Privacy Policy

Introduction

Welcome to Eldin Risk’s privacy policy.

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1 Important Information and Who We Are

Purpose of this privacy policy
This privacy policy aims to give you information on how Eldin Risk collects and processes your personal data in the context of Eldin Risk’s provision of its insurance mediation services to your business, through your use of this website and through any other ways we interact with you, as set out in more detail in Paragraph 3 below.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy, together with any other privacy notice or policy (or fair processing notice or policy) we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.

About us

Eldin Risk is an insurance mediation services provider authorised and regulated by the Financial Conduct Authority (number 991402).

Eldin Risk is the controller of and is responsible for your personal data (collectively referred to as "Eldin Risk", "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Eldin Risk Partners Limited

Email address: SJ@EldinRisk.com

Postal address: 14 Curzon Street, London, England, W1J 5HN

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 7th June 2023].

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links    

This website 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 but encourage you to read them when you visit the relevant site.

2 The Data We Collect About You    

For Eldin Risk to provide insurance mediation services, we may need to collect, retain and process certain personal data about the company and/or your employees.    
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).  

We may collect, use, store and transfer different kinds of personal data about you providing insurance mediation services. We have grouped the personal data together as follows:

· Identity Data includes name, title, job title, and employer details.    
· Contact Data includes address, email address and telephone numbers.    
· Financial Data includes bank account details and sanctions checks.    
· Risk Data includes information about your company which we and other market participants need to collect to assess the risk to be insured and provide a quote.    
· Claims Data includes information about your company's previous and current claims (including other unrelated insurances), which may include personal data.    
· Usage Data includes information about how you use our website, products and services.    
· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.  

In some cases, companies seeking to use our services may be required to share the Identity and Contact Data of certain employees. This personal data will be processed for the purpose of establishing a client relationship and general service of the client account (as set out in the table below). We will process this personal data on the ground of legitimate interests.  

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We do not collect any information about criminal convictions and offences.

If you fail to provide personal data  

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3 How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:  
· Direct interactions. You may give us your Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:    

• apply for our products or services;    
• subscribe to our service or publications;    
• request marketing to be sent to you;  
• enter a competition, promotion or survey; or    
• give us feedback or contact us.    

· Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:  

· Identity, Financial and Risk Data from credit reference and fraud prevention agencies, and courts.  
· Identity and Contact Data from financial databases such as Pitchbook.    
· Identity and Contact Data of portfolio managers from investors.    

4 How We Use Your Personal Data    
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:  

· Where we need to perform the contract we are about to enter into or have entered into with you.  
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.    
· Where we need to comply with a legal obligation.  

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.    

Purposes for which we will use your personal data    

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.  

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.  

We may share your personal data with the parties set out below for the purposes set out in the table below.    

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.  

 Your personal data will never be sold on to external parties or organisations for marketing purposes.

Purpose/Activity Lawful basis for processing including basis of legitimate interest Possible third party disclosures
Quotation and inception
(a) Establishing a client relationship (b) To evaluate, process and complete your requests and/or applications for our products and services (c) For security and verification of your identity (d) Performing credit or money laundering checks or other checks required by law (a) Performance of a contract with you (b) Complying with a legal obligation (c) Legitimate interest (to manage client relationship and to confirm client is within risk profile) (d) Substantial public interest (prevention of crime) (a) Regulators (b) Insurers/Reinsurers (c) Anti-fraud databases, sanctions lists, court judgments and other databases (d) Credit reference agencies (e) Insurance intermediaries (f) Insurance broking platform administrators/advisers
Throughout our contract
(a) General servicing of the client account, including communication with you and sending you updates (b) To update our records (c) Complying with our regulatory and legal obligations (d) Investigating fraud and preventing financial crime (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us and to keep our records updated and to assist with the detection and prevention of fraud) (a) Regulators (b) Insurers/Reinsurers (c) Courts and lawyers (d) Legal enforcement agencies (e) Auditors
Relationship management
(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to study how customers use our products/services)
Renewals
(a) Contacting our clients to aid in renewing their insurance policy. (a) Performance of a contract with you (b) Legitimate interest (to assist client in assessing and making claims, and to assist with the detection and prevention of fraud) (a) Insurers/Reinsurers (b) Insurance intermediaries
Business and website activities
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation (a) IT service providers


Marketing    
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.    

