Terms & Conditions

INCONF

Privacy Notice

We understand how important it is to keep your information safe and secure and we take this very seriously. We have taken steps to make sure your information is looked after in the best possible way and we review this regularly. Please read this Privacy Notice (‘Privacy Notice’) carefully, as it contains important information about how we use the information about you we collect, store and use.

Definitions

In this Privacy Notice the following words are used as set out below:

  • Inconf is referred to as ‘we’, ‘us’, ‘our’, or Inconf.
  • ‘Our Clients’ means event organisers and/or their event production companies or agencies.
  • ‘Your information’ means personal data that may be used to identify you as an individual.
  • ‘CRM’ means the system used to manage sales leads that come in via our website/ email, and to store contact data for prospects, targets and marketing.

1. WHY WE ARE PROVIDING THIS PRIVACY NOTICE

We are required to provide you with this Privacy Notice by Law. It explains how we use the information we collect, store, and hold about you. If you are unclear about how we process or use your information, or you have any questions about this Privacy Notice or any other issue regarding your information, then please contact our Data Protection Lead (see paragraph 3 below). The Law says:

  • We must let you know why we collect information about you
  • We must let you know how we use any information we hold on you
  • We need to inform you in respect of what we do with it
  • We need to tell you about who we share it with or pass it on to and why
  • We need to let you know how long we keep it for

2. ABOUT US

We are Inconf a company registered in England and Wales with company number 12399032 and our registered address is 28 Alexandra Terrace, Exmouth, Devon, EX8 1BD. We deliver virtual event platforms and live streaming services for brands, corporations, associations, rights-holders, event management agencies and production companies. (‘the Service’). We receive data from Our Clients or their event production companies or agencies. Other data collected includes but is not limited to questions submitted, polling responses, surveys, profiles and instant messages directly from the data subject during their interaction with the Inconf Platform. When delivering virtual events on behalf of Our Clients, we are the Data Processor and our Client (and/or their event management company / agency) is the Data Controller. We also collect data about our sales prospects and targets . This data is typically collected via LinkedIn, websites and our personal networks of contacts and is stored in our CRM (Customer Relationship Management) system. We are the Data Controller of our sales and marketing information unless we are a Data Processor as referred to above. The purposes for which we collect and use your information are set out in this Privacy Notice.

3. DATA PROTECTION LEAD

Our Data Protection Lead is Daniel Cave, Chief Experience Officer If you have a query or need any further information about this Privacy Notice or wish to make a complaint, please email the Data Protection Lead at: [email protected]

4. WHY WE COLLECT AND USE YOUR INFORMATION

All information collected will only be used for the purpose of providing the Service as described in this Privacy Notice. We will collect and use the information you have provided for the purposes of:

  • Populating the website and virtual event platform so that users can read about the agenda and speakers at an event
  • User data, including first name, last name, company name, job title and email address, is entered into the back-end database to facilitate users logging into the system
  • Data collected during users’ interaction with the Inconf platform, for example questions submitted, polling responses, surveys, profiles, instant messages etc. is used to facilitate the user’s engagement with event content and with other delegates.
  • Event feedback data will inform the planning of future events.
  • CRM data is used in our sales and marketing activities for example doing email campaigns, telemarketing, or inviting targets to join webinars we are hosting.

5. INFORMATION WE MAY COLLECT ABOUT YOU

We may collect the following information either from Our Clients or on behalf of Our Clients

  • First name and last name
  • Job Title
  • Company Name
  • Email address
  • A short biography or profile
  • Questions that users have posed (in writing) to speakers or presenters
  • Answers to polling questions that users have submitted via the platform either multiple choice or free-text responses
  • Responses to surveys / questionnaires / feedback forms completed by users via the platform
  • Instant messages sent between delegates / exhibitors / sponsors / presenters via the platform’s networking tools
  • Notes captured when a user types into the platform during an event
  • Analytics information to enable reporting on event attendees, sessions attended, duration of attendance, expo stands visited, which documents they downloaded and how they answered polling questions

In addition, we may collect the following:

  • Information regarding Our Clients and prospects on our CRM as part of our sales process
  • The contract/project plan and the billing details for Our Clients.

6. LEGAL BASIS FOR USING YOUR INFORMATION

The law states that we must collect and use your information in accordance with a legal basis. We will only use any information that you provide in accordance with the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (‘UK GDPR’), the Data Protection Act 2018 and any other relevant legislation, regulation, code of practice or guidance. The legal basis for collecting and using your information will depend on the information concerned and the specific context in which it is collected. We will normally use your information where:

  • We have your consent to do so (you have a right to withdraw this consent at any time).
  • We require the information to perform a contract with you. For example a user will be engaged by Our Clients by virtue of a contract to attend an event.
  • The processing is in our legitimate interests (where we have a business or commercial reason to use your information) and this is not overridden by your data protection interests or fundamental rights or freedoms
  • We have a legal obligation to process the information

7. HOW LONG WE RETAIN YOUR INFORMATION

We will keep your information for as long as necessary but in any event in accordance with our data retention and disposal policy, with current law and national guidance. All event data is deleted within 6 months days following the end of an event or project.

8. WHO WE SHARE YOUR INFORMATION WITH

We typically pass to Our Clients any data collected during their event, together with an analytics ‘insight report’ which gives them a summary of the key insights drawn from the data collected. We may pass on your information if we have a legal obligation to do so.

9. DATA

Your information may be used to report trends or reports to Our Clients. The data is used for analytics as a key part of the service to Our Clients and includes which delegates watched which sessions / downloaded which documents / visited which expo stands and submitted which questions. This information will not be anonymized which means it can identify you as an individual. Clients are offered the option for their delegates or visitors to be excluded from tracking if they wish.

10. DIRECT MARKETING

We will not share your information for marketing purposes unless we have your consent.

11. YOUR DATA PROTECTION RIGHTS

  • Be informed if your information is being used;
  • Request access to the information that we have collected about you. We are obliged to provide this to you free of charge within one month of receipt of your request (unless your request is complex, or you have made numerous requests in which case it may take us longer). If your request is unfounded, excessive, or repetitive we may charge a reasonable administrative fee;
  • Request the correction of any information held about you that is inaccurate or incomplete. We encourage you to inform us of any changes to your information so that we can ensure that the data we hold on you is accurate and up to date;
  • Request the deletion or removal of your information where your information is no longer necessary for the purpose for which it was collected/processed, where there is no appropriate reason for us to continue processing it or where we have processed your information unlawfully. However, your request for deletion/removal may not always be met for legal reasons. You will be informed of these reasons when you make your request;
  • Object to the processing of your information for a particular purpose or purposes.
  • Restrict the processing of your information for example when you challenge the accuracy of the data, we hold on to you and we are verifying that data;
  • Request portability of your information. This means you have a right to receive the information you provided to us in a way that is accessible and machine-readable. You also have the right to ask us to transfer your information to another organization if this is technically feasible;
  • Not to be subject to automated individual decision-making and profiling (known as automated processing) if the decision affects your legal rights or has an important effect on you in some other way;
  • Withdraw your consent at any time where we process your information on the basis of your consent. Please note that if you withdraw your consent, we may not be able to continue to provide you with our services. We will inform you of this at the time you withdraw your consent;

For further information on your rights please go to:https://ico.org.uk/your-data-matters/

12. RIGHT TO OBJECT AND COMPLAIN

You have the right to object to your information being used in some or all of the ways as described in this Privacy Notice. Please contact the Data Protection Lead should you have any questions or issues with the use of your information as described here.

