In connection with providing liquidity solutions to our customers, Clearwater has received certain personal data about you from third parties or may otherwise collect such information from you directly. This personal data is needed by Clearwater primarily in order to facilitate the provision of services from Clearwater to its customers.
Data is typically collected from court filings, statements of affairs and other such regulatory filings that exist in the public domain. In some cases we collect data directly from you or from third parties connected to you and your specific case, such as legal advisers, administrators, court appointed liquidators and registrars. We may also conduct internet searches about our you when conducting diligence on specific cases – this may involve collecting personal data that you have published on professional social networks such as LinkedIn.
We may process the following categories of personal data about our customers: name, work contact details (including telephone numbers and email addresses) and job title. We use these categories of personal data in order to comply with our legal obligations and for the purposes of legitimate interests which include: providing upfront liquidity solutions to our customers, conducting research and due diligence into potential assets that customers wish to sell, business management and planning, administration and maintenance of Clearwater core records; and to prevent fraud.
We may share your data with third parties including our processors; or where we are required by law; or where we have a legitimate interest in doing so, such as to facilitate the provision of liquidity solutions to our customers. All third-party processors with whom we share your personal data are required to take appropriate security measures to protect customers’ personal data. We would only permit them to process your personal data for specified purposes and in accordance with our instructions.
Where applicable we may share your personal data with other third parties such as legal advisers, court-appointed liquidators, administrators or other such professional service-providers in accordance with our legitimate interests and where confidentiality requirements apply. We may also need to share personal data with a regulator in order to comply with the law or other governmental, administrative or judicial authorities in order to comply legal procedures, inquiries or investigations.
We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised fashion, altered or disclosed. We further limit access to your personal data to those employees who have a business need to know that information (unless required to do so by law). They will only process your data on our instructions and in accordance with the law. We have also put in place procedures to deal with any suspected data security breach and will notify you of a suspected breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting or reporting requirements we may have and in accordance with applicable laws and regulations. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the data, the potential risk of harm resulting from unauthorised use or disclosure of said data, the purposes for which we need to retain it and whether we can achieve those purposes through other means, and for complying with any applicable legal requirements.
Under certain circumstances, by law, you have the right to: request access to your personal data; request correction of the personal data that we hold about you; request erasure of your personal data; object to our processing of your personal data; request the restriction of processing of your personal data; request the transfer of your personal data to another third party. Where applicable, to exercise any of these rights, please contact us (see the “contact us” page of this website). You also have the right to lodge a complaint with the competent data protection supervisory authority which, in the UK, is the Information Commissioner’s Office.
We reserve the right to update this privacy notice at any time.