Privacy policy

Last revised: 8/10/2023

This privacy statement applies to Walter & Associates and its affiliated entities (“Walter & Associates,” “we,” “us,” or “our”).
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Walter & Associates is dedicated to preserving the confidentiality of your information, employing responsible handling practices, and implementing appropriate technical, administrative, and physical security measures.
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The privacy notice provided below delineates the information we collect about you, its purpose, and the entities with whom we may share it. Additionally, it elucidates your rights and provides contact information for inquiries.
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If you are affiliated with Walter & Associates as an employee, partner, or independent contractor, please refer to the pertinent privacy statement available on the Walter & Associates intranet for details on the processing of your personal information.

If you or an entity relevant to you utilizes Walter & Associates for any of the services outlined below, you can refer to the associated links for information on how we handle your information in that specific service area:

* Tax & Legal
* Audit
* Actuarial Insurance & Banking Solutions
* Financial Advisory
* Walter & Associates Commercial Database Analysis

If these services do not apply to you, please consult the information in the statement below.

We may process information about you that: (i) you provide to us, (ii) we obtain from third parties, or (iii) is publicly available. This information may include your name, age, gender, date of birth, and contact details. It may also encompass ‘sensitive’ or ‘special categories’ of personal data, such as dietary requirements or mobility information. For a more detailed description, click here.

We collect and process information about you and/or your business to enable Walter & Associates to:
* Provide our services to you or our clients.
* Offer information that we believe may be of interest to you.
* Fulfill our legal or regulatory obligations.

For a detailed description of how we use your information, click here.

You have the right to unsubscribe from our communications at any time by contacting us as specified here or by following the unsubscribe instructions in our communications.

We may share information about you within Walter & Associates and with third parties. For more information, click here.
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Transfer of some information about you to countries outside the European Economic Area may occur. When done, we ensure your information remains adequately protected. For more details, click here.

Under data protection laws, your rights include the right to:

* Request copies of your data.
* Request correction of your data.
* Request erasure of your data.
* Object to us processing your data.
* Ask us to restrict the processing.
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For more information about your privacy rights, click here.

For questions or comments about privacy issues, or to exercise your rights, please write to the Data Protection Officer, Walter & Associates, [Address], or email DPO@walterandassociates.com. For additional contact information regarding privacy, click here.
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1. Who This Privacy Statement Applies To and What It Covers
2. About Other Areas of walterandassociates.com
3. What Personal Data We Collect
4. Personal Data Provided by or About Third Parties
5. How We Use Your Personal Data
6. The Legal Grounds We Use for Processing Personal Data
7. Sharing Your Personal Data
8. Transferring Your Personal Data Outside the UK
9. Protecting Your Data
10. How Long We Keep Your Data
11. For Your Rights
12. Sending You Marketing Information
13. Right to Complain
14. Changes to This Privacy Statement

“Data Protection Legislation” means the EU General Data Protection Regulation 2016/679; together with all other applicable legislation relating to privacy or data protection (including the UK Data Protection Act 2018).
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“Walter & Associates Network” means one or more entities affiliated with Walter & Associates. Please refer to walterandassociates.com/about for a detailed description of the legal structure of Walter & Associates and its affiliated entities.
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“Process” means any operation performed on information about you, including collecting, recording, organizing, storing, altering, using, transferring, destroying, or otherwise making it available.

This privacy statement applies to Walter & Associates and its affiliated entities.
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We are committed to protecting your privacy and handling your information transparently.
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This privacy statement explains how we collect, handle, store, and protect information about you when:
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* Providing services to you or our clients.
* You use our Website.
* Performing any other activities integral to the operation of our business.

When we refer to “our Website,” we mean the specific webpages of walterandassociates.com and any other website linked to this privacy statement.
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Our Website comprises various global, country, regional, and practice-specific websites. Each is provided by Walter & Associates or its independent member firms. To learn more about Walter & Associates, please see About Walter & Associates.
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This privacy statement also provides information about when we share your data with other members of the Walter & Associates Network and other third parties (e.g., service providers).

In this privacy statement, your information is sometimes called “personal data.” We may also refer to “processing” your data, which includes handling, collecting, protecting, and storing it.

