Frazier & Deeter’s Privacy Policy
Last Updated: October 20, 2024

 

Frazier & Deeter, LLC, and its affiliates (collectively, “FD,” “we,” “us,” or “our”) developed this Privacy Notice to explain how we collect, use, share, and protect Personal Data (defined below), and to make you aware of your choices about the collection and use of Personal Data.

 

1. Scope

This Notice applies when you use or access the website, www.frazierdeeter.co.uk, www.frazierdeeter.com, www.fdopportunities.com, www.fdrealassets.com,  and their subdomains or portals (collectively, the “Site”); or otherwise provide Personal Data or interact with us online or in-person. We refer to all of the above as “Services.” Our Services are used by our Clients (“Clients”), individuals who visit our Site (“Site Visitors”) and individuals applying for employment with FD (“Employment Applicants”). By using the Services, you agree to our Terms of Service.

Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to benefit from our Services if that Personal Data is necessary to provide you with the Services or if we are legally required to collect it.

If you have any questions about this Privacy Notice, please contact us using the information in the How to Contact Us section below.

2. What Is Personal Data?

“Personal Data” is information that, either alone or in combination with other information, identifies you. Examples of Personal Data include, among others, name, email address, phone number, and mailing address. When we combine Personal Data with other information (i.e., information that does not, on its own, identify you), we treat the combined information as Personal Data.

3. Personal Data We Collect and Use

A. Data We Receive from Clients

Our Clients may provide us with Personal Data from time to time in the course of our engagement with them. Personal Data obtained from or relating to Clients or former Clients may be subject to additional limitations and protections under our Code of Ethics, applicable codes of professional conduct, laws, regulations, and the terms of our engagement letter or other agreements in place with our Clients that outline the services being provided and use restrictions in place regarding Personal Data.

B. Data We Receive from Site Visitors

In various places on the Site, we request information, including Personal Data, from you via forms. The exact information we need to collect will depend on the purpose of the form. We will indicate on the form whether a particular field of information is mandatory or optional. If you choose not to provide certain information, we may not be able to provide the requested services. We collect Personal Data as follows:

  • Contact information such as name, email address and phone number when you sign up for our newsletter; register to receive some of our proprietary content such as webcasts, articles, whitepapers and videos; complete a survey; request information about our services; or sign up to participate in one of our events.
  • Contact information; professional employment history and education; and information about your gender, race, disability status and veteran status when you apply to work at FD.

C. Data We Receive from Third Parties

We collect Personal Data from Third Parties such as business partners and other vendors that provide such information to companies like ours. Specifically, we collect contact information such as name, company, email address, and phone number in the form of mailing lists.

D. Data We Receive from Employment Applicants

We may collect the following Personal Data from Employment Applicants:

  • Contact information such as your first and last name, email address, home or business address, shipping address, telephone numbers, mobile numbers;
  • Your current or past employment or educational information;
  • Relevant licenses and certifications; and/or
  • Other information that could reasonably be used to identify you personally.

E. Data We Receive from Your Use of the Site

We collect the following types of information automatically from Clients, Site Visitors and Employment Applicants through your use of the Site:

Cookies, Device Identifiers, and Similar Technologies

When you use or access the Site, we use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect information about how you use the Site. We process the information collected through such technologies, which may include Personal Data, to help operate certain features of the Site (e.g., to prevent online poll participants from voting more than once), to enhance your experience through personalization, and to help us better understand the features of the Site that you and other users are most interested in.

Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of device identifiers. If you choose to reject cookies or block device identifiers, some features of the Site may not be available or some functionality may be limited or unavailable. Please review your help pages of your browser or mobile device for assistance with changing your settings.

To help you make an informed choice concerning your acceptance of cookies on the Site, we have prepared the following overview:

Essential (Strictly Necessary Cookies)

Essential cookies enable you to navigate our Site and use certain features, such as accessing secure areas of our Site and using other features of our service that require us to keep track of certain information as you navigate from page to page. Although some of these cookies are “required” to enable certain functionality, you can disable them in the browser, but doing so will limit your ability to use the features supported by such cookies (e.g., automatic log-in).