Promotional offers from us    
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).    

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.  

Opting out  
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.  

Cookies  
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of websites may become inaccessible or not function properly. We only use strictly necessary cookies on our website which are essential for the website to function properly.  

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.  

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.  
 
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.    

5 International Transfers  

We do not transfer your personal data outside the UK.  

6 Data Security  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.  

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.  

7 Data Retention    

How long will you use my personal data for?    
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.    

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.    

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

8 Your Legal Rights
 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you'd like to learn more about your rights, please see the website of the Information Commissioner's Office.

You generally have the following rights, which you can usually exercise free of charge:    
• Request access to your personal data.    
• Request correction of your personal data.    
• Request, in certain circumstances the erasure of your personal data.    
• Object to processing of your personal data.    
• Request restriction of processing your personal data.    
• Request, in certain circumstances, personal data in an accessible and machine-readable format.  
• Right not to be subject to decisions without human involvement.  


If you have provided us with a consent to use your personal data, you have a right to withdraw that consent easily at any time. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.

If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above or have any other queries or concerns, please don't hesitate to contact us at: SJ@EldinRisk.com.    

No fee usually required  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.  

What we may need from you    
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.    

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


US PRIVACY POLICY    
ELDIN RISK PARTNERS, INC.        
 
Effective Date: June 1, 2023  

I.  Introduction

Our Website Privacy Policy (the “Policy”) explains how Eldin Risk Partners, Inc. (“ERP” or “we”, “our”, “us”) collects, uses, shares, and processes personal information that we collect through this website (www.eldinrisk.com) and through associated ERP content (the “Website”). Your use of our Website and the personal information you provide to us is your acknowledgement and agreement that you give us permission to process your personal information as described in this Policy. Please note that this Policy does not apply to personal information that we collect outside of the Website.  

By accessing the Website, you are indicating your understanding and agreement to the Policy. We reserve the right to modify the Policy at any time, without notice.

If you are a California resident, you may obtain additional information about our privacy practices and your rights in our California Privacy Notice, which can be found below.        

II. Information ERP May Collect      

Information You Provide Directly to Us. When you use our Website, you may choose to provide certain personal information that can be used to identify you.  This includes your name, contact information, and professional information, such as your employer, position, and location. By way of example, ERP collects your personal information when you subscribe to receive our alerts and communications, register for one of our events, or contact us with questions. Please note that by submitting personal information on behalf of someone else, you are representing that you have that individual’s permission to submit their personal information to us.        

Information Collected Automatically. ERP automatically collects certain personal information about you when you access or use our Website by using various tools and technologies. This may include cookies, web server logs, and other tracking technologies. Automatically collected information may include information about visitors to our Website and how they use our Website, including their IP addresses, device identifiers, browser characteristics, operating system details, referring URLs, and the pages or content viewed while visiting our Website. We may use the following technologies to collect information about our visitors automatically:    

i.  Cookies: Cookies are small data files that your web browser stores on your computer. These can allow us to recognize the device being used by a visitor to our Website, record that visitor’s preferences, track the Website pages visited, and identify the referring website.    

ii. Log Information: Log information is a recording of data about your use of our Website. This can include your IP address, the type of browser you use, your internet service provider, the referring and exiting webpages, the operating system you use, date and time stamps, and associated data, that may be stored in log files.    

iii.  Other Tracking
Technologies: Web beacons are small graphic images, also known as Internet tags or clear gifs that may be embedded in web pages and email messages. Web beacons may be used to monitor the number of visitors to a website, to track how users navigate a website, or to count how many emails were actually opened or specific pages or links were actually viewed. An embedded script is programming code designed to collect information about a visitor’s interactions with a website. Typically, the script is temporarily downloaded onto a computer from the host website’s server (or the server of a third-party service provider) and is active only while the visitor is connected to the website, then deleted or deactivated thereafter.  