You have the right to complain about the management of your information. In the first instance, please refer your complaint to the Data Protection Lead as detailed above. If you remain dissatisfied with our response you have a right to raise any concern or complaint with the Information Commissioner’s Office:https://ico.org.uk/

13. IF ENGLISH IS NOT YOUR FIRST LANGUAGE

If English is not your first language, you can request a translation of this Privacy Notice. Please contact our Data Protection Lead for further information.

14. COOKIES (GOOGLE ANALYTICS)

Our website uses cookies to enable certain core functionality such as allowing you to log in to the virtual event platform and to network with other participants. These cookies do not contain any sensitive or personal information and only act as a mechanism for our server to identify your user account as you move around the website.

When you visit our website, you are also prompted to allow us to collect additional information about how you use the website. This data is anonymized and is used to allow us to identify trends on our website and make improvements. For example, this anonymized data allows us to see how many people have visited a certain page on our website in a given month. Unless you click the “Allow cookies” option, we do not collect this data or store the Google Analytics tracking cookie that enables this functionality on your device.

For more information on ‘Cookies and similar technologies’ go to;https://ico.org.uk/your-data-matters/online/cookies/

15. HYPERLINKS

Our website contains hyperlinks to other third-party websites. If you go to another website from our website, it is important that you read their Privacy Notice on that website to find out what it does with your information and their policies may differ from ours. We take no responsibility legal or otherwise for the content or use of information, personal or otherwise, on other websites.

16. THIRD PARTY ENGAGEMENT / SUPPLIERS

Where we use third parties to process or use your information on our behalf, we ensure that we have a robust agreement in place which makes it clear that they must be compliant with the UK GDPR and any other relevant data protection legislation. We also make it clear that the information they may receive about you from us is only used in a manner consistent with the aims of Inconf and this Privacy Notice.

  • Inconf’s platform is built on a WordPress Engine and uses Google Drive and Google’s Gmail for Business4
  • It may be necessary during the course of any activities in relation to the use of the platform that WordPress will require access to your information but please rest assured that this is secure and done in compliance with data protection legislation.
  • We store a mix of PII and non-PII data with 3rd parties such as Mixpanel, Google Analytics, WP engine and Slido depending on the features requested for each event.

17. SECURITY AND STORAGE OF YOUR INFORMATION

We take the security of your information very seriously and we do everything we can to ensure that your information is always protected and secured. We regularly update our processes and systems and we also ensure that our staffs are properly trained. We also carry out assessments and audits of the information that we hold about you and make sure that, if we provide any other services, we carry out proper assessments and security reviews. The website is maintained by WordPress who are the website hosts and providers however they do not process any data on behalf of Inconf Ltd. Your information is held electronically. It is password protected and held securely on either our internal computer systems or on a third-party secure server. The data we collect can only be accessed by the key Inconf project team members including the Project Manager, Data Analyst, Developers and Senior Leadership Team.

18. CONTACTING YOU

We are obliged to protect any confidential information that we hold about you and we take this very seriously. It is imperative that you let us know immediately if you change any of the contact details you have given us or given to others to give us so as to ensure that the information, we hold about you is up to date and correct.

19. CHANGES TO OUR PRIVACY NOTICE

Please note that this Privacy Notice will be regularly reviewed and updated in line with current data protection legislation, regulation, and guidance. You should check this Notice occasionally to ensure you are aware of the most recent version that will apply each time you access this website.

This Privacy Notice was last updated on 1 July 2021

Cookies Policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

  • Strictly necessary cookies.  These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies.These are used to recognise you when you return to our website. This enables us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Title / Name Purpose  More information
wpe-auth wordpress_logged_in_ wordpress_sec_ Cookies that support the basic functionality of the site,such as logging in. –
gs_u_GSN gs_v_GSN-2194840-F gs_u_GSN gs_v_GSN >mp_<variable>_m Cookies used by a service called Gosquared, which we use to track how many visitors are online at once. Gosquared.com
_gat_UA-<variable>_ _dc_gtm_<variable>_ _gid _ga Google analytics tracking software to measure how many visits we get and what users do. Analytics.google.com
mp_<variable>_mixpanel Mixpanel tracking software to measure how many visits we get and what users do. Mixpanel.com
ONID sb presence pin xs _BEAMER_LAST_UPDATE_HLZbZZJA4756 usida c_user dpr datr __EX_d68e20632b79795d146f00d9ad8cfe95297749b6__ AWSALBCORS _BEAMER_USER_ID_HLZbZZJA4756 __exponea_time2__ AWSALBTGCORS fr _hjid currentAccountUuid __exponea_etc__ _ga Cookie set by Vimeo player, to enable embedded videos to play, and to track the number of views and similar metrics.
Slido.EventAuthTokens _gaexp Slido.Privacy _persistenceTest Cookies used by sli.do q&a tool to deliver functionality. Sli.do

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website. Except for essential cookies, all cookies will expire after various time periods. This Cookies Policy was last updated on 1 July 2021

Inconf Platform Terms of Use

Who we are and how to contact us

We are Inconf Ltd (“We”). We are registered in England and Wales under company number 12399032 and have our registered office at 28 Alexandra Terrace, Exmouth, England, EX8 1BD Our main trading address is 15 Victoria Road, Exmouth, England, EX8 1DL.

What’s in these terms?

This acceptable use policy sets out the standards that apply when you log in to this Platform or interact with our Platform in any other way.

By using our Platform you accept these terms:

By using our Platform, you confirm that you accept the terms of this policy and that you agree to comply with them. If you do not agree to these terms, you must not use the Platform.

We may make changes to the terms of this policy

We amend these terms from time to time. Every time you wish to use the Platform, please check these terms to ensure you understand the terms that apply at that time.

Prohibited uses

You may use the Platform only for lawful purposes. You may not use the Platform:

  • In any way that breaches any applicable local, national or international law or regulation.
  • In any way that is unlawful or fraudulent or has any unlawful or fraudulent purpose or effect.
  • For the purpose of harming or attempting to harm minors in any way.
  • To bully, insult, intimidate or humiliate any person.
  • To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).
  • To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You also agree:

  • Not to reproduce, duplicate, copy or re-sell any part of the Platform
  • Not to access without authourity, interfere with, damage or disrupt:
  • Any part of the Platform;
  • Any equipment or network on which the Platform is stored;
  • Any software used in the provision of the Platform; or
  • Any equipment or network or software owned or used by any third party.

Interactive services We may from time to time provide interactive services on the Platform, including, without limitation:

  • Chat rooms.
  • Bulletin boards.
  • Q&A tools.
  • Networking features.
  • Polling, voting and quiz features.

Any moderation of Interactive Services will be undertaken by our client and you should refer to them for details.

Content standards

These content standards apply to any and all material which you contribute to the Platform (Contribution), and to any interactive services associated with it. The Content Standards must be complied with in spirit as well as to the letter. The standards apply to each part of any Contribution as well as to its whole. If applicable our client will determine, in its discretion, whether a Contribution breaches the Content Standards.