Functionality Cookies

Functionality cookies are cookies that support features of the Site, such as remembering your preferences.

Example of functionality cookies: remembering your email address in order to view select videos and recorded webinars/podcasts which are hosted in wistia.com.

Performance Cookies

These cookies collect information about how you use our Site, including which pages you go to most often and if they receive error messages from certain pages. These cookies are only used to improve how our Site functions and performs.

Example of performance cookies: _ga, _gid, _gat: Allows tracking various statistics relating to Website and Service usage through Google Analytics.

Tracking or Targeting Cookies

From time-to-time, we may engage third parties that track individuals who visit our Site. These third parties may track your use of the Site for purposes of providing us with certain marketing automation features (to help us improve our outreach to current and prospective Clients) and providing you with targeted advertisements.

Example of tracking and targeting cookies: visitorid: Used by Pardot, a SalesForce marketing automation tool, to track use of our Site.

Some of our service providers may use cookies or other methods to gather information regarding your use of the Site and may combine the information in these cookies with any Personal Data about you that they may have. The use of such tracking information by a third party depends on the privacy policy of that third party. Because we do not engage in such tracking, we do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com.

Log File Data

When you use our Site, our servers automatically record information, including your Internet Protocol address (“IP Address”), browser type, referring URLs (e.g., the site you visited before coming to our Site), number of clicks, and how you interact with links on the Site, domain names associated with your internet service provider, pages viewed, and other such information (collectively, “Log File Data”). We may also collect similar information from emails sent to you which then help us track which emails are opened and which links are clicked by recipients. We use Log File Data collected from our implementation of the Site to further our legitimate interests in securing the Site by identifying potential threats and vulnerabilities, and in analyzing the effectiveness of our Site to improve the Site’s function and content.

Location Data

To help personalize our Site and to better understand the demographics of users of our Site, we may use information derived from your IP address to estimate your location (roughly at the precision of your postal code). If we require access to more precise location data to provide you a certain feature (e.g., to help you identify nearby opportunities), we will only access your device’s location in accordance with the consent that you provide through your browser or device, which you may revoke at any time by following the instructions provided by your browser or device manufacturer.

Third Party Advertising

We share information about your use of our Site, and your interaction with our ads on other websites with advertising partners to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit educational pages from the Network Advertising Initiative (https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work) or the Digital Advertising Alliance (https://youradchoices.com/).

You can opt out of targeted advertising by visiting the following:

F. Data Made Available through Client Portals

We offer an investor portal for Client investors through a third-party vendor. For your convenience and to help ensure the security of transmission, we provide you with access to financial records, which contain Personal Data, through these portals. For more information regarding how we collect, use, disclose, and protection Personal Data collected through these portals, please refer to the privacy notice published on the portal.

4. How We Use Personal Data

We use Personal Data from you for various purposes depending on the context in which we collected it. For example, on our Site, we collect contact information from you if you wish to sign up for our newsletter so that we can send you information on regulatory requirements, emerging trends, and upcoming events. As another example, we or one of our service providers collect survey information from you to help us improve our events and services.

In other words, we process Personal Data with your consent, as necessary to provide the Site, or for our legitimate interests, such as:

  • Enabling secure use of the Site (e.g., log-in for secure areas);
  • Providing, analyzing, administering, and improving the Site and our services;
  • Contacting you in connection with our Site and certain services, notifications, events, programs, offerings, or surveys that you may have registered for or participated in;
  • Sending you communications about our company and services, including webinars and events;
  • Sending you newsletters and other information that you have registered for, requested, or which you may be interested;
  • Responding to inquiries regarding the Site;
  • Processing job applications and other human resources administration purposes;
  • Protecting our rights or our property;
  • Meeting legal obligations;
  • Providing services within the scope of our engagement with a Client;
  • For other purposes related to the reasons for which you provide Personal Data.