Most web browsers accept cookies by default.  However, you may be able to adjust your browser settings to remove or reject cookies. Our Website uses both session ID cookies and tracking cookies. Session ID cookies make it easier for you to navigate the Website and expire when you close your browser. Tracking cookies help us understand how you use the Website and enhance your user experience. Please note that blocking cookies on our Website may affect the availability and functionality of the Website and other websites. Also, disabling cookies may invalidate opt-outs that use cookies to recognize devices that have opted out.  

Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. This sends a signal to a website that you do not want the website operator to track certain browsing information about you. Like many websites, our Website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, visit www.allaboutdnt.com.    

We use third-party analytics services to help us understand and analyze how our visitors use the Website. We have implemented Google Analytics Advertising features such as interest-based advertising, behavioral reporting, demographics and interests reporting, user segment analysis, and device reporting. We and our vendors may use first-party cookies or other first-party identifiers as well as third-party cookies or other third-party identifiers to deliver advertisements, create a profile of you, measure your interests, detect your demographics and location, identify your device, and personalize content.

ERP is not responsible for the privacy policies or practices of any third parties, including our vendors providing analytics and other tracking technologies associated with our Website. We encourage you to familiarize yourself with their privacy policies and other provided information.      

III.  Information We Collect From Other Sources  

 We may combine information that we collect about you on our Website, including information collected automatically, with information we obtain from others. To the extent we combine information that we collect automatically or that we obtain from others with personal information you provide to us, we will treat the combined information as personal information in accordance with this Policy. When you submit information to another party, you are solely subject to that party’s terms of use and privacy policies. ERP is not responsible or liable for the accuracy of the information provided by other parties or for third-party policies or practices.        


IV. How We Use Personal Information  

We may use personal information we collect through the Website for various purposes including: communicating with you, including responding to your requests or inquiries; marketing and advertising our services and expertise; improving our Website and our visitors’ online experience, including tailoring our content; preventing, investigating, identifying, or taking any other action regarding any suspected or actual fraudulent or illegal activity or other activity that violates our policies; complying with applicable laws, rules, regulations, and legal processes as well as our company policies; monitoring and analyzing trends, usage, and activities of Website visitors; and any other purposes, as allowed by law or with your consent.        

V.  Information We Share With Others

We may share your personal information with our business partners and vendors providing services on our behalf. We may also share your personal information as follows: to comply with the law, law enforcement, other legal process, or in response to a government request; for any purpose disclosed at the time you provide your information; in connection with any proposed or actual business transaction, including business financing; merger, purchase, sale, or any other type of acquisition or transaction; or a transfer of all or a portion of our assets or business; with your consent or at your direction; to prevent or detect fraud and other violations of the law and our policies; to protect rights, property, life, health, security, and safety; and for any other purpose consistent with our statements in this Policy or otherwise allowed by applicable law.        

VI. Links to Other Websites  

Our Website includes links to websites operated by other companies. This Policy does not apply to other companies’ websites, which may have their own privacy policies or notices that you should review to understand how they may collect, use, or disclose your personal information. When you follow other companies’ links, you may be subject to the cookies and other tracking technologies used by those companies, which may independently collect information about you. The other companies also may solicit personal information directly from you. ERP is not responsible for the content or privacy practices of any linked websites that it does not control.  

Certain features of our Website may permit you to initiate interactions between ERP and other platforms like social networks operated by unaffiliated companies. If you choose to “like” or share content or other information on a social media platform, that information may be publicly displayed, and the company operating the other platform may receive information about you and your use of our Website. Similarly, if you interact with us through social media, we may have access to information about you from the social media platform. Please note that if you mention ERP, or comment about or in response to us, in your post on a social media platform, that platform may allow us to publish your post on our Website. In addition, we may receive information about you when that information is accessible through another user’s social media. For example, if a user on a social media platform gives us access to their profile and connections, and you are a connection of that user, we may be able to obtain information about you. You should review the terms, policies, and settings of any social media platforms you use to learn more about their data practices and/or adjust your privacy settings.    

