Five Bells Settlement Corp. (“FBS”) takes your privacy seriously. This FBS Website, SocialMedia and Cookie Notice (“Notice”) applies to users (“you”) of this and other integrated FBSwebsites (“FBS Websites”) and visitors of FBS’ profiles in Social Media platforms and personalprofiles of FBS staff acting on FBS’ behalf. The Notice contains information that FBS and itsaffiliates (collectively “FBS”, “we”, “our”, or “us”) collect(s) through these webpages and SocialMedia platforms and what we do with that information. As part of our commitment to protectyour “Personal Data” we want to inform you in a transparent manner:
• why and how FBS collects, uses and stores (“processes”) your Personal Data; and
• how we attempt to protect your Personal Data.
This Notice applies to any “information” obtained by FBS through your use of FBS Websites andtracking technologies we use. It is not applicable to non-integrated FBS websites or any“internet“ websites controlled by third parties not affiliated with FBS that the FBS Websites maylink to ("Third Party Sites"). Please review the privacy statements of Third Party Sites as FBS isnot responsible for and has no influence on the content or the privacy practices of Third PartySites. It also applies to any information collected and processed in Social Media platforms(such as Facebook, LinkedIn and Twitter). The terms of this Notice are subject to any additionalterms or disclaimers or other contractual terms you have entered into with FBS such as potentialclient privacy statements or notices, and any applicable laws and regulations.
We collect the following Information through FBS Websites:
a) Information that you provide to us, for example:
• Personal details (e.g., name, gender, address, e-mail address, phone/fax number) on a registration page or if you sign up for an email, newsletter or other service or product;
• User login and subscription data (e.g., login credentials for FBS Websites);
• Other information that you give us by filling in forms, surveys, or by communicating with us, whether face-to-face, by phone, e-mail, online or otherwise.
b) Information that we collect or generate about you, for example:
• Data our server automatically records when you visit FBS Websites (e.g., your IP address, the website from which you visit us, the type of browser software used, the FBS Website pages that you actually visit including the date and the duration of your authentication information);
• Cookies, pixels, unique identifiers and other similar technologies to collect and process information from different channels and devices, including devices that you use to interact with us, to recognize you, remember your preferences, tailor the content we provide to you. For details on how we use cookies, please refer to the section below;
• Investigations data (e.g., due diligence checks, anti-money laundering checks, content and metadata related to relevant exchanges of information between individuals, organizations);
• Records of correspondence and other communication between us (e.g., live chats, instant messages and social media communications);
• Information that we need to support our regulatory obligations (e.g., information about transaction details, purpose of payment, counterparty/beneficiary information, detection of suspicious activities).
c) Information that we collect from other sources, for example:
• Information from third parties or delegated third party service providers (e.g., website user information collected through third party application service providers that we have a relationship with, or through cookies, pixels, social plugins, tags and other similar technologies).d) Information collected through Social Media Platforms: • Personal Details and Identification as included by you in your social media account, such as:first name, last name, account ID, title, profile photo, geographical area;
• Professional Profile to the extent included by you in your social media account, such as:profession, occupation, company you work for and job function, professional qualifications, professional title, education; and • Information included in the comments you post in the social media platform (“Social Media Post”) and in your interaction with our profiles, such as: date and time of your interaction with us and the text of your comments on our posts or under our profiles.
We always process your Personal Data for a specific purpose and attempt to only process thePersonal Data which is relevant to achieve that purpose. In particular, we process PersonalData for the purposes of:
a) Website Administration. For example, to:
• ensure technical administration, research & development for improving our websites and user administration.
b) Relationship Management. For example, to:
• assist you in registration to our events or logins;
• allow you to provide feedback;
• keep track of your specified preferences such as language, time zone and timeouts after periods of inactivity;
• respond to any service issues; and
• manage the social media community.
c) Product implementation and execution. For example, to:
• enhance the quality of our products and services and our use of technology.
d) Engaging in Prospecting and Business Development and/or Protecting and Enhancing the FBS brand. For example, to:
• contact you in relation to products and services;
• assist with our promotional and marketing efforts; and
• help us to develop targeted advertising initiatives (including behavioral advertising) wherepermitted, for instance ads we consider relevant for (groups of) users on external partnerwebsites and media.
e) Compliance and Risk Management and/or Crime Prevention, Detection and Investigation. For example, to:
• Perform due diligence or anti-money laundering checks on content and metadata; and
• comply with regulatory requirements, including the Supervision and ‘books and records’ archiving requirements imposed in the United States and elsewhere for social media interactions.
f) Recruitment Marketing and Application handling. For example, to:
• Check performance of candidate sourcing channels and to track candidate source;
• Measure the success of our social media campaigns on channels listed below;
• Retarget specific audiences on social channels with relevant content or build look-a-like audiences;
• Assist with our promotional and marketing efforts; and to help us to develop targeted advertising initiatives (including behavioral advertising) where permitted, for instance to create ads we consider relevant for (groups of) users on external partner websites and media.
