PRIVACY

CORLYTICS is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, CORLYTICS is committed to the appropriate protection and use of personal information (sometimes referred to as “personally identifiable information” or “PII”) that has been collected online.

Generally, our intent is to collect only the personal information that is provided voluntarily by online visitors so that we can offer information and/or services to those individuals or offer information about employment opportunities. Please review this Privacy Statement (“Privacy Statement”) to learn more about how we collect, use, share and protect the PII that we have obtained.

COLLECTION AND USE OF PERSONAL INFORMATION

We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you may have previously provided your PII to CORLYTICS (if, for example, you are a former employee). By registering and/or submitting personal information to CORLYTICS, you are also agreeing to the use of this information in accordance with this Privacy Statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you send us an email message requesting information about CORLYTICS, we will use your email address and other information you supply to respond to your request. If you send us a resume or curriculum vitae (CV) to apply online for a position with CORLYTICS, we will use the information that you provide to match you with available CORLYTICS job opportunities.

In some cases where you have registered for certain services we may store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).

CORLYTICS generally collects only the personal information necessary to fulfil your request. Where additional, optional information is sought, you will be notified of this at the point of collection.

Corlytics core products use publicly available information from regulatory enforcement notices to inform future risk management for the financial services industry. This information includes regulatory enforcements that may be levied against individuals. Therefore, this information constitutes personal information. This publicly available personal information is used to inform Corlytics risk intelligence and is then categorised for global comparison to make the data relevant to any financial institution. This data and its analysis are provided as part of Corlytics Solutions to clients made up financial and educational institutions.

Data included in regulatory enforcements against individuals can include name, occupation, employer organisation, offence, penalty, period of misconduct, job function, jurisdiction/city, solvency status, extenuating circumstance and prior disciplinary history.

The data sources are listed here below:

CORLYTICS only collects “sensitive” personal information when the relevant individuals voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards. Sensitive information includes personal information regarding a person’s race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, sexual life or criminal record. Please use your discretion when providing sensitive information to CORLYTICS, and under any circumstances, do not provide sensitive information to CORLYTICS, unless you thereby consent to CORLYTICS’s use of that information for its legitimate business purposes and consent to the transfer and storage of such information to and in CORLYTICS databases.

If you have any questions about whether the provision of sensitive information to CORLYTICS is, or may be, necessary or appropriate for particular purposes, please contact CORLYTICS at privacy@corlytics.com

COOKIES

Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.

On some of our web sites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities.  A secondary type of cookie referred to as “user-input” cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser’s cookies.

Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites’ features.

Further information about managing cookies can be found in your browser’s help file or through sites such as www.allaboutcookies.org.

Below is a list of the types of cookies used on our web sites:

Other third party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.

Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.

BY NAVIGATING ON OUR WEB SITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.

GOOGLE ANALYTICS

CORLYTICS uses Google Analytics. More information about how Google Analytics is used by CORLYTICS can be found here: http://www.google.com/analytics/learn/privacy.html

To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

LOCATION-BASED TOOLS

CORLYTICS may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

SOCIAL MEDIA WIDGETS AND APPLICATIONS

CORLYTICS web sites may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of CORLYTICS web sites (see details on ‘Social Sharing’ cookies above). Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, CORLYTICS web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any CORLYTICS social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

WHAT LEGAL BASIS DO WE HAVE FOR PROCESSING YOUR PERSONAL DATA?

The General Data Protection Regulation provides six legal bases under which data processing may take place. These are consent, contract, legitimate interests, vital interests, public task, legal obligation and consent.

For the purpose of its data processing activities, Corlytics relies on the legal basis of contract, legitimate interests and legal obligation.

CONTRACT: This legal basis is relied upon by Corlytics where the processing of personal data is required to fulfil contractual obligations to that individual or their company; or as part of a request before entering into a contract. The processing under this legal basis must be necessary. Art 6(1)(b) of the GDPR defines this legal basis as being where ‘processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.’

