Privacy Notice

Introduction

Your privacy is very important to us. This privacy notice (“Privacy Notice“) is provided by Devon Park Advisors, LLC and Devon Park Securities, LLC ( collectively “Devon Park”, “we”, “us” or “our”) and sets forth the policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of your personal information. We may change this privacy notice from time to time without prior notice to you. Any changes will be effective immediately upon posting to our Site.

The types of personal data we may collect and use

During the course of your relationship with us and otherwise in your interaction and correspondence with us and our representatives we may collect:

Information you provide to us:

  • basic personal details of certain directors or other individuals for client verification purposes such as name and address (and proof of name and address), email address, telephone number, and any other contact details you supply to us;
  • details of your company’s directors, shareholders, secretaries, authorized signatories and identification documents;
  • banking details;
  • details of business advisors you employ including your advisors;
  • records of all communications including electronic communications with our staff and meeting notes; and
  • employment and education history, references, skills, and information related to your candidacy (where you send us this information as part of a job application process).


Information we collect from other sources, such as publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet:

  • data received from background checks related to the job application process. This may include criminal record checks and credit history or bankruptcy checks as required for regulatory purposes;
  • data received from due diligence activities (such as anti-money laundering, politically exposed persons and sanctions checks);
  • fraud inquiries (for example, information from police reports); and
  • basic personal details, and employment and education history (where we are sent this information by you or an employment agent).


In the context of the provision of our services we may receive personal information from third parties such as your employer, other parties relevant to the services we are providing (e.g., counterparties in transactions) and others such as regulators and authorities. That information could include your name, contact details, employment details and other information relevant to the services that we are providing to our client.

Using your personal data: the legal basis and purposes

The information which we collect and what we use it for will depend on the nature of our business relationship with you.  We use your information to provide our services and to fulfill our contractual obligations to third parties; for our internal business administration and record keeping purposes; for legal and regulatory compliance purposes, including as necessary to respond to governmental, regulatory or law enforcement requests; where required or considered appropriate, carrying out ‘know-your-client’ (“KYC”) checks and other procedures that we undertake prior to you becoming a client of ours and in the course of our ongoing business relationship; for recruitment and evaluating your candidacy as a job applicant; and to send invitations, marketing materials, updates or other publications that we feel may be of interest to you and to organize events. 

Your personal data will be processed in accordance with Data Protection Law and may be processed with your consent, upon your instruction, or for any of the purposes set out herein, including where we or a third-party consider there to be any other lawful purpose to do so.

Where personal data is required to satisfy a statutory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in us being unable to provide services to you. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

How we may share your personal data

We may disclose information about you to third parties for the purpose of providing services to us (e.g. accountants, compliance consultants, legal advisors, professional advisors, and communications providers); fraud prevention agencies; information technology providers, including providers of client relationship management systems, and information security providers; administrative service providers; employment agents and data storage suppliers.  We will also release information about you if you direct us to do so.

Monitoring of communications

We may monitor and save electronic communications with you for the purposes of: (i) ascertaining the details of instructions given in connection with the delivery of our services to you; (ii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.

Retention periods and security measures

We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to Data Protection Law. How long we will hold your personal data will be determined by: (a) the purpose of which we are using it- we will need to keep the data for as long as it is necessary for that purpose; and (b) legal and regulatory obligations- laws or regulation may set the minimum period for which we have to keep your personal data. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.

To protect your personal information from unauthorized access and use, we apply organizational and technical security measures in accordance with Data Protection Law. These measures include computer safeguards and secured files and buildings. We will notify you of any material personal data breaches affecting you in accordance with the requirements of Data Protection Law.

International transfers

Because of the international nature of our business, personal data may be transferred outside your home country, such as to jurisdictions where we conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by your own. In such cases, we will take appropriate measures to ensure your personal information is handled as described in this privacy notice.

Your rights

Federal law gives you the right to limit only the following information sharing: (1) sharing with affiliates for everyday business purposes information about your creditworthiness; and (2) sharing with non-affiliates for the purpose of marketing products or services to you. If you would like to limit any of the foregoing sharing purposes, please contact us in writing at the address below.

You may contact us at any time to limit our sharing of your personal information.

California Residents’ rights under The California Consumer Privacy Act

Where applicable, California residents have the following privacy rights under the California Consumer Privacy Act of 2018 (the “CCPA”).  For the purposes of this section of the policy, “Personal Information” means any data that defines, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household, which is in the possession of, or is likely to come into the possession of Devon Park.

These rights include, to the extent required by the CCPA and subject to verification and any applicable exceptions:

  • the right to request information regarding Personal Information collected about you as described below:
    • the categories of Personal Information we have collected about you;
    • the categories of sources from which that Personal Information we have collected;
    • the specific pieces of Personal Information we have collected about you;
    • the categories of third parties to whom such Personal Information was disclosed;
    • the business or commercial purpose for which the Personal Information was collected;
  • the right to request that we erase your Personal Information in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Information but we are legally entitled to retain it; and
  • the right to be free from unlawful discrimination for exercising any of the rights above.

 

We will need to verify your identity prior to addressing or fulfilling a request made pursuant to the CCPA.  Your request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to Personal Information collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.

Please note that Devon Park does not, and will not, sell Personal Information collected about you.

You can exercise your rights by contacting us using the details listed below under the section titled “Who to Contact about this Privacy Notice.”

Who to contact about this Privacy Notice

If you have any questions about our Privacy Notice should contact our Compliance Department in writing at 12012 South Shore Boulevard, Suite 201 Wellington, FL 33414, or by email at info@devonparkadvisors.com 

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