VII.  Data Security
ERP takes measures to protect the personal information we collect. Nevertheless, transmission via the internet and other online interactions are not completely secure, and ERP cannot guarantee the security of your personal information collected through our Website. Any transmission of information is at your own risk.        

VIII. Your Choices  

Analytics and Advertising Tracking Technologies.
You may exercise choices regarding the use of cookies from Google Analytics by going to     https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may exercise choices regarding the use of cookies from Adobe Analytics by going to http://www.adobe.com/privacy/opt-out.html under the section labeled “Tell our customers not to measure your use of their web sites or tailor their online ads for you.” You may also limit some interest-based advertising by submitting opt-outs. Some of the advertisers and vendors that perform services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of cross-device data for serving ads, visit http://www.aboutads.info/choices/. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based advertising to you but does not mean you will no longer receive any targeted content or ads. If your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, if you use a different device or web browser or use a non-browser-based method of access, your NAI / DAA browser-based opt-out may not, or may no longer, be effective.  

Email Communications. You can opt out of receiving email communications from ERP at any time by following the instructions provided in emails to click on the unsubscribe link. If you opt out of only certain communications, other subscription communications may continue. Please note that your opt-out is limited to the email address used and will not affect subsequent subscriptions. Please note that even if you opt out of receiving marketing communications, ERP may continue to send you non-marketing communications, such as communications about events you have signed up to attend, information you explicitly request, or your business relationship with ERP.  

IX. Information For Visitors From Outside the United States    
ERP is based in the United States and governed by U.S. law. If you are accessing our Website from outside of the United States, please be aware that personal information collected through the Website will be processed in the United States. Data protection laws in the United States are likely different from those of your country of residence. By submitting your personal information through our Website, you acknowledge that your personal information will be processed in the United States in accordance with this Policy. Visitors residing outside the United States may contact us at Privacy@EldinRIsk.com for more information about our data practices.        

X.  Information For Visitors From California and Nevada

California residents may obtain additional information about our privacy practice and their rights in our California Privacy Notice, available below.    

We do not “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes.  Nevertheless, you may contact us and register an email address, so that we can provide you notice and the opportunity to opt out in the event we should do so in the future. It is your responsibility to keep your email contact information current.        

XI. Children's Privacy

The Website and the nature of our services are not intended or designed to be used by any individual under the age of 13 years. We do not knowingly collect or maintain any information about any individual under the age of 13. If you are under the age of 13 years old, you should not register with the Website, subscribe to any of our newsletter services, or provide any personally identifiable information to us. If you are concerned about your child’s use of the Website, you may use web-filtering technology to supervise or limit access to the site.      

XII.  Disclaimer  

UNDER NO CIRCUMSTANCES SHALL ERP HAVE ANY LIABILITY WHATSOEVER FOR ANY ERRORS OR OMISSIONS IN INFORMATION ON THE WEBSITE, OR FOR ANY DAMAGES, LOSSES, OR EXPENSES THAT MAY OCCUR WHILE ACCESSING THE WEBSITE, OR ANY LINKED SITE, OR THE INABILITY TO ACCESS THE WEBSITE; OR ANY FAILURE OF PERFORMANCE, ERROR, OMISSION, INTERRUPTION, DEFECT, DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS OR LINE OR SYSTEM FAILURE; OR ANY CONSEQUENTIAL, INCIDENTAL, INDIRECT OR SPECIAL DAMAGES ARISING OUT OF THE BREACH OF THIS POLICY, HOWEVER OCCASIONED.        

XIII. Changes To This Policy

This Policy is subject to change at our discretion. We will indicate changes to this Policy by updating the Effective Date. Your continued use of this Website after any update to this Policy will constitute your acceptance of our changes.        

XIV.  Contact ERP
If you should have any questions about this Policy, please contact us using one of the methods below:
By email:   info@EldinRisk.com    
By phone: +44 (0)20 3667 2970        
By mail:  Eldin Risk Partners, Inc.
The Chrysler Buildling
405 Lexington Avenue
NY 10174  



ELDIN RISK PARTNERS, INC. CALIFORNIA PRIVACY NOTICE  
We here at Eldin Risk Partners, Inc. (“ERP”) take data privacy seriously. We are committed to safeguarding the privacy and security of personal information that we collect from visitors to our Website and those for which we provide legal services.    

