Data protection privacy notice
We are committed to protecting your personal information and
ensuring we respect your privacy. This Privacy Notice explains how we
will look after and use any personal information that we collect about
What is personal information?
Personal information means any information about you from which
you can be identified. Examples of personal information include your
name, home address, national insurance number, date of birth, telephone
number and e-mail address but it also includes other pieces of information
which can be used to identify you, either directly or indirectly, such
as a cookie.
Who we are
Quantbot Technologies LP and Quantbot Technologies Ltd are both
Controller of the personal information you provide to us. If you have
any questions about this Privacy Notice or the information we hold about
you please contact our GDPR Contact, Thuong Lam using the details set
- Thuong Lam
- +44 (0)203 122 1904
- 4th Floor, 6-7 New Bridge Road, London, EC4V 6AB, United
If more convenient, please also feel free to contact Debra
our chief compliance officer using the details set out below:
- Debra Wisdom-Spielfogel
- +1 646 461 6204
- 369 Lexington Avenue, 9th Floor, New York, NY 10017 USA
You have the right to make a complaint at any time to the
Commissioner‟s Office (“ICO”), the UK supervisory authority
for data protection issues. We would however appreciate the chance to
deal with your concerns before you approach the ICO, so please contact
us in the first instance.
Consequences of not providing some types of
Where we need to collect your personal information by
under the terms of a contract we have with you, and you fail to provide
that information when requested, we may not be able to provide the goods
or services you asked for. In this case we may have to cancel the product
or services but we will tell you if this is the case.
How do we collect information about you?
Typically we will collect information from you when you
us directly or provide information in order for us to provide our products
and services. We collect information from and about you in the following
Through direct interactions when you give us your
by filling in forms or during correspondence with us. This includes when
- Send your CV to us.
- Invest in our employee private fund.
- Meet with us in person or talk to us on the phone.
- Provide contact details, proof of identity etc. as part of an on-boarding
- Direct correspondence with us.
- Through using our website when we collect information using
cookies or similar technologies which tell us about your equipment, browsing
actions and patterns.
- Through automated technologies through which we scan employee
emails and other correspondence to tell us about patterns, unauthorised
communication, etc. We use SMARSH to review emails.
For employees we collect additional information as set
- Through third parties such as background check companies we
use as part of our onboarding process or recruiters.
The background check company may provide us with the
- Employment history.
- Educational history.
- Financial information.
- Historical information (relating to negative news searches)
- Criminal information.
The recruiters may provide us with the following:
- Phone number, address and any other contact details.
- Employment history and Educational history.
We also collect the following information from you which
referred to as a special category of personal data because it is sensitive
information about you and will require special protections. The information
we collect is in relation to your:
- Religious or philosophical beliefs.
We are able to process this information because (i) the
is necessary in order that we can comply with our rights and obligations,
or those of the individual, in relation to employment law, social protection
law or social security law, or (ii) the processing is necessary in relation
to legal proceedings, for obtaining legal advice, or otherwise for establishing,
exercising or defending legal rights.
We have contractual and legal basis to do so. It is
for us to carry out our obligations under your employment rights and
other legal requirements.
To ensure you are fit and proper to undertake a specific
at the Company we may process personal data about you relating to criminal
convictions and offences or related security measures.
This includes information about criminal allegations,
and convictions as well as security measures. Note that, as we are regulated
by the Financial Conduct Authority, we have an obligation under the Financial
Services and Markets Act 2000 to do so.
How we will use your personal information
We only obtain, use and keep personal information where
it for a specific purpose. We set out in the table below the ways in
which we plan to use your personal information. We are only able to use
your personal information if we have a proper legal reason or basis for
doing so. This is called a legal basis and the regulations require that
we have a legal basis so that your privacy is protected. Most commonly
we will use your information in the following ways:
- We have a contract with you. For example, we have agreed
to provide financial advice or to manage investments for you and have
a contractual agreement to do this.
- We have a legal obligation. We need to use your personal
information to comply with laws that assist in the prevention of financial
crime and to comply with regulatory obligations. For example this might
include confirming your identity and source of wealth, as well as ensuring
we provide you with necessary information so you understand the risk
of the financial services we can provide.
- We, or a third party, have a legitimate interest in processing
the information and your interests and fundamental right do not override
those interests. For example, processing your information to prevent
We set out in the table below all the ways we plan to use
personal information and the legal bases we rely on to do so. We also
explain what our legitimate interests are where appropriate:
- Purpose Lawful basis for processing including our.
