Privacy Policy

Introduction:

Martello Advisory is (“Martello Advisory” or “we”) an Irish company providing professional services such as independent  director and strategic advisory services to the investment management industry (the “Services”). This Privacy Statement outlines our general policy and practices for protecting personal information that we collect through our Web site at www.martello-advisory.com (a “Site”) that we operate and in connection with the provision of the Services. This Privacy Statement explains the types of information we gather through our Site and in connection with our Services, how we use that information, and the choices individuals may exercise regarding our use of, and their ability to correct, that information. Any consent you provide is entirely voluntary. If you do not accept this Privacy Statement, then you should not submit any personal information to Martello Advisory through this Site or in connection with Services.

Martello Advisory is committed to complying with the applicable data privacy and security requirements in the countries in which it operates. Martello Advisory complies with internationally recognised standards of privacy protection, and with various privacy laws globally including, but not limited to, the EU General Data Protection Regulation (GDPR). This Privacy Notice applies when providing valuation, corporate finance, real estate advisory, disputes and investigations, compliance and regulatory support services, or other services (the “services”) to its customers.

Who is collecting data?  Martello Advisory.

Data We Collect

Martello Advisory collects the following categories of personal data:

Contact data: We may collect information about data subjects such as name and contact details (email, phone number, etc.) in order to communicate and facilitate the provision of our services with our clients or potential clients. For example, contact details of individuals who work for or on behalf of the clients, in order to carry out the client’s engagement with Martello Advisory.

Services data: Personal data may be provided to us by clients to the extent required to perform the services. Martello Advisory may also acquire personal data from a third party at the direction of our client as required to perform services.

Marketing information: We may collect information to respond to inquiries regarding our products and services or to provide you with information, reports, or updates.

Website visitor information: when you visit our website, we may collect information about your visit such as your IP address and the pages you visited and when you use our services we may collect information on how you use those services. Please see our Website Use and Cookies Policy for additional information.

Clients and other Third parties who provide personal information to Martello Advisory must do so in compliance with applicable data privacy regulations.

How we collect data

We collect personal data to offer and administer our services and products. These include valuation, corporate finance, real estate advisory, disputes and investigations, and compliance and regulatory support services.

The data you provide to us will be processed in accordance with the purposes specified in this notice, namely:

To provide the products or perform the services requested by clients and individuals pursuant to a letter of engagement, statement of work, or similar (where the processing is necessary for our legitimate business interests in conducting and managing our business)

To provide the products or perform the services requested by clients and individuals using our website or web applications (where the processing is necessary for our legitimate business interests in conducting and managing our business)

For complying with obligations provided by laws, current regulations and European legislation (e.g. tax regulations) (where processing is based on a legal obligation)

For legitimate business purposes to advise you through e-mail, phone call, or post, in the framework of our ordinary commercial relationship, about other products or services similar to the products or services we have provided to you and that we think will be of interest to you (where the processing is necessary for our legitimate business interests)

For marketing purposes. For example, we may use your information to further discuss your interest in the Services and to send you information regardingMartello Advisory such as information about promotions, events, products or services.

If you are located in the EU, we will only send you marketing communications and updates about our products, services and events with your prior consent. You can withdraw your consent at any time.

If you are not located in the EU, you may opt-out of receiving marketing communications and updates at any time.

You can manage your receipt of marketing and non-transactional communications by clicking on the «unsubscribe» link located on the bottom of Martello Advisorys marketing emails. Additionally, you may send a request to killian.buckley@martelloadvisory.com

For improving D&P’s communications with you. Emails sent to you by D&P may include standard tracking, including open and click activities. Martello Advisory may collect information about your activity as you interact with our email messages and related content.

For operating and improving D&P’s website and your customer experience. For example, we may collect and analyse data on your use of our website and process it for the purpose of improving our online experience. Please see our Website Use and Cookies Policy for additional information.

 For security purposes. For example, we may use your data to protect Martello Advisory and its third parties against security breaches and to prevent fraud and violation of Martello Advisory’s applicable agreements (where the processing is necessary for our legitimate business interests).

Whenever we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You have the right to object to this processing if you wish.

How data is processed

Personal data is processed both manually and electronically in accordance with the above-mentioned purposes and in compliance with current regulations. We permit only authorised Martello Advisory employees and Third-Party processors to have access to your information. Such employees and Third-Party processors are appropriately designated and trained to process data only according to the instructions we provide them.

