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PRIVACY POLICY

Principles protecting individuals’ privacy notice and choice

  • We notify individuals about the personal data we collect from them, how we use it and how to contact us with privacy concerns

  • We provide such notice through this statement, our engagement letters or other similar documents, and direct communication with individuals from whom we collect personal data

  • We collect and process personal data about our personnel for the purpose of human resources administration and recruitment

  • We collect and process personal data about our prospective and current clients, clients’ customers, and/or clients’ personnel for the purpose of rendering professional services to our clients

  • We collect personal data from individuals only as permitted

  • Consent for personal data to be collected, used, and/or disclosed in certain ways (including opt-in consent for sensitive data) may be required in order for an individual to obtain or use our services. Such consent is provided through our engagement letters, employment agreements and other similar documents

Disclosures and transfers

We do not disclose an individual's personal data to third parties, except when one or more of the following conditions is true:

  • We have the individual's permission to make the disclosure

  • The disclosure is required by lawful request by public authorities, including to meet national security or law enforcement requirements

  • The disclosure is required by law or mandatory professional standards

  • The disclosure is reasonably related to the sale or other disposition of all or part of our business

  • The information in question is publicly available

  • The disclosure is reasonably necessary for the establishment of legal claims

  • The disclosure is to another QuantAscend entity or to persons or entities providing services on our or the individual's behalf (each a TRANSFEREE), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:

    • Is subject to law providing an adequate level of privacy protection; or

    • Has agreed to provide an adequate level of privacy protection

We may transfer personal data from one jurisdiction to another. Privacy laws vary by jurisdiction, and some may provide less or different legal protection than others. However, we will protect personal data regardless of the jurisdiction in which the data resides.

We are responsible for the third-party acts within our control that result in the processing of personal data inconsistent with our policy.

Data, security, integrity and access

We employ various physical, electronic, and managerial measures, including education and training of our personnel, designed to reasonably protect personal data from loss, misuse or unauthorised access, disclosure, alteration, or destruction. Personal data collected or displayed through a website is protected in transit by standard encryption processes. However, we cannot guarantee the security of information on or transmitted via the internet.

We process personal data only for the limited and specific purpose for which it was originally collected or authorised by the individual. To the extent necessary for such purposes, we take reasonable steps so that personal data is accurate, complete, current, and otherwise reliable with regard to its intended use.

An individual has the right to access personal data we hold about them as specified by our policy. An individual may contact us using the information below to correct, amend or delete information where it is inaccurate or has been processed in violation of policy. The individual will need to provide sufficient identifying information, such as name, address and birth date. We may request additional identifying information as a security precaution, such as possibly a national identifier (e.g., an Aadhaar Card number). In addition, we may limit or deny access to personal data where providing such access would be unreasonably burdensome or expensive in the circumstances, or where the rights of persons other than the individual would be violated. In some circumstances, we may charge a reasonable fee, where warranted, for access to personal data.

Accountability and enforcement

We have established a programme to monitor our adherence to our policy and to address questions and concerns regarding our adherence. This programme will include a statement, at least once a year, signed by our authorised representative, verifying that this statement is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible. We encourage interested persons to raise any concerns with us using the contact information below.

Individuals may file a complaint with our PRIVACY OFFICE in connection with the firm's processing of their personal data. With respect to any dispute relating to this statement that cannot be resolved through our internal processes:

  • If the dispute involves data collected in the context of an employment relationship, we will cooperate with competent data protection authorities and comply with the advice of such authorities. In the event that we or such authorities determine that we did not comply with this statement, we will take appropriate steps to address any adverse effects and to promote future compliance

  • Personnel who violate our privacy policies will be subject to disciplinary process

  • An individual may under certain conditions invoke binding arbitration

Amendment

We may amend this statement from time to time by posting a revised statement on this website, or a similar website that replaces this website. If we amend the statement, the new statement will apply to personal data previously collected only insofar as the rights of the individual affected are not reduced. So long as we adhere to our Privacy Policy, we will not amend our statement in a manner inconsistent with it.

Information subject to other policies

We are committed to following the Principles for all personal data within the scope of our Privacy Policy. However, certain information is subject to policies of the firm that may differ in some respects from the general policies set forth in this statement.

Information obtained from or relating to clients or former clients is further subject to the terms of any privacy notice to the client, any engagement letter or other similar letters or agreements with the client, and applicable laws and professional standards.

Effective Date

This privacy policy was last updated on November 27th 2021.

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