- legitimate interests.
- Recruitment Process - To interview, correspond with, assess
and come to a decision on prospective staff members.
- Necessary for our legitimate interests – to recruit new
- To purchase services from our suppliers To fulfil contracts
- To use data to improve our website Necessary for our legitimate
interests – to understand how our customers interact with our website.
- Onboarding and whilst working for us - To give effect to your
contract of employment. This includes a wide range of activities including,
fitness and propriety, payroll, appraisal, training, discipline and internal
communications related to the business..
- To fulfil our regulatory and legal obligations and to fulfil
our obligations as an employer in accordance with employee contracts
- When your employment has ended - To enable us to provide regulatory
references, protect you or us against legal proceedings, provide for
- Necessary for our legitimate interest - to protect our legal
position in the event of a legal proceedings and to comply with legal
obligations. To fulfil our regulatory obligations.
- To on-board you as aninvestor (in the private.
- fulfil our contact with you employee fund).
- To fulfil our legal obligations to prevent financial crime.
- To monitor your investment on an on-going basis.
- To fulfil our contract with you.
- To meet our regulatory obligations to provide you with regular
information about your investment.
- To fulfil our regulatory obligations.
We will only use your personal information for the reason
which we collected it. We will only use it for another reason if we believe
that new reason is compatible with the original purpose. If we do need
to use your personal information for a non-related purpose we will tell
you about it and explain the legal basis which allows us to do so.
Cookies are small text files placed on your computer
(or other device where you access the internet) used to collect information
on your activities online. They can also be used as part of website
so you should be careful about accepting, deleting or removing them.
We can collect information about the device you are using to access the
internet, your IP address and website browser (for example). Cookies
can tell us what information you were looking at, for how long, which
internet sites interest you which are useful for us particularly for
marketing our products and to ensure we are delivering the right service
For example, cookies can tell us how many visitors to the
accessed the information and tools we provide. It may be the information
on our website is not clear and we need to improve it – or there
may be a genuine need to improve our range of products in the interests
of our customers.
If you have concerns about cookies this web site explains
you can delete and control the cookies that are stored on your computer:
Who we share your information with
We may need to provide information to third parties for a
of reasons, for example, we may need to provide information to assist
in the detection or prevention of crime or for the purpose of safeguarding
national security. Please refer to the table in the section „How
we will use your personal information‟ which explains how we use
your data. The third parties we share your information with are as
- Our accountants.
- The fund administrator for our employee private fund.
- Background check company.
- Service providers.
- Other group entities.
- Tax authorities.
- Sending your information outside of the EEA.
Quantbot Technologies Limited will transfer information
group to Quantbot Technologies LP. The regulations which have been put
in place to protect your privacy apply throughout the EEA. As explained in the
section above we will send your information
to other third parties who are based outside of the EEA, however we will
only share your information with them because the following safeguards
have been put in place:
- The information is being transferred between organisations which
have an agreement in place including standard contractual clauses which
sets out how your privacy will be protected.
You can obtain further information on the specific
used by us when transferring your personal information outside of the
EEA by contacting the GDPR Contact.
Storing your information
The period for which we will retain personal information
vary depending on the purposes that it was collected for, as well as
the requirements of any applicable law or regulation. When we decide
how long we will retain your personal information, we will take into
account the amount, nature, sensitivity of your information and how we
want to use it as well as the potential risk of harm being caused from
unauthorised use or disclosure. We review our retention periods for personal
information on a regular basis and will ensure all records are safely
destroyed if we no longer need to retain them or you have contacted us
to request so.
You are provided with a number of different rights under
data protection laws in relation to your personal information. These
- To access your information.
- To request we correct your information.
- To request that we erase your information.
- To object to the processing of your information.
- To request a restriction in the processing of your information.
- To request a transfer of your information.
- To withdraw your consent.
If you wish to exercise any of these rights please
GDPR Contact. Please note that you will not have to pay a fee to access
your personal information or to exercise any of the other rights. We
may, however, charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive or we may refuse to deal with your request. We
may also need to seek further information from you to confirm your identity
before we release any personal information. This does not affect your
right to make a complaint.
We have put in place appropriate security measures to
your personal information from being accidentally lost, used or accessed
in an unauthorised way, altered or disclosed. We have a procedure to
deal with any suspected personal data breach and will notify you, and
other regulators, where we are legally required to do so.