The other country and regional websites contained within walterandassociates.com belong to other entities within the Walter & Associates Network and are not provided by us. Those websites, as well as other websites linked to this Website, are not governed by this privacy statement. We encourage visitors to review the privacy statements on each of those other websites before disclosing any personal data.

We may collect, record, and use your personal data in physical and electronic form, in line with Data Protection Legislation and as outlined in this statement. When we provide services to you or our clients and perform due diligence checks, we process personal data about you. We may also collect personal data from you when you use this Website.

* You provide it to us (e.g., through forms on our Website like the My Walter portal).
* Other people provide it to us (e.g., your employer or adviser, or third-party service providers we use).
* It is publicly available.
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We may also collect personal information if you register for the Website using a third-party social network account (e.g., LinkedIn, Facebook, Twitter). For example, the Website may allow you to log in using your social network account credentials. The information we collect may depend on the privacy settings you have with the social network site. When you access the Website through your social network account, you authorize us to collect and use your information by this privacy statement.

We may process personal data from you by observing or inferring data about you from the way you interact with us or others. For example, to improve your Website experience and ensure its effectiveness, we (or our service providers) may use cookies (small text files stored in a user’s browser) or web beacons to collect personal data. More information on how we use these and other tracking technologies, and how you can control them, can be found in our cookie notice.
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The personal data we process may include your:
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* Name, gender, age, and date of birth.
* Contact information (e.g., address, email, and mobile phone number
* Country of residence.
* Lifestyle and social circumstances (e.g., hobbies).
* Family circumstances (e.g., marital status and dependents).
* Employment and education details (e.g., organization, job title, and education details).
* Financial and tax-related information (e.g., income, investments, and tax residency).
* Postings or messages on any blogs, forums, platforms, wikis, or social media applications and services that we provide.
* IP address, browser type and language, access times.
* Information on any complaints you make.
* Details of how you use our products and services.
* CCTV footage and other information collected when you access our premises.
* Details of how you like to interact with us and other similar information relevant to our relationship.

The personal data we collect may also include so-called ‘sensitive’ or ‘special categories’ of personal data, such as details about your:
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We will typically seek separate permission from you in writing to process these special categories of personal data.
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If you choose not to provide, or object to us processing, the information we collect (see section 11 below), we may not be able to process your instructions or continue to provide some or all of our services to you or our client.

When our client or another third party provides us with personal data about you, we ensure they have complied with relevant privacy laws and regulations. This may include informing you of the processing and obtaining any necessary permission for us to process that information, as described in this privacy statement.
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If any information you provide to us relates to a third party (e.g., a spouse, financially dependent, or joint account holder), by providing us with such personal data, you confirm that, in line with the above provisions, you have obtained any necessary permission to use it or are otherwise permitted to give it to us.

We process information about you and/or your business to enable us and other members of the Walter & Associates Network to provide services, meet legal or regulatory obligations, and for other business purposes. Some examples include:
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Providing services to you or our clients.
Conducting due diligence checks related to services.
Fulfilling legal or regulatory requirements.
Performing administrative tasks (e.g., client account opening).
Financial accounting, invoicing, and risk analysis.
Relationship management (e.g., sending thought leadership, event invitations, or marketing materials).
Recruitment and business development (e.g., using testimonials for recruitment materials).
Utilising third-party data sources to verify and improve information about key business relationships.
Receiving services from professional advisors (e.g., lawyers, accountants, consultants).
Investigating or preventing security incidents.
Protecting our rights and those of our clients.
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In addition to the above, we may use your personal data collected via our Website:
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To manage and improve our Website.
To tailor the content of our Website for a more personalized experience.
To draw attention to information about our products and services.
To manage and respond to any requests submitted through our Website.

We rely on one or more of the following lawful grounds to process your personal data:
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Your explicit agreement for specific processing.
Processing necessary to perform an agreement with you or take steps to enter into an agreement.
Processing necessary for compliance with a legal obligation (e.g., record-keeping for tax purposes).
Processing necessary for the purposes of a legitimate interest pursued by us or a third party, such as providing services, preventing fraud, protecting business interests, evaluating, developing, or improving services, and keeping you informed about relevant products and services.
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To the extent we process any special categories of data, we do so because:
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To manage and improve our Website.
To tailor the content of our Website for a more personalized experience
To draw attention to information about our products and services.
To manage and respond to any requests submitted through our Website.