A Contribution must:

  • Be accurate (where it states facts).
  • Be genuinely held (where it states opinions).
  • Comply with the law applicable in England and Wales and in any country from which it is posted.
  • A Contribution must not:
  • Be defamatory of any person.
  • Be obscene, offensive, hateful or inflammatory.
  • Bully, insult, intimidate or humiliate.
  • Promote sexually explicit material.
  • Include child sexual abuse material.
  • Promote violence.
  • Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.
  • Infringe any copyright, database right or trademark of any other person.
  • Be likely to deceive any person.
  • Breach any legal duty owed to a third party, such as a contractual duty or a duty of confidence.
  • Promote any illegal content or activity.
  • Be in contempt of court.
  • Be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety.
  • Be likely to harass, upset, embarrass, alarm or annoy any other person.
  • Impersonate any person or misrepresent your identity or affiliation with any person.
  • Give the impression that the Contribution emanates from Inconf Ltd, if this is not the case.>
  • Advocate, promote, incite any party to commit, or assist any unlawful or criminal act such as (by way of example only) copyright infringement or computer misuse.
  • Contain a statement which you know or believe, or have reasonable grounds for believing, that members of the public to whom the statement is, or is to be, published are likely to understand as a direct or indirect encouragement or other inducement to the commission, preparation or instigation of acts of terrorism.
  • Contain any advertising or promote any services or web links to other sites.

Breach of this policy

When we consider that a breach of this acceptable use policy has occurred, we and/or our client may take such action as we deem appropriate.

Failure to comply with this acceptable use policy may result in our taking all or any of the following actions:

  • Immediate, temporary or permanent withdrawal of your right to use the Platform.
  • Immediate, temporary or permanent removal of any Contribution uploaded by you to the Platform.
  • Issue of a warning to you.
  • Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.
  • Further legal action against you.
  • Disclosure of such information to law enforcement authorities as we reasonably feel is necessary or as required by law.

We exclude our liability for all actions we may take in response to breaches of this acceptable use policy. The actions we may take are not limited to those described above, and we may take any other action we reasonably deem appropriate.

How this contract can be transferred

We can transfer our rights and obligations under these terms to any third party, provided this does not adversely affect your rights under these terms.

Which country’s laws apply to any disputes?

If you are a consumer, please note that the terms of this policy, its subject matter and its formation are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are a resident of Scotland, you may also bring proceedings in Scotland. If you are a business, the terms of this policy, its subject matter, and its formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

Terms & Conditions

Sona Asset Management (UK) LLP is a company registered in England and Wales with company number OC412361. Sona is authorised and regulated by the Financial Conduct Authority (“FCA”) with Firm Reference Number 814191.

For the purposes of the General Data Protection Regulation (‘GDPR’), Sona will be the ‘controller’ of the personal data you provide. Please read the following information carefully in order to understand the Firm’s practices in relation to the treatment of your personal data. Should you have any questions, please email us at [email protected].

What data privacy principles does the Firm adhere to?

  • The Firm will process all personal data in a lawfully, fair and transparent manner;
  • The Firm will only collect personal data where it is necessary;
    • For the Firm to provide a service to you;
    • For you to provide a service to the Firm;
    • For the Firm to keep you informed of its products and services; or
    • For the Firm to comply with its legal and regulatory obligations.
  • The personal data collected by the Firm will be adequate, relevant and limited to what is necessary in relation to the specific purpose for which your data will be processed;
  • The Firm will take all reasonable steps to ensure that personal data is accurate and, were necessary, kept up-to-date;
  • The Firm will maintain personal data in a form that permits identification no longer than is necessary for the purposes for which the personal data has been collected for processing, in accordance with the Firm’s record retention requirements as mandated by the Financial Conduct Authority;
  • The Firm will hold and process person data in a manner that ensures appropriate security;
  • The Firm will only share personal data where it is necessary to provide the agreed service or where it is necessary for the Firm to comply with its legal and regulatory requirements.
  • The Firm will only utilise a service provider based outside of the EEA for the processing of personal data where this is strictly necessary to facilitate our services to you. In all cases, we will ensure service providers are fully compliant with GDPR ahead of transferring any personal data.

What personal data does the Firm collect and why?

In the course of providing products/services to you, the Firm may collect information that is considered personal information (e.g. name, contact details, address, passport number, driving licence).

As a client, contact or employee of Sona, we will require some personal information in order to verify your identity and have the applicable relationship with you. Some of this information may be required to satisfy legal obligations (e.g. to comply with obligations arising under the money laundering regulations whereas other information may be required in connection with the provision of services to you). The information collected will vary depending on the service the Firm provides to you or you provide to the Firm, but typically includes:

  • Personal information: Such as your name, date of birth, passport number or national insurance number;
  • Contact information: Including your address, telephone number and email address.

Where does the Firm store my personal data?

The Firm has comprehensive policies and procedures in place to ensure your personal data is kept safe and secure, with these including:

  • Data encryption;
  • Firewalls;
  • Intrusion detection;
  • 24/7 physical protection of the facilities where your data is stored (i.e. Microsoft’s UK data centres);
  • Background checks for personnel that access physical facilities; and
  • Security procedures across all service operations.

How long does the Firm retain personal data?

As a regulated entity, the Firm is required to maintain its books and records for a prescribed period (five years from either the ceasing of a business relationship, or, in the case of non-clients, from the making of a record – or alternatively, for seven years, where specifically requested to do so by the Financial Conduct Authority). As such, information that falls in scope of either of these requirements is retained in line with the mandated timeframe.

Any information that is outside the scope of this requirement will be retained whilst relevant and useful, and destroyed where this ceases to be the case or where the data subject specifically requests this.

How have I been categorised in accordance with GDPR?

The GDPR requires the Firm to inform you of the legal basis on which we maintain your personal data. Typically, the Firm will reach out to you personally to confirm this; however, as a general rule the following is applicable:

  • Clients – Information is maintained on the basis of contractual obligation and/or legitimate interests (where relevant);
  • Service providers – Information is maintained on the basis of contractual obligation; and
  • Database/marketing contacts – Information is maintained on the basis of legitimate interest.

What are my rights?

Once you have provided your details to the Firm, you have certain rights which apply, depending on your relationship with the Firm, the information you have shared with us and the Firm’s legal and regulatory obligations.

You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all, of your personal information, please email the Firm at [email protected].

The Firm will provide this information to you within one month (with the ability to extend this by an additional two months where necessary), free of charge.

  • You have the right to request that the information the Firm holds about you is erased under certain circumstances including where there is no additional legal and/or regulatory requirement for the Firm to retain this information.
  • As a client, you have the right to request that any information the Firm holds about you be provided to another company in a commonly used and machine-readable format, otherwise known as ‘data portability’.
  • You have the right to ensure that your personal information is accurate and up to date, or where necessary rectified. Where you feel that your personal data is incorrect or inaccurate and should therefore be updated, please contact [email protected].
  • You have the right to object to your information being processed, for example for direct marketing purposes.
  • You have the right to restrict the processing of your information, for example limiting the material that you receive or where your information is transferred.
  • You have the right to object to any decisions based on the automated processing of your personal data, including profiling.
  • You have the right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/concerns/ if you are not happy with the way that we manage or process personal data.

Will I be notified of changes to this policy?

The Firm may, from time to time, review and update this policy. The Firm will maintain the latest version of this policy on its website, and where the changes are deemed material, it will make you are aware of these.

Who should I direct questions to?

If you have any questions, concerns or complaints about the practices contained within this document or how the Firm has handled your data, please contact [email protected]. Alternatively, you may write to: 20 Saint James’s Street, London, SW1A 1ES, UNITED KINGDOM.

Privacy Notice, Hong Kong

Sona Asset Management (HK) Limited (the “Sona Asset Management”, “we”, “us” or “our”) is providing you with this privacy notice to help you understand our privacy policies and practices and how they relate to the personal data that we receives and/or collects from you.