5. Disclosure of Personal Data

We will not disclose your Personal Data except as set forth in this Privacy Notice or with your consent. In particular, we do not sell, lease, or exchange your Personal Data.

This section describes to whom we disclose Personal Data, and for what purposes:

  • Our Service Providers. We employ service providers to perform tasks on our behalf and to assist us in providing the Site. For example, among other services, we use third parties to provide services such as website analytics, document repository software, job application processing, customer satisfaction surveys, marketing, customer relationship management, and video- and podcast-hosting. We take reasonable steps to help ensure our service providers provide at least the same level of protection for Personal Data as we do.
  • Companies Involved in Mergers and Acquisitions Transactions. If we sell or otherwise transfer part or the whole of FD or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, or liquidation), any information collected through the Site, including Personal Data, may be among the items sold or transferred.
  • Law Enforcement, Government Agencies, and Courts. We may disclose Personal Data at the request of law enforcement or government agencies or in response to subpoenas, court orders, or another legal process to establish, protect, or exercise our rights or to defend against a legal claim or as otherwise required or allowed by law, or to protect the rights, property, or safety of any other person. We may also disclose Personal Data to investigate or prevent a violation by you of any contractual or other relationship with us or your illegal or harmful activity.

6. Personal Data Transferred from Outside the US

If you are using the Site from outside the United States, please be aware that Personal Data may be transferred to, stored, and processed in the United States. Although we take steps to provide adequate safeguards, the data protection laws of the United States might not be as comprehensive as those in your country. By using the Site, you consent to your information being transferred to the United States for the purposes described in this Privacy Notice.

7. How We Protect the Confidentiality of Personal Data

FD strives to protect the confidentiality and security of information we obtain in the course of business. Our Code of Ethics, which applies to all employees, restricts the use of personal non-public information (that includes Personal Data as defined in this Privacy Notice) and requires that it be held in strict confidence. We also use reasonable safeguards, such as industry-standard encryption technology, to help keep the information collected through the Site secure.

Despite these efforts to store Personal Data in a secure operating environment that is not available to the public, we cannot guarantee the security of Personal Data during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Data, we cannot guarantee that our security measures will prevent third parties such as so-called hackers from illegally obtaining access to Personal Data. We do not represent or warrant that Personal Data about you will be protected against, loss, misuse, or alteration by third parties.

8. Children’s Privacy

FD does not knowingly collect or solicit any Personal Data from children other than information that may be required for the preparation of individual tax returns. In the event that we learn that we have collected Personal Data from a child without parental consent, we will promptly take steps to delete such information. If you believe that we have received Personal Data from a child under the age of 16, you may contact us at privacy@frazierdeeter.com to request deletion of that information.

9. Your Privacy Choices

We hope to ensure that the Personal Data we possess is always accurate and therefore we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Data under applicable law. We take every reasonable step to ensure that the Personal Data that we process are limited to the Personal Data that are reasonably required in connection with the purposes set out in this Privacy Notice.

If you would like to access, amend, erase, export, or object to or restrict the processing of Personal Data about you, you may submit a request to privacy@frazierdeeter.com. We will promptly review all such requests in accordance with applicable laws. When we process Personal Data about you on behalf of a Client, we must act on our Client’s instructions—including with regard to how to respond to your request.

10. Retention of Personal Data

FD will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

All information you provide to us is stored on our secure servers or those of our third-party data storage providers.

We have implemented measures intended to ensure that we will delete your personal data when it is no longer needed to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. Note, however, that if we have a legitimate interest in retaining the data, or if we are required to do so by applicable law, we will retain the data in accordance with our data retention policies.

In some circumstances we may choose to anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

11. Your Rights Under the General Data Protection Regulation

This Section of our Privacy Notice applies if you are a data subject who resides or is located in the European Economic Area (“EEA”). This Policy is intended to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this Section.