LEGITIMATE INTERESTS: This legal basis can be relied upon where processing is conducted in manner data subjects would reasonably expect and with minimal privacy impact or where there is a compelling justification for the processing. When using this legal basis, a legitimate interest must be identified, processing must be necessary and balanced against the interests, rights and freedoms of individuals. Legitimate interest can be that of Corlytics or the interests of third parties. It is in Corlytics legitimate interest to process certain publicly available enforcement data to provide the necessary risk analytics to our clients. Art 6(1)(f) of the GDPR gives a lawful basis for processing where ‘processing is necessary for the purposes of legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.’

LEGAL OBLIGATION:This legal basis can be relied upon where the processing is necessary to comply with a common law or statutory obligation. The processing must be necessary. Art 6(1)(c) of the GDPR describes this as ‘processing… necessary for compliance with a legal obligation to which the controller is subject.’

HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

Corlytics is bound by various obligations relating to personal data we retain or that is under our control. These obligations include the time period for which we may hold personal data and when or how we may destroy it. These may arise from local laws or regulations or from contracts with employees, customers, goods and service providers and our partners. Data will be retained as per Corlytics obligations and then appraised and evaluated for archiving where relevant otherwise, they will be securely destroyed.

These laws may include the Terms of Employment (Information) Acts 1994 to 2012, Payment of Wages Act 1991, National Minimum Wage Act 2000, Organisation of Working Time Act 1997, Protection of Young Persons (Employment) Act 1996, Employment Permits Acts 2003 to 2012, Carer’s Leave Act 2001 and Maternity Protection Acts 1994 and 2004. This list is non-exhaustive. Further information regarding the Corlytics Data Retention and Disposal Policy is available from privacy@corlytics.com

Personal data in paper form will be shredded and securely disposed of by shredding and pulping. Electronic equipment containing personal data will be destroyed using hard drive erasing software and individual folders, will be permanently deleted from the system using secure file deletion.

CHILDREN

CORLYTICS understands the importance of protecting children’s privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.

SHARING AND TRANSFER OF PII

We do not share personal information with unaffiliated third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards.

In some instances, CORLYTICS may share PII about you with various outside companies or service providers or vendors working on our behalf to help fulfil your requests.

In addition, CORLYTICS may transfer certain PII across geographical borders to other CORLYTICS member firms or outside companies working with us or on our behalf. CORLYTICS may also store PII in a jurisdiction other than where you are based. By providing PII on online, visitors are consenting to this transfer and/or storage of their PII across borders.

CORLYTICS may also disclose PII in connection with the sale, assignment, or other transfer of the business of the site to which the data relates, in order to respond to requests of government or law enforcement agencies or where this is required by applicable laws, court orders, or government regulations. These disclosures may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat. CORLYTICS does not sell PII to any third parties. Also, CORLYTICS will not transfer the PII you provide to any third parties for their own direct marketing use.

CHOICES

In general, you are not required to submit any PII to CORLYTICS online, but we may require you to provide certain PII in order for you to receive additional information about our services and events. CORLYTICS may also ask for your permission for certain uses of your PII, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

As described in “Cookies” above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

YOUR RIGHTS IN RELATION TO PERSONAL DATA

The GDPR (General Data Protection Regulation) provides certain rights to Data Subjects. Corlytics will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

The GDPR provides the following Rights for individuals:

• Right to Rectification (Under GDPR must be dealt with without undue delay)
• Right to Erasure (Under GDPR must be dealt with without undue delay)
• Right to Restrict Processing
• Right to Data Portability
• Right to Object
• Rights in Relation to Automatic Decision Making and Profiling

RIGHTS OF ACCESS (ALSO KNOWN AS A SUBJECT ACCESS REQUEST)

Data Subjects have the Right to obtain:

• Confirmation that their data is being processed
• Access to their personal data and
• Other supplementary information

Corlytics will respond to access requests within one month.

RIGHT TO RECTIFICATION

Data Subjects are entitled to have their personal data rectified if it is inaccurate or incomplete. Where the information was disclosed to a third party they will be informed of the request for rectification where possible. Information on these third parties will be provided, where appropriate.

Rights to rectification must be responded to within one month

RIGHT TO ERASURE

The Right to Erasure allows Data Subjects to request the deletion or removal of personal data where no compelling reason exists for its continued processing.