In accordance with the Personal Data (Privacy) Ordinance of Hong Kong (Cap. 486), the term “personal data” means any data relating directly or indirectly to a living individual, from which it is practicable for the identity of the individual to be directly or indirectly ascertained and in a form in which access to or processing of the data is practicable.

What personal data does Sona Asset Management collect and/or process?

Sona Asset Management collects personal data about you from the following sources:

  • Information Sona Asset Management receives from you in subscription documents or other related forms;
  • Information about your transactions with Sona Asset Management, our affiliates, or others;
  • Information about you that Sona Asset Management receives from third parties, such as consumer reporting agency, credit reference agency, verification service provider and other publicly available sources, etc.;
  • Any other information you have provided to Sona Asset Management; and/or
  • Any other information we collect or generate about you, when communicating with or providing services to you. Your communication with Sona Asset Management will be subject to monitoring in accordance with and to the extent permitted by applicable laws.

Sona Asset Management may collect and/or process certain types of your personal data, including but not limited to the following:

  • Name, address, email address, phone number, date of birth;
  • Personal identification information, such as identity card or passport details, proof of address;
  • Information about your source of wealth and source of funds; and/or
  • Other personal data that you may choose to share with Sona Asset Management.

What are our purposes of collecting and/or processing your personal data?

Sona Asset Management may process the above categories of personal data for some or all of the following purposes:

  • To verify your identity and comply with applicable law, including know-your-client and anti-money laundering and sanctions requirements;
  • To effect client transactions (including accepting subscriptions);
  • To comply with any applicable legal or regulatory obligations, including information disclosure requirements;
  • To conduct statistical analysis and market research;
  • To allow service providers retained by Sona Asset Management or our affiliates to provide services associated with your transactions with us;
  • To improve our products and services and defend our legal rights and interests;
  • With your valid consent, to conduct direct marketing of products and services that Sona Asset Management or any of our affiliates considers may be of interest to you; and/or
  • Any other uses relating to the above to which you have consented.

Providing your personal data to third parties

Sona Asset Management may disclose personal data to the following third parties for the above mentioned purposes:

  • Sona Asset Management’s affiliates;
  • Any agent, contractor or third party firms engaged by Sona Asset Management or our affiliates, including without limitation, brokers, fund administrators, accounting support firms and compliance/operational support service providers;
  • Any agents of Sona Asset Management who need to know that information in order to provide services to its investors;
  • Any third party for promotional or marketing purposes in relation to the products and services of Sona Assessment Management and/or our affiliates, with your consent;
  • Any applicable regulators, exchanges, government bodies, tax authorities or other industry recognized bodies located inside or outside Hong Kong;
  • Any third party as required by any applicable law, rules and regulations, codes of practice or guidelines of any applicable jurisdiction, or as required by an order by a court of competent jurisdiction; and/or
  • Any other third parties who you consent to share your data with.

Sona Asset Management will require such third parties to protect the confidentiality of your personal data and to use the personal data only for the purposes for which it is disclosed to them. Where we share or transfer your personal data outside of Hong Kong, we will ensure that the overseas recipients’ processing of your personal data meets the personal data protection standards prescribed by applicable laws and regulations.

Will your personal data be used for direct marketing?

Subject to obtaining your consent where required by law, we may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. We do not share your information with non-affiliates for them to market their own services to you. We may disclose information you provide to us to companies that perform marketing services on our behalf, such as any placement agent retained by the Funds that Sona Asset Management and/or its affiliates manages and/or advises, subject to obtaining your consent where required by law.

If you change your mind on which communications you would like to receive or how you would like to receive them or you decide that you do not wish to receive direct marketing communications any more, you can unsubscribe at any time by contacting us at [email protected].

What are your rights?

You have a right to request access to, and request correction of, your personal data. Requests for access and correction should be
addressed to Sona Compliance at [email protected] .

Who should I direct questions to?

If you have any questions about this privacy policy or how we handle your personal data, you can contact the offices of Sona Asset
Management at [email protected] / +44 (0)20 3872 4572 .

Candidate Data Protection Notice and Privacy
Policy

Sona Asset Management and its affiliates (together “we” of the “Company” operate in different countries and some of these countries have laws related to the collection, use, transfer and disclosure of personal information, including those of our job applicants (“candidates”). The purpose of this Candidate Data Protection Notice and Privacy Policy (“Candidate Notice”) is to give you information about what personal information we collect and why, to whom we disclose it, and how we protect it, as well as your respective privacy rights under applicable laws..

This Candidate Notice applies to you to the extent that you provide or have provided your personal information in your capacity as a job candidate for a position at Sona Asset Management, either as an employee or as non-employee staff.

The Company is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does the Company collect?

The Company collects a range of information about you. This includes:

  • your name, address and contact details, including email address and telephone number; talent management information (e.g., degrees, licenses, trainings, professional references, work experience, job titles and duties, seniority, educational history, any role or roles for which you are applying or being considered, and other information about you that you provide in a CV or similar document);
  • whether or not you have a disability for which the Company needs to make reasonable adjustments during the recruitment process;
  • information about your entitlement to work ; and
  • Details of any FCA controlled function status.

The Company may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests such as psychometric testing.

The Company may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records check or screenings. The Company will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Why does the Company process personal data?

The Company needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.

In some cases, the Company needs to process data to ensure that it is complying with its legal obligations and those required by the FCA or SEC. For example, it is required to check a successful applicant&#39;s eligibility to work in the UK before employment starts.

The Company has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the Company to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The Company may also need to process data from job applicants to respond to and defend against legal claims.

The Company may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. It may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. The Company processes such information to carry out its obligations and exercise specific rights in relation to employment.

For some roles, the Company is obliged to seek information about criminal convictions and offences. Where the Company seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

If your application is unsuccessful, the Company may keep your personal data on file in case there are future employment opportunities for which you may be suited. The Company will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

Your information may be shared internally for the purposes of the recruitment exercise which may include managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles,

The Company will also share your data with our third party outsourced HR provider if they are involved in the recruitment process. However, the Company will not share your data with other third parties, unless your application for employment is successful and it makes you an offer of employment. The Company will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.

Your data may be transferred outside the European Economic Area (EEA).

How does the Company protect data?

The Company takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

For how long does the Company keep data?

The Company will not retain your personal information for longer than is necessary in relation to the purposes for which your personal information is processed. The criteria used to determine our retention periods are:

  • The duration of your application and recruitment process;
  • As required by a legal obligation to which we are subject; and
  • As advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

Subject to applicable law, some personal data will be retained after the application and recruitment process ends, either because you are employed or otherwise engaged by us or, if your application is withdrawn or unsuccessful.

Your rights

Depending on the applicable laws in your country of resident, you may have certain rights related to your personal information. For example, the right to:

  • access and obtain a copy of your data on request;
  • require the Company to change incorrect or incomplete data;
  • require the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
  • object to the processing of your data where the Company is relying on its legitimate

interests as the legal ground for processing. If you would like to exercise any of these rights, please contact [email protected]

Depending on your country, you may have the right to lodge a complaint with your local data protection authority if available. If you believe that the Company has not complied with your data protection rights, you can complain to the Information Commissioner.

  • United Kingdom – Information Commissioner’s Office https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/
  • Hong Kong – Office of the Privacy Commissioner for Personal Data, Hong Kong, https://www.pcpd.org.hk/

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the Company during the recruitment process. However, if you do not provide the information, the Company may not be able to process your application properly or at all.

Automated decision-making

Recruitment processes are not based solely on automated decision-making.