Please visit our PRIVACY POLICY, and if you are a California resident and the California Consumer Privacy Act applies to you, this California Consumer Privacy Notice (“Privacy Notice”) is for you.    

As you will see, our Privacy Notice is designed to help you understand our practices surrounding how we collect, use, and disclose data by detailing:    
• how we collect personal information about you    
• what personal information we collect about you    
• our purposes for collecting that personal information    
• the categories of third parties with whom we share or disclose that personal information  
• our data retention practices    
• how we protect your personal information    
• your rights when it comes to your personal information    
• our use of cookies and other tracking technologies    
• our updating of this Privacy Notice    
• how to contact us    

By providing your personal information to us through our Website, by email, by phone, or in person, you agree to the processing of your personal information as detailed in this Privacy Notice.    

This Privacy Notice applies only to ERP and we are not responsible for any third-party websites that are accessible using links from our Website. If you click on a link to a third-party website, they should have their own privacy policies or notices that you should check before submitting any personal information through those third-party websites.  

 1. Personal Information: Collection / Purpose / Disclosure & Sharing / Retention  

We may collect and have collected the following categories of personal information from California consumers within the last twelve (12) months:

Categories of Personal Information ERP May Collect, Disclose, or Share Our Purpose for Collecting or Using Your Personal Information California Residents to Whom This Applies Categories of Third Parties to Whom Personal Information May be Disclosed or Shared Retention Period
Identifiers (e.g., name, contact details, and other demographic information) Communicating with you; marketing our services; performing services and assuring payment for those services; research and development; quality assurance and improvement; physical and virtual security; to comply with a legal obligation. Employees, Clients, Website Visitors, Prospective Employees, Service Providers Service providers, and government/law enforcement when necessary. As long as necessary to fulfill the purpose(s) for which we collected your personal information, including for the purpose of satisfying legal, regulatory, accounting or auditing requirements.
“Personal Information” as defined by California Customer Records Statute Communicating with you; marketing our services; performing services and assuring payment for those services; research and development; quality assurance and improvement; physical and virtual security; to comply with a legal obligation. Employees, Clients, Website Visitors, Prospective Employees, Service Providers Service providers, and government/law enforcement when necessary. As long as necessary to fulfill the purpose(s) for which we collected your personal information, including for the purpose of satisfying legal, regulatory, accounting or auditing requirements.
Protected classification characteristics under California or federal law Performing services; research and development; quality assurance and improvement; physical and virtual security; to comply with a legal obligation. Employees, Website Visitors, Prospective Employees Service providers, and government/law enforcement when necessary. As long as necessary to fulfill the purpose(s) for which we collected your personal information, including for the purpose of satisfying legal, regulatory, accounting or auditing requirements.
Commercial information Communicating with you; marketing our services; performing services and assuring payment for those services; research and development; quality assurance and improvement; physical and virtual security; to comply with a legal obligation. Clients and Service Providers Service providers, and government/law enforcement when necessary. As long as necessary to fulfill the purpose(s) for which we collected your personal information, including for the purpose of satisfying legal, regulatory, accounting or auditing requirements.
Sensitive Personal Information including certain financial information Communicating with you; marketing our services; performing services and assuring payment for those services; research and development; quality assurance and improvement; physical and virtual security; to comply with a legal obligation. Employees, Clients, Website Visitors, Prospective Employees, Service Providers Service providers, and government/law enforcement when necessary. As long as necessary to fulfill the purpose(s) for which we collected your personal information, including for the purpose of satisfying legal, regulatory, accounting or auditing requirements.
Biometric information Normal business operations, including identity verification for network access, and health or exercise data if volunteered by you. Employees, Service Providers Service providers, and government/law enforcement when necessary. As long as necessary to fulfill the purpose(s) for which we collected your personal information, including for the purpose of satisfying legal, regulatory, accounting or auditing requirements.
Internet or other similar network activity Communicating with you; marketing our services; performing services and assuring payment for those services; research and development; quality assurance and improvement; improving our Website; physical and virtual security; to comply with a legal obligation. Employees, Clients, Website Visitors, Prospective Employees, Service Providers Service providers, and government/law enforcement when necessary. As long as necessary to fulfill the purpose(s) for which we collected your personal information, including for the purpose of satisfying legal, regulatory, accounting or auditing requirements.
Geolocation Data Marketing our services; performing services and assuring payment for those services; research and development; quality assurance and improvement; improving our Website; physical and virtual security. Employees, Website Visitors, Service Providers Service providers, and government/law enforcement when necessary. As long as necessary to fulfill the purpose(s) for which we collected your personal information, including for the purpose of satisfying legal, regulatory, accounting or auditing requirements.
Audio, electronic, visual, thermal, olfactory, or similar information (i.e., sensory data) Marketing our services; performing services; research and development; quality assurance and improvement; physical and virtual security; to comply with a legal obligation. Employees, Clients, Prospective Employees, Service Providers Service providers, and government/law enforcement when necessary. As long as necessary to fulfill the purpose(s) for which we collected your personal information, including for the purpose of satisfying legal, regulatory, accounting or auditing requirements.
Professional or employment-related information Communicating with you; marketing our services; performing services and assuring payment for those services; research and development; quality assurance and improvement; physical and virtual security; to comply with a legal obligation. Employees, Clients, Prospective Employees, Service Providers Service providers, and government/law enforcement when necessary. As long as necessary to fulfill the purpose(s) for which we collected your personal information, including for the purpose of satisfying legal, regulatory, accounting or auditing requirements.
Non-public education information Performing services; quality assurance and improvement. Employees, Clients, Prospective Employees, Service Providers Service providers, and government/law enforcement when necessary. As long as necessary to fulfill the purpose(s) for which we collected your personal information, including for the purpose of satisfying legal, regulatory, accounting or auditing requirements.
Inferences from personal information Marketing our services; performing services and assuring payment for those services; research and development; quality assurance and improvement; physical and virtual security. Employees, Prospective Employees Service providers, and government/law enforcement when necessary. As long as necessary to fulfill the purpose(s) for which we collected your personal information, including for the purpose of satisfying legal, regulatory, accounting or auditing requirements.


