PRIVACY NOTICE
SCHWARZ QUANT INVESTMENT BANK PRIVACY NOTICE
This privacy notice pertains to Samuel Lawrence Einzelunternehmer, Samuel Lawrence L.L.C., and its DBA Schwarz Quant Investment Bank. In this notice, “we,” “us,” and “our” refer to the Samuel Lawrence (Schwarz Quant Investment Bank) entities that handle your personal information.
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This notice applies to you if:
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You are a client or an investor in a fund or other investment product we manage or advise (a “Fund”).
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Your information has been provided to us or obtained by us in connection with a client or an investor in a Fund (e.g., you are an employee, agent, director, officer, partner, trustee, or direct/indirect owner (“Representative”) of a client or an investor in a Fund).
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You are a potential client or potential investor in a Fund, or a Representative of a potential client or potential investor in a Fund.
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You contact us or our affiliates by email, telephone, or any other means.
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You visit any website operated by us or our affiliates (a “Samuel Lawrence Website”).
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You are a Representative of a supplier, service provider, professional adviser, consultant, or business partner of ours or a Fund (“Service Providers”).
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You are a director, officer, or senior manager of a listed company in which we or a Fund may invest.
This notice, along with any applicable agreement between you and us, outlines the basis on which we use your personal information. It discloses information required under applicable privacy laws, including the European Union General Data Protection Regulation and the US law under Title V of the Gramm-Leach-Bliley Act of 1999. We are a data controller of your personal information.
Sources of Personal Information
We may use personal information from the following sources:
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Information provided by you via email, telephone, during meetings, or as part of an application for interests in a Fund.
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Information collected or generated in relation to an investment in a Fund by you or the entity you represent.
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Information collected or generated in relation to services we provide to you or the entity you represent.
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Information collected or generated in relation to services provided to us by the entity you represent.
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Information received from third parties, such as the entity you represent, administrators of Funds, background check providers, public agencies, and database or directory providers.
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Information collected using cookies and other technologies when visiting a Schwarz Quant Website.
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Information obtained from public sources, such as websites and regulatory filings.
Categories of Personal Information
We may use the following types of personal information:
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Personal Details: Name, title, addresses, telephone numbers, email addresses, date of birth, gender, citizenship, signature, photographs, and details about your employment and education.
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Financial Details: Information about your investments, income, assets, bank accounts, tax residency, and tax identification.
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Correspondence and Usage Data: Call recordings, website usage data, IP addresses, and location data.
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Know-Your-Client Information: Results of background screening checks, which may include information about your political opinions.
How We Use Personal Information
Schwarz Quant Investment Bank may use personal information to:
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Communicate with you and/or the entity you represent and retain records of such communication.
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Conduct business development and marketing activities, including providing information about Funds, our services, research, and events.
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Assess suitability for Funds and our services and carry out know-your-client procedures.
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Process and administer investments in Funds and manage our service appointments.
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Conduct due diligence on Service Providers and manage Service Provider relationships.
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Make decisions related to the Funds, our services, and our business strategy.
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Enter into contracts and perform contractual obligations.
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Meet legal, regulatory, or self-regulatory requirements applicable to us or our affiliates.
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Administer the Schwarz Quant Websites and ensure they are effectively presented for you and your computer or device.
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Respond to enquiries and complaints.
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For research and investment purposes regarding directors, officers, and senior managers of listed companies in which we or the Funds may invest.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis for such use.
Lawful Basis
We can only use your personal information when the law allows us to (i.e., there is a “lawful basis for processing”). The lawful basis will be one or more of the following:
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Contractual Necessity: When we need to perform a contract we have entered into with you.
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Legal Compliance: When we need to comply with EU or EU member state law.
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Legitimate Interests: When it is necessary for our legitimate interests (or those of our affiliates or Service Providers) and your interests and fundamental rights do not override those interests. Depending on the type of personal information, these legitimate interests include running day-to-day business operations; mitigating operational, financial, legal, tax, reputational, strategic, economic, and other risks; ensuring we remain a viable and competitive business; and complying with non-EU or non-EU member state law.