Login
Click here for Sona Asset Management’s Terms and Conditions

When you log on to this platform, you agree that you have read and accept Inconf’s Privacy Notice, Terms of Use and Cookie Policy. Inconf acts as data processor for the event organiser. Please contact the event organiser directly for their data protection policies.

INCONF

Privacy Notice

We understand how important it is to keep your information safe and secure and we take this very seriously. We have taken steps to make sure your information is looked after in the best possible way and we review this regularly. Please read this Privacy Notice (‘Privacy Notice’) carefully, as it contains important information about how we use the information about you we collect, store and use.

Definitions

In this Privacy Notice the following words are used as set out below:

  • Inconf is referred to as ‘we’, ‘us’, ‘our’, or Inconf.
  • ‘Our Clients’ means event organisers and/or their event production companies or agencies.
  • ‘Your information’ means personal data that may be used to identify you as an individual.
  • ‘CRM’ means the system used to manage sales leads that come in via our website/ email, and to store contact data for prospects, targets and marketing.

1. WHY WE ARE PROVIDING THIS PRIVACY NOTICE

We are required to provide you with this Privacy Notice by Law. It explains how we use the information we collect, store, and hold about you. If you are unclear about how we process or use your information, or you have any questions about this Privacy Notice or any other issue regarding your information, then please contact our Data Protection Lead (see paragraph 3 below). The Law says:

  • We must let you know why we collect information about you
  • We must let you know how we use any information we hold on you
  • We need to inform you in respect of what we do with it
  • We need to tell you about who we share it with or pass it on to and why
  • We need to let you know how long we keep it for

2. ABOUT US

We are Inconf a company registered in England and Wales with company number 12399032 and our registered address is 28 Alexandra Terrace, Exmouth, Devon, EX8 1BD. We deliver virtual event platforms and live streaming services for brands, corporations, associations, rights-holders, event management agencies and production companies. (‘the Service’). We receive data from Our Clients or their event production companies or agencies. Other data collected includes but is not limited to questions submitted, polling responses, surveys, profiles and instant messages directly from the data subject during their interaction with the Inconf Platform. When delivering virtual events on behalf of Our Clients, we are the Data Processor and our Client (and/or their event management company / agency) is the Data Controller. We also collect data about our sales prospects and targets . This data is typically collected via LinkedIn, websites and our personal networks of contacts and is stored in our CRM (Customer Relationship Management) system. We are the Data Controller of our sales and marketing information unless we are a Data Processor as referred to above. The purposes for which we collect and use your information are set out in this Privacy Notice.

3. DATA PROTECTION LEAD

Our Data Protection Lead is Daniel Cave, Chief Experience Officer If you have a query or need any further information about this Privacy Notice or wish to make a complaint, please email the Data Protection Lead at: [email protected]

4. WHY WE COLLECT AND USE YOUR INFORMATION

All information collected will only be used for the purpose of providing the Service as described in this Privacy Notice. We will collect and use the information you have provided for the purposes of:

  • Populating the website and virtual event platform so that users can read about the agenda and speakers at an event
  • User data, including first name, last name, company name, job title and email address, is entered into the back-end database to facilitate users logging into the system
  • Data collected during users’ interaction with the Inconf platform, for example questions submitted, polling responses, surveys, profiles, instant messages etc. is used to facilitate the user’s engagement with event content and with other delegates.
  • Event feedback data will inform the planning of future events.
  • CRM data is used in our sales and marketing activities for example doing email campaigns, telemarketing, or inviting targets to join webinars we are hosting.

5. INFORMATION WE MAY COLLECT ABOUT YOU

We may collect the following information either from Our Clients or on behalf of Our Clients

  • First name and last name
  • Job Title
  • Company Name
  • Email address
  • A short biography or profile
  • Questions that users have posed (in writing) to speakers or presenters
  • Answers to polling questions that users have submitted via the platform either multiple choice or free-text responses
  • Responses to surveys / questionnaires / feedback forms completed by users via the platform
  • Instant messages sent between delegates / exhibitors / sponsors / presenters via the platform’s networking tools
  • Notes captured when a user types into the platform during an event
  • Analytics information to enable reporting on event attendees, sessions attended, duration of attendance, expo stands visited, which documents they downloaded and how they answered polling questions

In addition, we may collect the following:

  • Information regarding Our Clients and prospects on our CRM as part of our sales process
  • The contract/project plan and the billing details for Our Clients.

6. LEGAL BASIS FOR USING YOUR INFORMATION

The law states that we must collect and use your information in accordance with a legal basis. We will only use any information that you provide in accordance with the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (‘UK GDPR’), the Data Protection Act 2018 and any other relevant legislation, regulation, code of practice or guidance. The legal basis for collecting and using your information will depend on the information concerned and the specific context in which it is collected. We will normally use your information where:

  • We have your consent to do so (you have a right to withdraw this consent at any time).
  • We require the information to perform a contract with you. For example a user will be engaged by Our Clients by virtue of a contract to attend an event.
  • The processing is in our legitimate interests (where we have a business or commercial reason to use your information) and this is not overridden by your data protection interests or fundamental rights or freedoms
  • We have a legal obligation to process the information

7. HOW LONG WE RETAIN YOUR INFORMATION

We will keep your information for as long as necessary but in any event in accordance with our data retention and disposal policy, with current law and national guidance. All event data is deleted within 6 months days following the end of an event or project.

8. WHO WE SHARE YOUR INFORMATION WITH

We typically pass to Our Clients any data collected during their event, together with an analytics ‘insight report’ which gives them a summary of the key insights drawn from the data collected. We may pass on your information if we have a legal obligation to do so.

9. DATA

Your information may be used to report trends or reports to Our Clients. The data is used for analytics as a key part of the service to Our Clients and includes which delegates watched which sessions / downloaded which documents / visited which expo stands and submitted which questions. This information will not be anonymized which means it can identify you as an individual. Clients are offered the option for their delegates or visitors to be excluded from tracking if they wish.

10. DIRECT MARKETING

We will not share your information for marketing purposes unless we have your consent.

11. YOUR DATA PROTECTION RIGHTS

  • Be informed if your information is being used;
  • Request access to the information that we have collected about you. We are obliged to provide this to you free of charge within one month of receipt of your request (unless your request is complex, or you have made numerous requests in which case it may take us longer). If your request is unfounded, excessive, or repetitive we may charge a reasonable administrative fee;
  • Request the correction of any information held about you that is inaccurate or incomplete. We encourage you to inform us of any changes to your information so that we can ensure that the data we hold on you is accurate and up to date;
  • Request the deletion or removal of your information where your information is no longer necessary for the purpose for which it was collected/processed, where there is no appropriate reason for us to continue processing it or where we have processed your information unlawfully. However, your request for deletion/removal may not always be met for legal reasons. You will be informed of these reasons when you make your request;
  • Object to the processing of your information for a particular purpose or purposes.
  • Restrict the processing of your information for example when you challenge the accuracy of the data, we hold on to you and we are verifying that data;
  • Request portability of your information. This means you have a right to receive the information you provided to us in a way that is accessible and machine-readable. You also have the right to ask us to transfer your information to another organization if this is technically feasible;
  • Not to be subject to automated individual decision-making and profiling (known as automated processing) if the decision affects your legal rights or has an important effect on you in some other way;
  • Withdraw your consent at any time where we process your information on the basis of your consent. Please note that if you withdraw your consent, we may not be able to continue to provide you with our services. We will inform you of this at the time you withdraw your consent;

For further information on your rights please go to:https://ico.org.uk/your-data-matters/

12. RIGHT TO OBJECT AND COMPLAIN

You have the right to object to your information being used in some or all of the ways as described in this Privacy Notice. Please contact the Data Protection Lead should you have any questions or issues with the use of your information as described here.

