European Client and Third Party Privacy Notice
This Privacy Notice was last updated on 4th May 2021.
Who is responsible for your personal data?
Baird Europe is responsible for your personal data. Baird Europe comprises Robert W. Baird Limited, (00863502) Finsbury Circus House, 15 Finsbury Circus, London, EC2M 7EB; Baird Capital Partners Europe Limited, (03024884) Finsbury Circus House, 15 Finsbury Circus, London, EC2M 7EB, Robert W. Baird GmbH, Omniturm, Große Gallusstraße 18, 60312 Frankfurt am Main, Germany and their respective representatives and affiliates (the "Baird Europe Entities"). Specifically, your data will be controlled by the Baird Europe Entity that you have instructed or that is providing services or communication to you in your region.
Which personal data do we collect?
In the course of our business we may need to collect and use "personal data" about you, by which we mean any information about you from which you can be identified. The personal data we collect may include:
- Contact information, such as your name, job title, postal address, including your home address, where you have provided this to us, business address, telephone number, mobile phone number, fax number and email address;
- Payment data, such as data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;
- Further business information necessarily processed in a project or client contractual relationship with Baird Europe or voluntarily provided by you, such as instructions given, payments made, requests and projects;
- Information collected from publicly available resources, integrity data bases and credit agencies;
- If legally required for compliance purposes, information about relevant and significant litigation or other legal proceedings against you or a third party related to you and interaction with you which may be relevant for antitrust purposes;
- Other personal data regarding your preferences where it is relevant to legal services that we provide or to evaluate an application for employment; and/or
- Details of your visits to our premises.
From time to time, it may include personal data about your membership of a professional or trade association or union, health personal data, details of dietary preferences when relevant to events to which we invite you and details of any criminal record you may have.
How do we collect your personal data?
We may collect personal data about you in a number of circumstances, including
- When you or your organisation seek financial services from us;
- When you apply for a job with us;
- When you or your organisation browse, make an enquiry or otherwise interact on our website;
- When you attend a Baird Europe event; and
- When you or your organisation offer to provide or provide services to us.
In some circumstances, we collect personal data about you from a third party source. For example, we may collect personal data from your organisation, other organisations with whom you have dealings, government agencies, a credit reporting agency, an information or service provider or from a publicly available record.
Are you required to provide personal data?
As a general principle, you will provide us with your personal data entirely voluntarily; there are generally no detrimental effects for you if you choose not to consent or to provide personal data. However, in certain circumstances it will be necessary for you to provide us with your personal data, to enable us to manage our operations, to provide services to you or your organisation, or to comply with our statutory obligations.
However, please note that where you do not supply any of the personal data we request, this may mean that we are unable to maintain or provide services or products to you or your organisation.
For which purposes will we use your personal data?
We will use your personal data in connection with the management of your relationship with you and for the following purposes ("Permitted Purposes"):
- to provide our financial services or solutions as instructed or requested by you or your organisation;
- to manage and administer your or your organisation's business relationship with Baird Europe, including processing payments, accounting, auditing, billing and collection, customer support services;
- to comply with our legal obligations (such as record keeping obligations), compliance screening or recording obligations (e.g. under antitrust laws, export laws, trade sanction and embargo laws, for anti-money laundering, financial and credit check and fraud and crime prevention and detection purposes), which may include automated checks of your contact data or other information you provide about your identity against applicable sanctioned-party lists and contacting you to confirm your identity in case of a potential match or recording interaction with you which may be relevant for compliance purposes;
- to analyse and improve our services and communications to you;
- to protect the security of and access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;
- for insurance purposes;
- to monitor and assess compliance with our policies and standards;
- to identify persons authorised to trade on behalf of our clients, customers, suppliers and/or service providers;
- to comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies;
- to comply with court orders and exercises and/or defend our legal rights;
- to communicate with you through the channels you have approved to keep you up to date on the latest market developments, announcements, and other information about Baird Europe services, products and technologies (including client briefings, newsletters and other information) as well as Baird Europe events and projects; and
- to send you customer surveys, marketing campaigns, market analysis, sweepstakes, contests or other promotional activities or events.
With regard to Baird Europe marketing-related communication, you will be able to opt out anytime if you do not want to receive further marketing-related communication from us.
Depending on for which of the above Permitted Purposes we use your personal data, we may process your personal data on one or more of the following legal grounds:
- Because processing is necessary for the performance of a client instruction or other contract with you or your organisation;
- To comply with our legal obligations (e.g. to keep pension records or records for tax purposes); or
- Because processing is necessary for purposes of our legitimate interest or those of any third party recipients that receive your personal data, provided that such interests are not overridden by your interests or fundamental rights and freedoms.
In addition, the processing may be based on your consent where you have expressly given that to us.
With whom will we share your personal data?
- We share or disclose personal data when necessary to provide services or conduct our business operations as described below. When we share personal data, we do so in accordance with data privacy and security requirements. We may also occasionally share non-personal, anonymised, statistical data with third parties. Below are the parties with whom we may share personal data and why. We may share your personal data between the Baird Europe Entities on a confidential basis where required for the provision of services, account administration, sales and marketing, customer and technical support. All of Baird Europe employees and contractors are required to follow our data privacy and security policies when handling personal information. A list of our locations can be found on our website.