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Substantial Public Interest: In the case of sensitive personal information, such as the political opinions of a politically exposed person, the use will be necessary for reasons of substantial public interest.
Sharing Personal Information
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As a global business, we may share your personal information with our affiliates for the purposes outlined above. We may also share your personal information with third parties, including:
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Marketing Providers: To assist with the delivery of information to you or the entity you represent.
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Service Providers: For the performance of any contract we have entered into with you, the entity you represent, or the Service Providers.
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Analytics Providers: To assist in the improvement of the Schwarz Quant Investment Bank and Samuel Lawrence Websites.
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Administrators and Directors of Funds: In connection with investments in a Fund (or applications for interests in a Fund) by you or the entity you represent.
We may also share your personal information with third parties if:
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Business Transactions: We sell or buy any business or assets, making it necessary to share your personal information with the prospective seller or buyer.
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Acquisition: We are acquired by a third party, in which case your personal information will be one of the transferred assets.
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Legal Requirements: It is necessary to meet any legal, regulatory, or self-regulatory requirement that applies to us or our affiliates.
Security
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Your personal information is stored on secure servers, and access is limited in accordance with our information security policies and procedures.
International Transfers
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Our affiliates and third parties that receive your personal information may be based anywhere in the world, including countries outside the UK or the EU such as Australia, Hong Kong, The People’s Republic of China, United Arab Emirates, and the United States of America. These countries may not be subject to a decision by the German government or the European Commission that their laws provide an adequate level of protection for personal information. In such cases, we strive to ensure your personal information receives adequate protection, such as through German government or European Commission-approved standard data protection provisions, standard contractual clauses, or inter-governmental arrangements.
Retaining Your Personal Information
The length of time we hold your personal information varies. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we use the information, and applicable legal requirements. We may retain your personal information indefinitely to maintain a reasonable record of our dealings with you and to ensure we do not duplicate communications or contact you when you no longer wish us to do so. In some circumstances, we may anonymize your personal information so that it can no longer be associated with you, allowing us to use such information without further notice to you.
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Your Rights
You have the following rights regarding your personal information that we hold:
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Access: You may request details and a copy of your personal information that we hold.
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Rectification: You may request that we correct or complete any inaccurate or incomplete personal information.
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Erasure: You may request that we delete your personal information, although we may be legally entitled to retain it in some circumstances.
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Restriction: You may object to and request that we restrict our use of your personal information, although we may be legally entitled to continue using it or to refuse such requests in some circumstances.
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Direct Marketing: You may request that we do not use your personal information for direct marketing.
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Portability: For information you have provided to us, you may request that we provide it in a structured, commonly used, and machine-readable format and transfer it to a third party where technically feasible.
If you exercise your rights of erasure or restriction or refuse to provide certain personal information, we may not be able to provide services to you or the entity you represent, and you or the entity you represent may not be able to invest or continue to invest in a Fund. You will not have to pay a fee to exercise these rights except if your request for access is clearly unfounded or excessive, in which case we may charge a reasonable fee or refuse to comply.
Changes to This Notice
We may update this notice at any time and will post updates on the relevant Schwarz Quant Investment Bank or Samuel Lawrence legal entities websites. We may also notify you in other ways from time to time about our use of your personal information.
Third-Party Links
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Schwarz Quant Investment Bank or Samuel Lawrence legal entities websites may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave a Schwarz Quant Investment Bank or Samuel Lawrence legal entities website, we encourage you to read the privacy policy of every website you visit.
Contact and Complaints
If you have any questions about this notice or how we use your personal information, or if you wish to exercise any of your rights, please email info@schwarzquant.com
You have the right to make a complaint at any time to the Information Commissioner's Office, the German supervisory authority for data protection issues.