You have the right to complain about the management of your information. In the first instance, please refer your complaint to the Data Protection Lead as detailed above. If you remain dissatisfied with our response you have a right to raise any concern or complaint with the Information Commissioner’s Office:https://ico.org.uk/

13. IF ENGLISH IS NOT YOUR FIRST LANGUAGE

If English is not your first language, you can request a translation of this Privacy Notice. Please contact our Data Protection Lead for further information.

14. COOKIES (GOOGLE ANALYTICS)

Our website uses cookies to enable certain core functionality such as allowing you to log in to the virtual event platform and to network with other participants. These cookies do not contain any sensitive or personal information and only act as a mechanism for our server to identify your user account as you move around the website.

When you visit our website, you are also prompted to allow us to collect additional information about how you use the website. This data is anonymized and is used to allow us to identify trends on our website and make improvements. For example, this anonymized data allows us to see how many people have visited a certain page on our website in a given month. Unless you click the “Allow cookies” option, we do not collect this data or store the Google Analytics tracking cookie that enables this functionality on your device.

For more information on ‘Cookies and similar technologies’ go to;https://ico.org.uk/your-data-matters/online/cookies/

15. HYPERLINKS

Our website contains hyperlinks to other third-party websites. If you go to another website from our website, it is important that you read their Privacy Notice on that website to find out what it does with your information and their policies may differ from ours. We take no responsibility legal or otherwise for the content or use of information, personal or otherwise, on other websites.

16. THIRD PARTY ENGAGEMENT / SUPPLIERS

Where we use third parties to process or use your information on our behalf, we ensure that we have a robust agreement in place which makes it clear that they must be compliant with the UK GDPR and any other relevant data protection legislation. We also make it clear that the information they may receive about you from us is only used in a manner consistent with the aims of Inconf and this Privacy Notice.

  • Inconf’s platform is built on a WordPress Engine and uses Google Drive and Google’s Gmail for Business4
  • It may be necessary during the course of any activities in relation to the use of the platform that WordPress will require access to your information but please rest assured that this is secure and done in compliance with data protection legislation.
  • We store a mix of PII and non-PII data with 3rd parties such as Mixpanel, Google Analytics, WP engine and Slido depending on the features requested for each event.

17. SECURITY AND STORAGE OF YOUR INFORMATION

We take the security of your information very seriously and we do everything we can to ensure that your information is always protected and secured. We regularly update our processes and systems and we also ensure that our staffs are properly trained. We also carry out assessments and audits of the information that we hold about you and make sure that, if we provide any other services, we carry out proper assessments and security reviews. The website is maintained by WordPress who are the website hosts and providers however they do not process any data on behalf of Inconf Ltd. Your information is held electronically. It is password protected and held securely on either our internal computer systems or on a third-party secure server. The data we collect can only be accessed by the key Inconf project team members including the Project Manager, Data Analyst, Developers and Senior Leadership Team.

18. CONTACTING YOU

We are obliged to protect any confidential information that we hold about you and we take this very seriously. It is imperative that you let us know immediately if you change any of the contact details you have given us or given to others to give us so as to ensure that the information, we hold about you is up to date and correct.

19. CHANGES TO OUR PRIVACY NOTICE

Please note that this Privacy Notice will be regularly reviewed and updated in line with current data protection legislation, regulation, and guidance. You should check this Notice occasionally to ensure you are aware of the most recent version that will apply each time you access this website.

This Privacy Notice was last updated on 1 July 2021

Cookies Policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

  • Strictly necessary cookies.  These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies.These are used to recognise you when you return to our website. This enables us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Title / Name Purpose  More information
wpe-auth wordpress_logged_in_ wordpress_sec_ Cookies that support the basic functionality of the site,such as logging in. –
gs_u_GSN gs_v_GSN-2194840-F gs_u_GSN gs_v_GSN >mp_<variable>_m Cookies used by a service called Gosquared, which we use to track how many visitors are online at once. Gosquared.com
_gat_UA-<variable>_ _dc_gtm_<variable>_ _gid _ga Google analytics tracking software to measure how many visits we get and what users do. Analytics.google.com
mp_<variable>_mixpanel Mixpanel tracking software to measure how many visits we get and what users do. Mixpanel.com
ONID sb presence pin xs _BEAMER_LAST_UPDATE_HLZbZZJA4756 usida c_user dpr datr __EX_d68e20632b79795d146f00d9ad8cfe95297749b6__ AWSALBCORS _BEAMER_USER_ID_HLZbZZJA4756 __exponea_time2__ AWSALBTGCORS fr _hjid currentAccountUuid __exponea_etc__ _ga Cookie set by Vimeo player, to enable embedded videos to play, and to track the number of views and similar metrics.
Slido.EventAuthTokens _gaexp Slido.Privacy _persistenceTest Cookies used by sli.do q&a tool to deliver functionality. Sli.do

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website. Except for essential cookies, all cookies will expire after various time periods. This Cookies Policy was last updated on 1 July 2021

Inconf Platform Terms of Use

Who we are and how to contact us

We are Inconf Ltd (“We”). We are registered in England and Wales under company number 12399032 and have our registered office at 28 Alexandra Terrace, Exmouth, England, EX8 1BD Our main trading address is 15 Victoria Road, Exmouth, England, EX8 1DL.

What’s in these terms?

This acceptable use policy sets out the standards that apply when you log in to this Platform or interact with our Platform in any other way.

By using our Platform you accept these terms:

By using our Platform, you confirm that you accept the terms of this policy and that you agree to comply with them. If you do not agree to these terms, you must not use the Platform.

We may make changes to the terms of this policy

We amend these terms from time to time. Every time you wish to use the Platform, please check these terms to ensure you understand the terms that apply at that time.

Prohibited uses

You may use the Platform only for lawful purposes. You may not use the Platform:

  • In any way that breaches any applicable local, national or international law or regulation.
  • In any way that is unlawful or fraudulent or has any unlawful or fraudulent purpose or effect.
  • For the purpose of harming or attempting to harm minors in any way.
  • To bully, insult, intimidate or humiliate any person.
  • To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).
  • To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You also agree:

  • Not to reproduce, duplicate, copy or re-sell any part of the Platform
  • Not to access without authourity, interfere with, damage or disrupt:
  • Any part of the Platform;
  • Any equipment or network on which the Platform is stored;
  • Any software used in the provision of the Platform; or
  • Any equipment or network or software owned or used by any third party.

Interactive services We may from time to time provide interactive services on the Platform, including, without limitation:

  • Chat rooms.
  • Bulletin boards.
  • Q&A tools.
  • Networking features.
  • Polling, voting and quiz features.

Any moderation of Interactive Services will be undertaken by our client and you should refer to them for details.

Content standards

These content standards apply to any and all material which you contribute to the Platform (Contribution), and to any interactive services associated with it. The Content Standards must be complied with in spirit as well as to the letter. The standards apply to each part of any Contribution as well as to its whole. If applicable our client will determine, in its discretion, whether a Contribution breaches the Content Standards.