This right applies in the following circumstances:

• The personal data is no longer necessary in relation to the purpose for which it was originally collected
• The processing was based on consent, and the Data Subject has now withdrawn their consent
• The Data Subject objects to processing and there is no overriding legitimate interest of the Data Controller
• The data was being unlawfully processed
• The data must be erased to comply with a legal obligation

RIGHT TO RESTRICT PROCESSING

Where this right is exercised, Corlytics is permitted to store the personal data but not further process it. Restricted information about the individual may be retained to ensure that the restriction is respected in the future.

This right applies:

• When a Data Subject contests the accuracy of their personal data, processing is restricted to storage only until accuracy is verified
• When a Data Subject objects to processing which is being carried out for the reason of performance of a task in the public interest, or for the legitimate interests of the Data Controller, then it must be restricted to storage while they consider if the legitimate grounds override the Rights and freedoms of the individual.
• When processing is unlawful, and a Data Subject opposes erasure and requests restriction to storage instead.
• When the Data Controller no longer requires the data, but the Data Subject requires it for a legal claim.

RIGHT TO DATA PROBABILITY

This right provides Data Subjects with the right to obtain and reuse their personal data for their own purposes across different services. Allows data to be moved, copied or transferred from one IT environment to another in a safe and secure way in a common data format.

The Right to Data Portability applies in the following circumstances:

• Where the personal data was provided to the controller directly by the Data Subject
• Where the processing is based on consent or performance of a contract
• Where processing is carried out by automated means

RIGHT TO OBJECT

Individuals have the Right to object to:

• Processing based on legitimate interest or performance of a task in the public interest/exercise of official authority (including profiling)
• Direct marketing (including profiling)
• Processing for the purposes of scientific/historical research and statistics

Corlytics will assess all requests objecting to processing and balance these against both the right and freedoms of Data Subject, as well as Corlytics basis for processing this data.

RIGHT IN RELATION TO AUTOMATIC DECISION MAKING AND PROFILING

This provides safeguards for individuals against the risks of a damaging decision being taken without human intervention.

This applies where:

• It is based on automated processing
• It produces legal/significant effects on the individual

It does not apply where it:

• Is necessary for entering into or performance of a contract
• Is authorised by law
• Is based on explicit consent
• Does not have a legal/significant effect on the data subject

Corlytics are committed to operating transparently and complying all reasonable requests for information not subject to specific exemption in the Regulation. Data Subject rights can be exercised through the Corlytics Subjects Right Request process.

As part of this process we will verify we have sufficient information to confirm your identity. In most cases you will be requested to provide an official form of identification as part of this process. We cannot supply information about a data subject to a third party, save for limited circumstances provided by law.

Once we have sufficient information to identify your data, we will assemble any manually or electronically held. If we identify any third party data that may affect their privacy, this will be redacted.

Once all outstanding queries relating to the information have been resolved, access will be provided. Your have the right of appeal through our internal appeals process, against any decision made on foot of a Data Subject Request. If you are unhappy with the result of such an appeal you also have recourse to complain to the Data Protection Commissioner.

A subject access request form should be completed and returned to privacy@corlytics.com or via post to:

NexusUCD,

Belfield Office Park,

Beech Hill Road,

Clonskeagh,

Dublin,

D04V2N9

ACCESS

If you have submitted personal information to CORLYTICS, under most circumstances you have the right to reasonable access to that data to correct any inaccuracies. You can also make a request to update or remove information about you by contacting privacy@Corlytics.com and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

DATA SECURITY AND INTEGRITY

CORLYTICS has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite CORLYTICS’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information. We also make reasonable efforts to retain personal information only for so long as the information is necessary to comply with an individual’s request or until that person asks that the information be deleted.

LINKS TO OTHER SITES

Please be aware that CORLYTICS web sites may contain links to other sites, including sites maintained by other CORLYTICS member firms that are not governed by this Privacy Statement but by other privacy statements that may differ somewhat. We encourage users to review the privacy policy of each Web site visited before disclosing any personal information.

CHANGES TO THIS STATEMENT

CORLYTICS may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how CORLYTICS is protecting your information.

POLICY QUESTIONS AND ENFORCEMENT

CORLYTICS is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personally identifiable information, please contact our Data Protection Officer at privacy@corlytics.com . You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.