We may also use, disclose or share yourpersonal information as described to you at the time we collect your personalinformation; as otherwise set forth in the CCPA; to evaluate or conduct amerger, divestiture, restructuring, reorganization, dissolution, or other saleor transfer of some or all of our assets, whether as a going concern or as partof bankruptcy, liquidation, or similar proceeding, in which personal informationheld by us is among the assets transferred. Please note that we will notcollect additional categories of personal information or use the personalinformation we collected for materially different, unrelated, or incompatiblepurposes without first providing you with notice.

2. How we obtain the personal data aboutyou

We may collect or obtain your personalinformation, as follows: when you provide it to us; as we monitor the use of,or interactions with, our Website, any marketing email we may send to you, orother communications sent from or received by us; from third-parties; or, frompublicly available sources.  

3. Retention
We retain data in accordance with ourrecord retention program. How long we retain data depends on the following: (i)the length of time we have an ongoing relationship with you and provide theWebsite or legal services to you; (ii) whether there is a legal obligation thatwe are subject to comply with; or (iii) whether retention is required due toour legal position.

The time periods listed in the chart aboveare based on the longest period we need to keep a category of our records thatmay contain a category of personal information. When we no longer need toretain your personal information, we promptly destroy it pursuant to our recordretention program, unless a legal obligation to continue to retain that dataapplies.

4. Who we share your personal informationwith

Any personal information that we obtain, oryou provide to us directly, may be shared and processed by us.

We may also share your personal informationwith the following categories of third parties: our professional consultants;ERP’s insurers, insurance brokers, and employee benefits providers andconsultants; third-party service providers; and third-party external advisorsor experts engaged in the course of the services we provide to our clients andwith their prior consent, such as local counsel, experts, and legal technologyservice providers.