- If you are a client of Baird Europe, or are contracted to or are an agent of a client of Baird Europe, we may also disclose your personal data to:
- barristers, other legal specialists (including mediators), consultants or experts engaged in your matter; or
- foreign law firms for the purpose of obtaining foreign legal advice.
- If we have collected your personal data in the course of providing financial services to any of our clients, we may disclose it to that client, and where permitted by law to others for the purpose of providing specified services.
- We may share your personal data with companies providing services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such personal data is shared.
- We may share your personal data with any third party to whom we assign or novate any of our rights or obligations.
- We will share personal data with third parties for legal reasons when we believe it is required, such as:
- to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence.
- in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
- to protect our rights, users, systems and services.
- Where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process.
- We will share personal data with third parties who we engage with in provision of services for Baird Europe events (e.g. restaurants, sporting venues, travel provider, etc.). In the case where this data is necessary to provide services to you.
- We may also instruct service providers within or outside of Baird Europe, domestically or abroad, e.g. shared service centres, to process personal data for the Permitted Purposes on our behalf and in accordance with our instructions only. Baird Europe will retain control over and will remain fully responsible for your personal data and will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers.
Otherwise, we will only disclose your personal data when you direct us or give us permission.
Personal data about other people which you provide to us
If you provide personal data to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings) you must ensure that you are authorised to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice. In particular, you must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our personal data disclosure practices (including disclosure to overseas recipients), the individual's right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided (such as our inability to provide services).
Personal Candidate Data
If you apply for a job with any Baird Europe entity, Baird Europe will be the data controller in respect of information processed about you in order to assess your suitability for the role and subsequent onboarding (if applicable), including:
- Information you include on your CV or application form or which you tell us by completing forms or by corresponding with us by mail, phone, email or otherwise, such as personal contact details (i.e. name, title, addresses, telephone numbers, work and personal email addresses), education and training details, employment history including job titles, professional memberships, compensation history, copies of right to work documentation, and other similar information as needed to consider your application.
- Information we receive through references from your former employers or as part of your background check from our background check providers.
- Information we create about you, such as feedback on you in (but our decision as to whether to hire/engage you will always involve some human consideration and will not be based solely on automated computer programs).
- We will process personal data about you as we need to: (a) in order to carry out the recruitment process prior to entering into an employment/engagement contract with you; (b) in order to comply with our legal and regulatory obligations; and (c) for our legitimate interests. If you are unable to provide the information we need, we might not be able to employ/engage you.
Keeping personal data about you secure
We will take appropriate technical and organisational measures to keep your personal data confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to personal data. Personal data may be kept on our personal data technology systems, those of our contractors or in paper files.
Transferring your personal data abroad
Baird Europe is a global financial services firm. We may transfer your personal data abroad if required for the Permitted Purposes as described above. This may include countries which do not provide the same level of protection as the laws of your home country (for example, the laws within the European Economic Area or United States of America (“USA”)). We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the General Data Protection Regulation (EU) 2016/679 or other relevant laws. This includes entering into the EU Standard Contractual Clauses. You may contact us anytime using the contact details below if you would like further information about the safeguards we have in place.
All Baird offices throughout the world will at all times ensure a level of data protection at least as protective as that required in the European Economic Area and USA. We will also require our agents, consultants and sub-contractors and others who are outside the European Economic Area or USA and to whom we transfer your personal data to ensure a similar level of data protection.
Updating personal data about you
If any of the personal data that you have provided to us changes, for example if you change your email address or if you wish to cancel any request you have made of us, or if you become aware we have any inaccurate personal data about you, please let us know by sending an email to EURRegulation@rwbaird.com. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Data that you provide to us.
For how long do we retain your personal data?
Your personal data will be deleted when it is no longer reasonably required for the Permitted Purposes or you withdraw your consent (where applicable) and we are not legally required or otherwise permitted to continue storing such data. We will, in particular, retain your personal data where required for Baird Europe to assert or defend against legal claims until the end of the relevant retention period or until the claims in question have been settled.
Subject to certain legal conditions, you have the right to request a copy of the personal data about you which we hold, to have any inaccurate personal data corrected and to object to or restrict our using your personal data. You may also make a complaint if you have a concern about our handling of your personal data.
If you wish to do any of the above, please send an email to EURRegulation@rwbaird.com. We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of data. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your data, and for any additional copies of the personal data you request from us.
We endeavor to respond to any requests or complaints within a month or less, although we reserve the right to extend this period for complex requests.
If you are not satisfied with our response, you may take your complaint to the relevant privacy regulator. We will provide you with details of your relevant regulator upon request.
Updates to this Privacy Notice
We may change or update parts of this Privacy Notice in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. We will do this by updating this notice on our Baird EuropeWebsite. You will not necessarily be directly notified of such a change. Therefore, please ensure that you regularly check this Privacy Notice so you are fully aware of any changes or updates.
The changes will take effect as soon as they are posted on this website.
How to get in touch with Baird Europe
We welcome your views about our website and our Privacy Notice. If you would like to contact us with any queries or comments, please send an email to EURRegulation@rwbaird.com or send a letter to Head of Compliance & Legal Counsel, Finsbury Circus House, 15 Finsbury Circus, London, EC2M 7EB.