Under applicable law, we may be considered a “data controller” or “data processor” of the personal information we handle under this Notice. In other words, FD may be responsible under applicable law for deciding how to collect, use, or disclose this information, or may instead be contracted to “process” personal information in conjunction with services we provide to a data controller, such as an employer. If you have questions about the circumstances in which we may act in these different capacities or how we may process Personal Data, you may contact us at privacy@frazierdeeter.com.

If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:

  • The right to access, update or delete the information we have collected from you. You can access, update, or request deletion of your Personal Data by using the contact information below.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your Personal Data.
  • The right to data portability. You have the right to be provided with a copy of the information we have about you in a structured, machine-readable, and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where FD relied on your consent to process your Personal Data.

A. Legal Basis for Processing Personal Data

We rely on the following legal bases for processing your Personal Data:

  • We may process Personal Data that you provide to us when you interact with our Services, such as commenting in our community blog, watching our videos, or registering for our newsletter, seminars, or podcasts; or when such processing is necessary to respond to or implement your request prior to entering into a contract with us.
  • When you apply for employment through our Site, we will process your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) as necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you send through our Site.
  • We use account-related data to set up accounts for users in our platform and to administer and support those accounts (such as usernames, email address and billing information), provide you with access to the Services, contact you regarding your use of the Services or to notify you of important changes to the Services. Such use is necessary for the performance of the contract between you and us.
  • We will send you information by email regarding our new services or other promotions if you opt-in to receiving communications from us. If you do not provide us with your consent to the processing of your Personal Data for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below.
  • Our use of data relating to your use of the Site and/or the Services, described above, is necessary for our legitimate interests in understanding how the Site and the Services are being usedand to improve your experience on the Site and with our Services offerings. We have also a legitimate interest in aggregating and/or anonymizing the information that we collect through our Site and/or the Services and using this information for our business purposes, as described above. When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on you unless those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below.

B. How to Exercise Your Rights Under GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the contact details below. You may make a request related to your Personal Data or on behalf of someone for whom you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA in order to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us as follows:

Frazier & Deeter
Tower 42
Level 32, Leaf A
25 Old Broad Street
London EC2N 1HQ
United Kingdom

main: +44 (0) 203 318 3976

12. Your Rights Under the UK GDPR

If you are based in the United Kingdom, the following provisions also apply:

UK GDPR means the Retained Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

If we share your personal data within FD or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the international data transfer addendum to the European Commission’s Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.

You have the same data subject rights as those for the EU listed above, except that references to the “GDPR” should be read as references to the “UK GDPR” and complaints should be filed with the UK supervisory authority, the Data Commissioner’s Office.

13. Opting Out of Receiving E-mail Communications

With your permission, we may send notifications, newsletters, promotions, or other information via email (“Communications”). You may follow the unsubscribe instructions in any email you receive. You may also send a global unsubscribe request to privacy@frazierdeeter.com.

14. Other Websites and Services, Including Social Media

We are not responsible for the practices employed by any websites or services linked to or from our Site, including the information or content contained within them. A link to a third party’s website should not be construed as an endorsement by FD. We encourage you to investigate and ask questions before disclosing your Personal Data to third parties, including social media sites on which you choose to share your FD content.

15. Changes to Our Privacy Notice

We may modify or update this Privacy Notice from time to time, so please review it periodically. We may provide you with notice of material changes to the Privacy Notice as appropriate under the circumstances. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY NOTICE WILL APPLY IMMEDIATELY UPON POSTING TO THE SITE.

16. How to Contact Us

If you have any questions about this Privacy Notice or the Site, please email us at privacy@frazierdeeter.com or call 866.226.2104 or write to:

Data Privacy Officer
Frazier & Deeter
Tower 42
Level 32, Leaf A
25 Old Broad Street
London EC2N 1HQ
United Kingdom