We may also process your personal data to comply withvalid government subpoenas or other legal process. Before complying, wherepossible, we will provide you with notice so that you may object

5. How we protect your personal data

ERP takes measures to protect the personalinformation we collect. Nevertheless, transmission via the internet and otheronline interactions are not completely secure, and ERP cannot guarantee thesecurity of your personal information collected through our Website. Anytransmission of information is at your own risk.

Where we have given you credentials whichenable you to access certain parts of our Websites or computer system, you areresponsible for keeping these credentials confidential and for complying withany other security procedures that we notify you of. We ask you not to shareyour credentials with anyone.

6. What rights you have in relation toyour personal data

You have the right to request us to:

- Disclose if we have collectedpersonal information about you (you may only make two requests in a 12-monthperiod, and the information provided need only cover the 12-month period priorto your request)
- Disclose the categories ofpersonal information that we have collected on you (if any); the categories ofsources from which the personal information is collected; the business or commercialpurpose for collecting or selling personal information; and the categories ofthird parties with whom the business shares personal information (you may onlymake two requests in a 12-month period, and the information provided need onlycover the 12-month period prior to your request)
- Disclose the specific pieces ofpersonal information that we have collected about you (if any) (you may onlymake two requests in a 12-month period, and the information provided need onlycover the 12-month period prior to your request)
- Delete personal information wehave collected about you (if you satisfy the conditions set out in the CCPA);and
- Correct inaccurate personalinformation that we maintain about you.


Under certain circumstances and inaccordance with applicable data protection laws you have the right to requestthat we disclose to you what information we collect, use, disclose, share, and sell.

We do not offer a right to opt-out of thesale or sharing of your personal information, because within the meaning of the CCPA, we have not sold or shared personal information to any third party withinthe last twelve months.

We do not offer a right to limit the use ordisclosure of sensitive personal information because, within the meaning of the CCPA, we do not use sensitive personal information for inferringcharacteristics.

To submit any of the above requests, youmay call toll-free [INSERT]. You may also submit via email at Info@EldinRIsk.com for assistance. Pleasenote for your protection, certain requests sent to us will be subject to averification procedure that may require you to provide us with informationabout you that we have in our files.

We may have disclosed your information asdescribed above during the preceding 12 months, but we do not sell yourpersonal information.

We do not have actual knowledge that wesell the personal information of minors under 16 years of age. You may designate an authorized agent tomake a request to exercise your rights on your behalf.

For your protection, wereserve the right to deny any request from an agent who does not submit proofthat they have been authorized to act on your behalf. You can exercise yourright to stop email marketing messages from us at any time by using anunsubscribe facility or contacting us at Info@EldinRIsk.com.

If you contact us to exercise any of theserights we will check your entitlement to your request and respond in most caseswithin 45 days.

We shall not discriminate against you forexercising any of your above rights

7. How we use cookies and tracking technologies
Please see our Privacy Policy for an explanation of how we use cookies and tracking technologies.

Because we link to social media sites, andfrom time to time may include third-party advertisements, other parties maycollect your personally identifiable information about our online activitiesover time and across different websites when you visit this Website.

Please note that not all tracking will stopeven if you delete cookies

8. How you can contact us
If you are a California resident who hasprovided personal information to us, you may exercise your rights under theCCPA and submit your requests via one of the following methods:

Call us at +44 (0)203667 2970E
-mail us at  Info@EldinRisk.com

or
Write to us at:
Eldin Risk Partners, Inc.
The Chrysler Building
405 Lexington Ave
NY 10174

If you are an employee or prospectiveemployee, and you have any concerns or questions about how we have processedyour personal information, please first raise your issue with Human Resources.If Human Resources is unable to resolve your issue, we invite you to use thecontact information above.

9. Updates to this Privacy Notice
We may change the content of our Websiteand how we use tracking technologies without notice and consequently thisPrivacy Notice may change from time to time in the future. Therefore, we askthat you review them when you visit the Website to stay informed of how we areusing personal information.

 In the event of any conflict with ourgeneral Privacy Policy, this Privacy Notice will take precedence. 

Effective Date: 01 June 2023