A Contribution must:

  • Be accurate (where it states facts).
  • Be genuinely held (where it states opinions).
  • Comply with the law applicable in England and Wales and in any country from which it is posted.
  • A Contribution must not:
  • Be defamatory of any person.
  • Be obscene, offensive, hateful or inflammatory.
  • Bully, insult, intimidate or humiliate.
  • Promote sexually explicit material.
  • Include child sexual abuse material.
  • Promote violence.
  • Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.
  • Infringe any copyright, database right or trademark of any other person.
  • Be likely to deceive any person.
  • Breach any legal duty owed to a third party, such as a contractual duty or a duty of confidence.
  • Promote any illegal content or activity.
  • Be in contempt of court.
  • Be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety.
  • Be likely to harass, upset, embarrass, alarm or annoy any other person.
  • Impersonate any person or misrepresent your identity or affiliation with any person.
  • Give the impression that the Contribution emanates from Inconf Ltd, if this is not the case.>
  • Advocate, promote, incite any party to commit, or assist any unlawful or criminal act such as (by way of example only) copyright infringement or computer misuse.
  • Contain a statement which you know or believe, or have reasonable grounds for believing, that members of the public to whom the statement is, or is to be, published are likely to understand as a direct or indirect encouragement or other inducement to the commission, preparation or instigation of acts of terrorism.
  • Contain any advertising or promote any services or web links to other sites.

Breach of this policy

When we consider that a breach of this acceptable use policy has occurred, we and/or our client may take such action as we deem appropriate.

Failure to comply with this acceptable use policy may result in our taking all or any of the following actions:

  • Immediate, temporary or permanent withdrawal of your right to use the Platform.
  • Immediate, temporary or permanent removal of any Contribution uploaded by you to the Platform.
  • Issue of a warning to you.
  • Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.
  • Further legal action against you.
  • Disclosure of such information to law enforcement authorities as we reasonably feel is necessary or as required by law.

We exclude our liability for all actions we may take in response to breaches of this acceptable use policy. The actions we may take are not limited to those described above, and we may take any other action we reasonably deem appropriate.

How this contract can be transferred

We can transfer our rights and obligations under these terms to any third party, provided this does not adversely affect your rights under these terms.

Which country’s laws apply to any disputes?

If you are a consumer, please note that the terms of this policy, its subject matter and its formation are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are a resident of Scotland, you may also bring proceedings in Scotland. If you are a business, the terms of this policy, its subject matter, and its formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

Sona Asset Management (UK) LLP is a company registered in England and Wales with company number OC412361. Sona is authorised and regulated by the Financial Conduct Authority (“FCA”) with Firm Reference Number 814191.

For the purposes of the General Data Protection Regulation (‘GDPR’), Sona will be the ‘controller’ of the personal data you provide. Please read the following information carefully in order to understand the Firm’s practices in relation to the treatment of your personal data. Should you have any questions, please email us at [email protected].

What data privacy principles does the Firm adhere to?

  • The Firm will process all personal data in a lawfully, fair and transparent manner;
  • The Firm will only collect personal data where it is necessary;
    • For the Firm to provide a service to you;
    • For you to provide a service to the Firm;
    • For the Firm to keep you informed of its products and services; or
    • For the Firm to comply with its legal and regulatory obligations.
  • The personal data collected by the Firm will be adequate, relevant and limited to what is necessary in relation to the specific purpose for which your data will be processed;
  • The Firm will take all reasonable steps to ensure that personal data is accurate and, were necessary, kept up-to-date;
  • The Firm will maintain personal data in a form that permits identification no longer than is necessary for the purposes for which the personal data has been collected for processing, in accordance with the Firm’s record retention requirements as mandated by the Financial Conduct Authority;
  • The Firm will hold and process person data in a manner that ensures appropriate security;
  • The Firm will only share personal data where it is necessary to provide the agreed service or where it is necessary for the Firm to comply with its legal and regulatory requirements.
  • The Firm will only utilise a service provider based outside of the EEA for the processing of personal data where this is strictly necessary to facilitate our services to you. In all cases, we will ensure service providers are fully compliant with GDPR ahead of transferring any personal data.

What personal data does the Firm collect and why?

In the course of providing products/services to you, the Firm may collect information that is considered personal information (e.g. name, contact details, address, passport number, driving licence).

As a client, contact or employee of Sona, we will require some personal information in order to verify your identity and have the applicable relationship with you. Some of this information may be required to satisfy legal obligations (e.g. to comply with obligations arising under the money laundering regulations whereas other information may be required in connection with the provision of services to you). The information collected will vary depending on the service the Firm provides to you or you provide to the Firm, but typically includes:

  • Personal information: Such as your name, date of birth, passport number or national insurance number;
  • Contact information: Including your address, telephone number and email address.

Where does the Firm store my personal data?

The Firm has comprehensive policies and procedures in place to ensure your personal data is kept safe and secure, with these including:

  • Data encryption;
  • Firewalls;
  • Intrusion detection;
  • 24/7 physical protection of the facilities where your data is stored (i.e. Microsoft’s UK data centres);
  • Background checks for personnel that access physical facilities; and
  • Security procedures across all service operations.

How long does the Firm retain personal data?

As a regulated entity, the Firm is required to maintain its books and records for a prescribed period (five years from either the ceasing of a business relationship, or, in the case of non-clients, from the making of a record – or alternatively, for seven years, where specifically requested to do so by the Financial Conduct Authority). As such, information that falls in scope of either of these requirements is retained in line with the mandated timeframe.

Any information that is outside the scope of this requirement will be retained whilst relevant and useful, and destroyed where this ceases to be the case or where the data subject specifically requests this.

How have I been categorised in accordance with GDPR?

The GDPR requires the Firm to inform you of the legal basis on which we maintain your personal data. Typically, the Firm will reach out to you personally to confirm this; however, as a general rule the following is applicable:

  • Clients – Information is maintained on the basis of contractual obligation and/or legitimate interests (where relevant);
  • Service providers – Information is maintained on the basis of contractual obligation; and
  • Database/marketing contacts – Information is maintained on the basis of legitimate interest.

What are my rights?

Once you have provided your details to the Firm, you have certain rights which apply, depending on your relationship with the Firm, the information you have shared with us and the Firm’s legal and regulatory obligations.

You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all, of your personal information, please email the Firm at [email protected].

The Firm will provide this information to you within one month (with the ability to extend this by an additional two months where necessary), free of charge.

  • You have the right to request that the information the Firm holds about you is erased under certain circumstances including where there is no additional legal and/or regulatory requirement for the Firm to retain this information.
  • As a client, you have the right to request that any information the Firm holds about you be provided to another company in a commonly used and machine-readable format, otherwise known as ‘data portability’.
  • You have the right to ensure that your personal information is accurate and up to date, or where necessary rectified. Where you feel that your personal data is incorrect or inaccurate and should therefore be updated, please contact [email protected].
  • You have the right to object to your information being processed, for example for direct marketing purposes.
  • You have the right to restrict the processing of your information, for example limiting the material that you receive or where your information is transferred.
  • You have the right to object to any decisions based on the automated processing of your personal data, including profiling.
  • You have the right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/concerns/ if you are not happy with the way that we manage or process personal data.

Will I be notified of changes to this policy?

The Firm may, from time to time, review and update this policy. The Firm will maintain the latest version of this policy on its website, and where the changes are deemed material, it will make you are aware of these.

Who should I direct questions to?

If you have any questions, concerns or complaints about the practices contained within this document or how the Firm has handled your data, please contact [email protected]. Alternatively, you may write to: 20 Saint James’s Street, London, SW1A 1ES, UNITED KINGDOM.

Privacy Notice, Hong Kong

Sona Asset Management (HK) Limited (the “Sona Asset Management”, “we”, “us” or “our”) is providing you with this privacy notice to help you understand our privacy policies and practices and how they relate to the personal data that we receives and/or collects from you.

