This privacy statement applies to the collection, process, disclosure and use of personal identifiable information (PII) or the personal sensitive information (PSI), as the case may be, which is submitted to The Brief (“The Brief” or “we”).
The Brief is committed to maintaining the privacy and integrity of PII and PSI and this privacy statement describes The Brief’s approach on addressing all such issues. This privacy statement provides details about the types of personal information that we collect, how we use, process, protect and disclose such personal information, and the rights individuals have to control our usage and disclosure of such personal information. Personal information submitted may be transferred to other individual Coinmen firms, which are member entities of the Coinmen group, particularly: MNV & Co, Coinmen Capital Advisors, and Novistra Coinmen LLP, where it is necessary to meet the purpose for which the user has submitted the information. By using this site and submitting any personal information, you agree to the use and disclosure by Coinmen of such information in accordance with this privacy statement.
2. Data collection
Through this website, we only collect PII or PSI that is specifically and voluntarily provided by visitors having regard to the purpose for its disclosure. Coinmen receives limited personal information, such as name, title, company details, email address, and contact numbers from website visitors. It is our policy to limit the information collected to only the minimum information required to complete a visitor’s request. Visitors are also able to contact us via email through this site. Their messages will contain the user’s screen name and email address, as well as any additional information the user may wish to include in the message. Because we use the website as a lead capture tool, a visit to the website also enables a user to send more detailed information via the message function, but limited by character length, to an individual within Coinmen.
3. Use of personal information
The main purposes of collecting personal information about individuals are as follows:
- Providing services
- Respond to an individual’s request
- Maintaining contact with clients
- Keeping clients and other contacts informed of the services we offer and industry developments that may be of interest to them, and to notify them of service offerings, seminars and other events we organise
- General management and reporting purposes, such as invoicing and account management
- All other lawful purposes related to our business and in furtherance to fulfilment of lawful contract.
Personal information collected by us through this site is used only for the intended purpose stated at the time that the information is collected or for the purposes specified above.
4. Disclosure of personal information
We do not routinely disclose or transfer an individual’s personal information to other organisations unless we have the prior and specific permission of the individual or the entity that provided such information on behalf of such individuals or unless:
- such disclosure or transfer is permitted under this privacy statement or the disclosure or transfer required by law, including for the purpose of compliance with subpoenas, court orders, requests or order from legal authorities or law enforcement agencies requiring such disclosure;
- we believe it necessary to provide the individual with a product or services which it has requested; or
- the disclosure is required for us to use or process the data for the purpose for which it was obtained.
Except as set out in this privacy statement or specifically allowed under law, we will not disclose, share, sell or rent an individual’s personal information to any third party. If an individual wishes to update or change any information, he or she may do so by requesting to us and we will prospectively cease to use or modify his or her personal information.
We use a range of service providers and contractors to help us maximise the quality and efficiency of our services and our business operations (including internal business requirements). This means that third-party individuals and organisations may sometimes have access to personal information held by Coinmen and may collect it from, process or use it on behalf of Coinmen. We require our service providers and contractors to be under appropriate confidentiality requirements, maintain adequate technical and network security and not to use or disclose such information for any unauthorised purposes.
5. Transfer of personal information outside India
As part of a global network of business associates, Coinmen exchanges or may need to exchange information, including personal information within the network or with other overseas service providers/contractors working and acting on behalf of the member firm of the network. As a result, we may transfer personal information outside India to other countries whose privacy laws provide different level of protection. Coinmen may also use overseas facilities to process, host or back up its information. As a result, we may need to transfer personal information to our overseas facilities for these purposes. However, any such information transferred shall be subject to appropriate data protection obligations.
6. Cookies and log files
7. Personal information retention
Contact information about visitors (such as information generated though registration for access to areas on the site) will be kept as long as the information is required for the purposes for which it was collected or until a user requests that we delete that information or as required by law. Mailing list information, discussion posts, and email details are kept for only the period of time considered reasonable to facilitate the visitor’s requests. Information that is kept by us will be destroyed or deleted after a reasonable period from the time when it becomes outdated or is no longer required. We may, however, need to retain copies of information (which may include personal information) for internal record-keeping purposes and/or for compliance with applicable laws or professional standards, whose requirements may be more than that of laws and rules requiring data protection and privacy.
All information including sensitive personal information provided to Coinmen through its website is provided voluntarily by visitors. Should visitors subsequently choose to withdraw their consent in respect of their personal information, unsubscribe from mailing lists or any registrations, the same can be communicated to us through the ‘Contact us’ section on the website or sending us an email with the necessary details on [email protected]
When requested and practical, each individual has the right of access to personal information they have submitted to Coinmen. We do not assume responsibility for verifying the ongoing accuracy of the content of personal information. We are committed to providing reasonable and practical access to users to allow them the opportunity to identify and correct any inaccuracies. When requested and practical, Coinmen will arrange to delete personal information from current operational systems.
Coinmen has implemented generally accepted standards of technology and operational security in order to protect personal information from loss, misuse, alteration or destruction. We follow a network-wide security policy. Only authorised personnel are provided access to sensitive personal information and these personnel have agreed to maintain confidentiality, security and integrity of this information. While Coinmen follows the standard industry practices and takes reasonable security measures to protect the personal information under our control, information may be disclosed through any unlawful or unauthorised access or regulatory environment and measures or interception of transmissions or private communications and other users and third parties may abuse or misuse an individual’s personal information. We disclaim all liability for error in transmissions and unauthorised access or interceptions, abuse or misuse by third parties and other users.
11. Third-party links
Coinmen reserves the right to modify or amend this statement at any time with or without notice for legal, administrative and technical reasons.
13. Grievance resolution
If an individual has any questions or grievances regarding anything covered by this privacy statement, he or she can contact us on [email protected]
If an individual has any queries about our privacy practices or the implementation thereof or notice any discrepancy in our database relating to the individual, he or she may address such matters to [email protected]