepartners.com

For the attention of Hartree Legal (Data Protection Group)

If you contact us, we will do our utmost best to address any concerns you may have about our processing of your personal data.