Among other things, FBS uses tracking technology such as cookies, pixels, unique identifiers or tags (“Tracking Technologies”) to gather information as outlined above to understand how visitors use the FBS Website. Tracking Technology helps us to manage and improve the usability of FBS Websites, for example by detecting whether there has been any contact between your device and us in the past and to identify the most popular sections of the FBSWebsite. We may also use these Tracking Technologies to check your instructions to us, assess, analyze and improve our service, train our staff as well as for other purposes. The“Cookies” link at the bottom of the page gives you more details about FBS’s use of cookies, and lets you control which types of cookies FBS Websites may set on your device (known as your “Privacy Settings”). When you save your privacy settings, they should also apply to your future visits to FBS Websites. However, for technical reasons beyond FBS’s control, this cannot be guaranteed. For example, if you reset your browser, delete your cookies or access FBSWebsites from another browser or device your privacy settings may be lost. To comply with applicable laws and regulations, in some countries you may be asked to confirm your privacy settings when you first visit a FBS Website. In addition, you might be periodically required tore-confirm your settings. In many cases you can also control Tracking Technologies using your browser. Please ensure that your browser setting reflects whether you wish to be warned about and/or accept Tracking Technologies where possible. The specific capabilities of your browser and instructions on how to use them can usually be found in the manual or help file of your browser. Refusing, disabling or deactivating of Tracking Technologies may result in a reduced availability of the services. The list of Tracking Technologies applied by FBS will change from time to time and may be requested from FBS at info@fivebellssettlement.com.
Functional cookies are strictly necessary for www.fivebellssettlement.com to work properly. We use them to remember your entries in a form or to provide you access to closed user groups using your FBS profile. Functional cookies cannot be deactivated. These tracking applications are used to track behavioral information on websites and mobile applications. The technologiesFBS uses for these purposes will change from time to time and may be requested from FBS at info@fivebellssettlement.com.
FBS has implemented adequate technical and organizational security measures to protect yourPersonal Data collected by FBS via FBS Websites against unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing, although no guarantees can be provided that such measures will be successful. All employees accessing Personal Data must comply with the internal rules and processes in relation to the processing of your Personal Data to protect them and ensure their confidentiality. Specifically, we restrict access to personal information about you to employees but also to agents or other parties who need to know the information to provide services to you. However, again, no guarantees that total protection of your Personal Data can be provided by FBS.
FBS may disclose your information to its affiliates and their agents and third-party service providers inside or outside your country of residence to perform services for FBS and for the purposes stated above. Our affiliates, agents and third-party service providers who have access to Personal Data obtained through FBS Websites are obliged to respect your privacy, comply with legal obligations and adhere to contractual safeguards. When transferring PersonalData internationally we attempt to make sure that we comply with applicable laws and regulations, for example, by entering into agreements which will ensure that the recipients of your information maintain an adequate level of data protection. FBS does not presently intend to transfer your personal data to other third parties, provided that this might change in FBS’s sole discretion subject to applicable law. We may also disclose your information to governmental agencies or entities, regulatory authorities, or other persons in line with any applicable law, regulations, court order or official request, and for the purposes of any guidelines issued by regulatory or other authorities, or similar processes as required by applicable law.
Please note that if you transfer your information to us through an open network such as the internet, such networks are generally not regarded as a secure environment. Information sent via e.g., the internet (such as to or from the FBS Website or via electronic message) may be accessed by unauthorized third parties, potentially leading to disclosures, changes in content or technical failures. Even if both sender and receiver are located in the same country, information sent via the internet may be transmitted across international borders and be forwarded to a country with a lower data protection level than the one in your country of residence. Please note that we accept no responsibility or liability for the security of your information whilst in transit over the internet to FBS. In order to protect your privacy we would like to kindly remind you that you may choose other means of communication with FBS, where you deem it appropriate.
FBS Websites do not seek to collect Personal Data from individuals under the age of 18.Children should obtain parental or legal guardian consent as per the age threshold established by each country (which, for example in the EU, can be between 13 and 16 years depending on the Members State).
If you are not satisfied with any aspect of the processing of your Personal Data by FBS, please let us know and we will investigate your concern by contacting the Data Protection Office at info@fivebellssettlement.com.
Any amendment or update to this Notice we will make available to you via www.fivebellssettlement.com/privacy-policy.html.