Contemi Solutions and its subsidiaries are committed to protecting personal data and respecting your privacy.

This privacy statement describes how we collect, use, share, protect, and otherwise process personal information about you. This statement applies to personal information that you provide to us:

• as a visitor to our websites or as a user of our client portals;
• when you send us personal information in connection with an inquiry about Contemi providing products and services directly to you;
• as a visitor to our premises; and
• as a contact at one of our clients, potential clients, suppliers or other business partners.

Notice to Customers of Contemi Clients
Where we collect personal information on behalf of our clients, Contemi acts as a “data processor” (as defined in the European General Data Protection Regulation (GDPR)) on behalf of its clients and this privacy policy does not apply.  Customers of our clients should consult directly with the applicable client to obtain a copy of the privacy policy issued by the client as “controllers”(as described in GDPR) which will apply in such instance.

What information do we collect from you?

We may collect and process the following information (personal data) about you:

• Information that you give us:
  • This includes information about you that you give to us by filling in forms on our website (or other forms that we ask you to complete), giving us a business card (or similar), or corresponding with us by telephone, post, email or other means.
  • It may include, for example, your name, address, email address, work telephone number, mobile telephone number, information about your business relationship with us, information about you necessary to complete anti-money laundering checks in order to comply with requirements relating to anti-money laundering and other legislation applicable to us; and information about your professional role, background and interests.
• Information that our website and other systems collect about you:
  • If you visit our website it will automatically collect certain information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and other information such as your browser type and version. We may also collect information about the pages on our site that you visit. Our website may also download "cookies" to your device – this is described in our separate cookie policy below.
  • If you email, telephone, write, or exchange other electronic communications with our employees and other staff members, our information technology systems will record details of those conversations and exchanges, sometimes including their content.
  • Some of our premises have closed circuit TV systems which may record you if you visit our premises, for security and safety purposes.
• Other information: We may also collect some information from other sources. For example:
  • If we have a business relationship with the organisation that you represent, your colleagues or other business contacts may give us information about you, such as your contact details or details of your role in the organisation that you represent.
  • We sometimes collect information from other third parties, which can include third party data providers, or from publicly available sources for anti-money-laundering, background checking and similar purposes, to protect our business and to comply with our legal and regulatory obligations.

Cookie Policy

We track user activity on our website by setting cookies on your browsers. These cookies are set in order to remember preferences when you return to our site, such as form field values. By continuing to browse the site, you are agreeing to our use of cookies.

Our website uses three types of cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. Further information about cookies and their purpose can be found by visiting: http://www.allaboutcookies.org/

We use the following first-party cookies:

• Session cookie
• Visitor cookie
• Opt In cookie

You can find more information about the individual cookies we use and the purposes for which we use them below:

• Session cookie: Session cookies allow us to identify your device as you use our website, so that you are not treated as a new visitor each time you access another part of the website; · Ensure that the servers we use to power the website, each serve an equal number of users; and · Help make user's browsing as quick and responsible as possible, noting your browser's capabilities.
• Visitor cookie: The visitor cookie includes the name “visitor_id” plus a unique identifier. The value stored is your unique ID, which allows us to remember your preferences when you return to our site and pre-populate form field values.
• Opt In cookie: Opt in cookies are set to ensure we are in compliance with the Do Not Track initiative. · The “Do Not Track” initiative began in an effort to prevent third party ad networks from gaining personal information across multiple websites without the consent of the individual whose activities are being tracked. Browsers with “Do Not Track” enabled, disallow someone’s activities on one site to be used to display targeted ads on another site. Some browsers, like Internet Explorer 10, enable “Do Not Track” by default.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Blocking cookies

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access parts of our site.

Duration of cookies

Except for essential cookies, all cookies will expire after 10 years.

How will we use your information?

We may use your information for the following purposes:

• to personalise and customise your experience with us; conduct research and analysis; and fulfil orders and requests for products, services, or information from you or the organization that you represent.
• to send you marketing communications regarding our products and services.
• for ordinary business purposes, including to operate and administer the products and services provided by Contemi Solutions in accordance with the terms of any agreements that we may have with our clients.
• to operate, administer and improve our website and premises and other aspects of the way in which we conduct our operations.
• to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes.
• to comply with our legal and regulatory obligations, and to bring and defend legal claims where the information is pertinent (including to allow us to pursue available remedies or limit the damages that we may sustain).
• to comply with our internal policies and maintain our records or as otherwise required by applicable data protection laws.
• to respond to requests from our clients that are not already addressed above.

We may from time to time be required to review information about you held in our systems – including the contents of and other information related to your email and other communications with us – for compliance and business-protection purposes as described above.

This may include reviews for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations.

To the extent permitted by applicable law, these reviews will be conducted in a reasonable and proportionate way, and approved at an appropriate level of management. They may ultimately involve disclosure of your information to governmental agencies and litigation counterparties as set out below.

Your emails and other communications may also be accessed occasionally by persons other than the member of staff with whom they are exchanged for ordinary business management purposes (for example, where necessary when a staff member is out of the office or has left our organisation).

We will only process your personal information as necessary to pursue the purposes described above.

In exceptional circumstances, we may also be required by law to disclose or otherwise process your personal information.

We will tell you, when we ask you to provide information about yourself, if:

• provision of the requested information is necessary for compliance with a legal obligation, or
• it is purely voluntary and there will be no implications if you decline to provide the information.

If you are uncertain as to Contemi’s need for information that we request from you, please contact us at info@contemi.com for more information.

Disclosure and international transfer of your information

We may disclose personal information about you, in accordance with the various legitimate purposes set out above:

• to the other legal entities within Contemi Solutions.
• if we receive the personal information from you as a representative of one of our business partners or clients, to your colleagues within the organisation that you represent.
• to third party service providers who host our website or other information technology systems or otherwise hold or process your information on our behalf, under substantially similar conditions of confidentiality and security.
• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
• in connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of a business or operating unit; in accordance with our legal obligations, including to competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory or where we are otherwise required by law to disclose.

These disclosures may involve transferring your personal information overseas. If you are dealing with us within the European Economic Area (or the UK, after it has left the European Economic Area), you should be aware that this may include transfers to countries outside the European Economic Area / UK, which do not have similarly strict data privacy laws and which may therefore afford a lower standard of personal data protection. In those cases, where we transfer personal data to other legal entities within Contemi or our service providers, we will ensure that our arrangements with them are governed by data transfer agreements, designed to ensure that your personal information is protected, on terms approved for this purpose by the European Commission.

How we keep your personal information safe?

We are committed to protecting your personal information submitted to us. We maintain an information security program including internal policies addressing the acceptable use and access to confidential business information and personal information which may be contained within Contemi’s information systems. We maintain physical, electronic and procedural safeguards reasonably designed to guard personal information from loss, misuse or unauthorized access, disclosure, alteration or destruction of the information that has been provided to us through our on-line services.

Contact us

We welcome questions, comments and requests regarding this privacy policy and our processing of personal information. Please email us at info@contemi.com

To make a request for the disclosures or deletion, please email is at info@contemi.com

We will respond to your request consistent with applicable data protection laws.   Depending upon the type of business relationship that you have with us, we may need to notify you that additional information is necessary to authenticate your identity for your data security or that we will refer your inquiry to the financial services entity that holds the primary relationship with you.

For requests to delete your personal information as permitted under applicable data protection laws, we will work with you to accomplish your requests unless otherwise exempted under applicable data protection laws, such as compliance with applicable law or regulatory inquiry.

Changes to this policy

Any changes we make to this privacy policy in the future will be posted to our website. Please check back frequently to see any changes.