In connection with any purposes outlined in the “How We Use Your Personal Data” section above, we may disclose details about you to:
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Other members of the Walter & Associates Network or third parties providing services or online platforms.
Competent authorities (e.g., courts and authorities regulating Walter & Associates).
Your employer and/or its advisers or your advisers.
Parties involved in a restructure, sale, or acquisition of any member of the Walter & Associates Network, as long as they use your information for the same purposes.
Credit reference agencies or organizations assisting in credit decisions and fraud reduction.
Other third parties reasonably require access to personal data relating to you.

Our Website hosts various blogs, forums, wikis, and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal data you contribute to these Social Media Applications can be read, collected, and used by other users. We have limited control over these other users, and any information you contribute might not be handled in line with this privacy statement.

Information we hold about you may be transferred to other countries, including those outside the UK or the European Economic Area (“EEA”):
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Where we do business.
Linked to your engagement with us.
From which you regularly receive or transmit information.
Where our third parties conduct their activities.
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These countries may have less stringent privacy laws than we do, subjecting any information held to their laws and disclosure requirements. Additionally, some countries have agreements facilitating information exchange for law enforcement, tax, and other purposes.
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When Walter & Associates or its permitted third parties transfer your data outside the UK or the EEA, contractual obligations are imposed on the recipients to protect your data to UK and EEA standards. The recipient may also subscribe to international frameworks intended for secure data sharing. If we transfer your data outside the UK or EEA in other circumstances (e.g., by law), we ensure it remains adequately protected.

We may share non-personal, anonymized, and aggregated information with third parties for various purposes, including data analytics, research, thought leadership, and promotional activity.

We employ various measures to ensure the security, accuracy, and currency of your data. These include:

Education and training for relevant staff to ensure awareness of privacy obligations.
Administrative and technical controls to restrict access to personal data.
Technological security measures, such as firewalls, encryption, and antivirus software.
Physical security measures, such as security passes to access our premises.

While we use appropriate measures to protect personal data, the transmission of data over the internet is never completely secure. Therefore, despite our efforts, we cannot guarantee the security of data transmitted to us or by us.

If you or an entity relevant to you utilizes Walter & Associates for any of the services listed below, you can find details on how we handle your information by clicking on the links for the respective service areas:
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* Tax & Legal
* Audit
* Actuarial Insurance & Banking Solutions
* Financial Advisory
* Walter & Associates Commercial Database Analysis
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If none of these apply to you, please consult the information in the statement below.

We may process information about you that you provide to us, that we obtain from third parties, or that is publicly available. This information may encompass details such as your name, age, gender, date of birth, and contact information. It may also include sensitive or special categories of personal data, such as dietary requirements or mobility information. For a detailed description of the information we may process, please click here.

We collect and process information about you and/or your business to:

* Provide services to you or our clients.
* Furnish information that may be of interest to you.
* Fulfil legal or regulatory obligations.

You have the right to unsubscribe from communications providing information of interest at any time. Information about unsubscribing can be found here. We may share your information within Walter & Associates and with third parties. For more details, click here.

We may transfer some information about you to countries outside your region that have different data protection laws. When doing so, we ensure your information remains adequately protected. For more information, click here.

Under data protection laws, you have rights such as requesting copies of your data, correcting, erasing, or restricting processing, and objecting to processing. For a comprehensive guide on your privacy rights, click here.

If you have questions, or comments, or wish to exercise your privacy rights, please contact our Data Protection Officer at Walter & Associates, 1 New Street Square, London EC4A 3HQ, or email DPO@walterassociates.com. For more information on whom to contact about privacy

This privacy statement applies to Walter & Associates and the entities under our ownership or control. It covers activities such as providing services, using our website, and other business operations.

Other WalterAndAssociates.com Areas: Websites on WalterAndAssociates.com from different entities within the Walter & Associates Network are not covered by this statement. Please review the privacy statements on those websites before disclosing personal data.

* Personal Data Collection: We collect, record, and use personal data in various forms and mediums, in line with data protection laws and this statement.
* Third-Party Provided Data: When personal data is provided by third parties, we ensure compliance with privacy laws and regulations.
* Legal Grounds: We process personal data based on explicit consent, contractual obligations, legal requirements, or legitimate interests.
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The remaining sections, from “How we use your data” to “Changes to this privacy statement,” remain unchanged.