In accordance with the Personal Data (Privacy) Ordinance of Hong Kong (Cap. 486), the term “personal data” means any data relating directly or indirectly to a living individual, from which it is practicable for the identity of the individual to be directly or indirectly ascertained and in a form in which access to or processing of the data is practicable.

What personal data does Sona Asset Management collect and/or process?

Sona Asset Management collects personal data about you from the following sources:

  • Information Sona Asset Management receives from you in subscription documents or other related forms;
  • Information about your transactions with Sona Asset Management, our affiliates, or others;
  • Information about you that Sona Asset Management receives from third parties, such as consumer reporting agency, credit reference agency, verification service provider and other publicly available sources, etc.;
  • Any other information you have provided to Sona Asset Management; and/or
  • Any other information we collect or generate about you, when communicating with or providing services to you. Your communication with Sona Asset Management will be subject to monitoring in accordance with and to the extent permitted by applicable laws.

Sona Asset Management may collect and/or process certain types of your personal data, including but not limited to the following:

  • Name, address, email address, phone number, date of birth;
  • Personal identification information, such as identity card or passport details, proof of address;
  • Information about your source of wealth and source of funds; and/or
  • Other personal data that you may choose to share with Sona Asset Management.

What are our purposes of collecting and/or processing your personal data?

Sona Asset Management may process the above categories of personal data for some or all of the following purposes:

  • To verify your identity and comply with applicable law, including know-your-client and anti-money laundering and sanctions requirements;
  • To effect client transactions (including accepting subscriptions);
  • To comply with any applicable legal or regulatory obligations, including information disclosure requirements;
  • To conduct statistical analysis and market research;
  • To allow service providers retained by Sona Asset Management or our affiliates to provide services associated with your transactions with us;
  • To improve our products and services and defend our legal rights and interests;
  • With your valid consent, to conduct direct marketing of products and services that Sona Asset Management or any of our affiliates considers may be of interest to you; and/or
  • Any other uses relating to the above to which you have consented.

Providing your personal data to third parties

Sona Asset Management may disclose personal data to the following third parties for the above mentioned purposes:

  • Sona Asset Management’s affiliates;
  • Any agent, contractor or third party firms engaged by Sona Asset Management or our affiliates, including without limitation, brokers, fund administrators, accounting support firms and compliance/operational support service providers;
  • Any agents of Sona Asset Management who need to know that information in order to provide services to its investors;
  • Any third party for promotional or marketing purposes in relation to the products and services of Sona Assessment Management and/or our affiliates, with your consent;
  • Any applicable regulators, exchanges, government bodies, tax authorities or other industry recognized bodies located inside or outside Hong Kong;
  • Any third party as required by any applicable law, rules and regulations, codes of practice or guidelines of any applicable jurisdiction, or as required by an order by a court of competent jurisdiction; and/or
  • Any other third parties who you consent to share your data with.

Sona Asset Management will require such third parties to protect the confidentiality of your personal data and to use the personal data only for the purposes for which it is disclosed to them. Where we share or transfer your personal data outside of Hong Kong, we will ensure that the overseas recipients’ processing of your personal data meets the personal data protection standards prescribed by applicable laws and regulations.

Will your personal data be used for direct marketing?

Subject to obtaining your consent where required by law, we may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. We do not share your information with non-affiliates for them to market their own services to you. We may disclose information you provide to us to companies that perform marketing services on our behalf, such as any placement agent retained by the Funds that Sona Asset Management and/or its affiliates manages and/or advises, subject to obtaining your consent where required by law.

If you change your mind on which communications you would like to receive or how you would like to receive them or you decide that you do not wish to receive direct marketing communications any more, you can unsubscribe at any time by contacting us at [email protected].

What are your rights?

You have a right to request access to, and request correction of, your personal data. Requests for access and correction should be
addressed to Sona Compliance at [email protected] .

Who should I direct questions to?

If you have any questions about this privacy policy or how we handle your personal data, you can contact the offices of Sona Asset
Management at [email protected] / +44 (0)20 3872 4572 .

Candidate Data Protection Notice and Privacy
Policy

Sona Asset Management and its affiliates (together “we” of the “Company” operate in different countries and some of these countries have laws related to the collection, use, transfer and disclosure of personal information, including those of our job applicants (“candidates”). The purpose of this Candidate Data Protection Notice and Privacy Policy (“Candidate Notice”) is to give you information about what personal information we collect and why, to whom we disclose it, and how we protect it, as well as your respective privacy rights under applicable laws..

This Candidate Notice applies to you to the extent that you provide or have provided your personal information in your capacity as a job candidate for a position at Sona Asset Management, either as an employee or as non-employee staff.

The Company is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does the Company collect?

The Company collects a range of information about you. This includes:

  • your name, address and contact details, including email address and telephone number; talent management information (e.g., degrees, licenses, trainings, professional references, work experience, job titles and duties, seniority, educational history, any role or roles for which you are applying or being considered, and other information about you that you provide in a CV or similar document);
  • whether or not you have a disability for which the Company needs to make reasonable adjustments during the recruitment process;
  • information about your entitlement to work ; and
  • Details of any FCA controlled function status.

The Company may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests such as psychometric testing.

The Company may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records check or screenings. The Company will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Why does the Company process personal data?

The Company needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.

In some cases, the Company needs to process data to ensure that it is complying with its legal obligations and those required by the FCA or SEC. For example, it is required to check a successful applicant&#39;s eligibility to work in the UK before employment starts.

The Company has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the Company to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The Company may also need to process data from job applicants to respond to and defend against legal claims.

The Company may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. It may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. The Company processes such information to carry out its obligations and exercise specific rights in relation to employment.

For some roles, the Company is obliged to seek information about criminal convictions and offences. Where the Company seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

If your application is unsuccessful, the Company may keep your personal data on file in case there are future employment opportunities for which you may be suited. The Company will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

Your information may be shared internally for the purposes of the recruitment exercise which may include managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles,

The Company will also share your data with our third party outsourced HR provider if they are involved in the recruitment process. However, the Company will not share your data with other third parties, unless your application for employment is successful and it makes you an offer of employment. The Company will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.

Your data may be transferred outside the European Economic Area (EEA).

How does the Company protect data?

The Company takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

For how long does the Company keep data?

The Company will not retain your personal information for longer than is necessary in relation to the purposes for which your personal information is processed. The criteria used to determine our retention periods are:

  • The duration of your application and recruitment process;
  • As required by a legal obligation to which we are subject; and
  • As advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

Subject to applicable law, some personal data will be retained after the application and recruitment process ends, either because you are employed or otherwise engaged by us or, if your application is withdrawn or unsuccessful.

Your rights

Depending on the applicable laws in your country of resident, you may have certain rights related to your personal information. For example, the right to:

  • access and obtain a copy of your data on request;
  • require the Company to change incorrect or incomplete data;
  • require the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
  • object to the processing of your data where the Company is relying on its legitimate

interests as the legal ground for processing. If you would like to exercise any of these rights, please contact [email protected]

Depending on your country, you may have the right to lodge a complaint with your local data protection authority if available. If you believe that the Company has not complied with your data protection rights, you can complain to the Information Commissioner.

  • United Kingdom – Information Commissioner’s Office https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/
  • Hong Kong – Office of the Privacy Commissioner for Personal Data, Hong Kong, https://www.pcpd.org.hk/

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the Company during the recruitment process. However, if you do not provide the information, the Company may not be able to process your application properly or at all.

Automated decision-making

Recruitment processes are not based solely on automated decision-making.