Storage of Personal Data

Martello Advisory will retain personal data for a reasonable period, taking into account legitimate business needs to capture and retain such information. Information will also be retained for a period necessary to comply with state, local, federal regulations, or country specific regulations and requirements, and in accordance with Martello Advisory’s Document Retention Schedule.

Disclosure/Sharing of Personal Data

We only share your personal data with your consent or in accordance with this policy. We will not otherwise share, sell or distribute any of the information you provide to us except as described in this Privacy Notice.

We share personal data amongMartello Advisory controlled affiliates and subsidiaries who act for Martello Advisory for the purposes set out in this notice.

Martello Advisory may share your information with external third parties, such as vendors, consultants and other service providers who are performing certain services on behalf of Martello Advisory. Such third parties have access to personal data solely for the purposes of performing the services specified in the applicable service contract, and not for any other purpose. Martello Advisory requires these third parties to undertake security measures consistent with the protections specified in this notice.

Martello Advisory may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

If Martello Advisory’s business enters into a joint venture with or is merged with another business entity, your information may be disclosed to our new business partners.

You have the following rights concerning your data processed by Martello Advisory:

Access: You have the right to access personal information that Martello Advisory holds about you.

Rectification: You have the right to ask us to rectify information Martello Advisory holds about you if it is inaccurate or not complete.

Erasure: You can request that Martello Advisory erase your personal data. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.

Restrict Processing: You have the right to ask Martello Advisory to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future.

Object to processing: Where processing is based on legitimate interests, you have the right to object to Martello Advisory processing your data. Martello Advisory will discontinue processing your data, unless we can demonstrate compelling legitimate grounds for the processing.  We will keep basic data to identify you and retain it solely for preventing further unwanted processing.

Portability: Where processing is based on consent or performance of a contract, you have the right to data portability. Martello Advisory must allow you to obtain and reuse your personal data for your own purposes in a safe and secure way without this effecting the usability of your data. This right only applies to personal data that you have provided to Martello Advisory as the Data Controller.

Please contact killian.buckley@martello-advisory.com to request access, rectification, or erasure, or to restrict processing, to object to processing, to request data portability.

Automated Decision Making

Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved.

Martello Advisory does not make automated decisions using personal data. If automated decisions are to be made, affected persons will be given an opportunity to express their views on the automated decision in question and object to it.

Providing Information to Martello Advisory

If you choose not to provide certain personal information, it may be an impediment to the exchange of information necessary for the execution of the contract or provision of services, and we may not be able to provide you with some services and you may not be able to participate in some of the activities on our website(s).

Third Party Websites or Other Services

We are not responsible for the privacy practices of any non-Martello Advisory operated websites, mobile apps or other digital services, including those that may be linked through Martello Advisory websites or services, and we encourage you to review the privacy policies or notices published thereon.

Contact Us

Please contact us at Martello Advisory with questions, concerns, or complaints:

Buckley Advisory Services Limited t/a Martello Advisory
26 Shelbourne Park Mews
Ringsend Road
Dublin 4
Ireland

killian.buckley@martello-advisory.com

General information

One of our main priorities is the privacy of our visitors. This Privacy Policy document contains types of information that is collected and recorded by KeyDesign and how we use it.

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us through email at Incubator. An example of a privacy policy can be found at buyproxies.io.

Log files

KeyDesign follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include:

internet protocol (IP) addresses
browser type, Internet Service Provider (ISP)
date and time stamp, referring/exit pages
possibly the number of clicks

Privacy policies

You may consult this list to find the Privacy Policy for each of the advertising partners of Incubator.

Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Incubator, which are sent directly to users’ browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalise the advertising content that you see on websites that you visit.

Note that KeyDesign has no access to or control over these cookies that are used by third-party advertisers.

Third party policies

Incubator’s Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options. You may find a complete list of these Privacy Policies and their links here: Privacy Policy Links.

You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites. What Are Cookies?

Children Information

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

Incubator does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

Online privacy

This privacy policy applies only to our online activities and is valid for visitors to our website with regards to the information that they shared and/or collect in KeyDesign. This policy is not applicable to any information collected offline or via channels other than this website.

By using our website, you hereby consent to our Privacy Policy and agree to its Terms and Conditions.

Update

This Privacy Policy was last updated on October 31, 2019. If there will be any update, amendment, or changes to our Privacy Policy then these will be posted on this page.