Last revised: March 2, 2019
Sugarwood Financial.com and MitVest.com are comprised of websites in different languages, each of which is provided by Sugarwood Financial.
What information we collect
In the course of providing products or services to you or our client and performing due diligence checks in connection with our products or services (or discussing the possible products or services we might provide), we generally collect personal information about you. We also typically collect personal information about you when you visit or use our Website.
We typically collect or obtain your personal information because you give it to us (for example, in a form on our Website) or because other people give that information to us (for example, third party service providers that we use to help operate our Website or your employer where it receives products or services from Sugarwood Financial). We may also collect or obtain personal information from you because we observe or infer that information about you from the way you interact with us.
The personal information that we may collect depends on the specific services, activities or products we undertake but typically includes: your name; age; date of birth; gender; home address; email address; telephone number; other contact details; country of residence; passport number and other national ID numbers; employment details (for example, the organization you work for, your job title); family circumstances (for example, your marital status where you enter it in a form on our Website or it appears in any documentation you provide to us); financial and tax related information (for example, your income, assets and tax residency where you enter such information in a form on our Website or it appears in any documentation that you provide to us); details of how you use any product or service provided by Sugarwood Financial; postings on any blogs, forums, wikis, and any other social media applications and services that we provide; IP address; browser and device type; user name that is used by you for one of our products or services; language; access times and duration; details of how you like to use our Website or the interactive products, tools, other technology or services we provide to you or our clients; websites that you visited before and after visiting our Website; details of how you like to interact with us, and similar information.
The types of personal information and ‘sensitive’ or ‘special categories’ of personal information that we collect will generally vary depending on the nature of the products and services that we provide to you and how you use our Website. In some cases, the ‘sensitive’ or ‘special categories’ of personal information that we collect include: your dietary requirements (for example, where we would like to provide you with lunch during a meeting); your health (for example, so that we can make reasonable accommodations for you in our buildings); your sexual orientation (for example, if you provide us with details of your spouse or partner); and any criminal convictions that you may have (for example, if this information is collected as part of ‘know your client’ and anti-money laundering checks that we must conduct before accepting you or your employer as a client).
In very rare circumstances, we will also gather other ‘special categories’ of personal information about you because you volunteer that data to us (for example, it appears in a copy of your balance sheet or portfolio statement that you upload to our Website). In some other circumstances, the personal information we collect from you is needed to meet our legal or regulatory obligations or to provide you with the products or services requested by you or our client (who may be your employer). If so, we will indicate to you that the provision of this information is mandatory, and the consequences if we cannot collect this information.
In some cases, we will also collect personal information about you indirectly from third parties such as: (i) your employer where we provide it with products or services; (ii) third parties such as providers of ‘know your client’ and anti-money laundering services which we sometimes use to help us meet our legal requirements in this area and to help us verify your identity where we provide you or your employer with products or services; (iii) intermediaries (such as independent financial advisers); (iv) background check providers which we sometimes use to verify your identity when you apply for a job through our Website; (v) third party service providers that help us to operate our Website; and (vi) from publicly available sources such as business and employment oriented social networking services and jobs boards.
How we use information about you
Use of personal information to provide products and services
We will use your personal information to provide you or our client with products or services. As part of this, we may use your personal information in the course of correspondence relating to those products or services. Such correspondence may be with you, our client, other members of the Sugarwood Financial Group, our service providers or public or judicial authorities with the necessary authorization.
In many cases, we also use your personal information to conduct due diligence checks in advance of providing products or services to you or our client, and to process an application from you or a prospective client to receive products or services from us. If you are referred to us by an intermediary or similar third party, we also typically use your personal information to assess whether to accept or reject your referral to Sugarwood Financial by that intermediary or similar third party.
Because we provide a wide range of products and services to our clients, the way in which we use personal information in relation to our products and services varies. For example, we use personal information about you when:
Use of personal information collected via our Website
We generally use your personal information collected via this Website:
Use of personal information for other activities that form part of the operation of our business
We generally also use your personal information collected via this Website for the purposes of, or in connection with:
The legal grounds we rely on for processing personal information
We generally use your personal information for the purposes outlined above because: (a) it is necessary for our legitimate interests and does not unduly affect your interests or fundamental rights and freedoms (see below); (b) it is necessary for legal and/or regulatory obligations or requests that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency; (c) it is necessary to perform contractual obligations that we owe towards you or our client, or to take pre-contractual steps at the request of you or our client; (d) it is necessary for the performance of a task carried out in the public interest (such as assisting with diversity in the workplace where you make contact through our Website in relation to job opportunities at Sugarwood Financial); or (e) in some cases, we have obtained your prior consent.
Examples of the ‘legitimate interests’ referenced above are: (i) to benefit from cost-effective services (for example, we may opt to use certain IT platforms offered by our service providers); (ii) to assess and verify any job application that you submit through the Website; (iii) to prevent fraud or criminal activity, misuses of our products and services, as well as the security of our IT systems, architecture and networks; (iv) to exercise our rights under Articles 16 and 17 of the Charter of Fundamental Rights of the European Union, including our freedom to conduct a business and right to property; and (v) to meet our corporate and social responsibility objectives.
To the extent that we process any sensitive personal information relating to you for any of the purposes outlined above, we will do so because either: (1) you have given us your explicit consent to process that information; (2) the processing is necessary for reasons of substantial public interest on the basis of applicable law (for example where we are required by law or regulatory requirements to process that information in order to ensure we meet our ‘know your client’ and ‘anti money laundering’ obligations); (3) the processing is necessary to carry out our obligations under employment, social security or social protection law; or (4) the processing is necessary for the establishment, exercise or defense of legal claims. The legal grounds for processing sensitive personal information outlined above at (1) to (4) appear at Articles 9(2)(a), 9(2)(g), 9(2)(b) and 9(2)(f) of the EU’s General Data Protection Regulation respectively.
Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you.
If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function in the communication or e-mail
firstname.lastname@example.org at any time.
To whom we disclose your information
In connection with one or more of the purposes outlined in the “How we use information about you” section above, we generally disclose details about you to: other members of the Sugarwood Financial Group; competent authorities (including any national and/or international regulatory or enforcement body or court or other form of tribunal, where we (or any other member of the Sugarwood Financial Group) are required to do so by applicable law or regulation at their request); and any central or local government department and other statutory or public bodies.
If you are an individual in the European Union, please note that some of the recipients of your personal information referenced above will be based in countries outside of the European Union whose laws may not provide the same level of data protection. Those countries typically include: the United States, Canada, Singapore, and India. In such cases, Sugarwood Financial will ensure that there are adequate safeguards in place to protect your personal information that comply with our legal obligations. To ensure this level of protection for your personal information, Sugarwood Financial typically uses a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission. A copy of these clauses is available here: https://ec.europa.eu/info/law/law-topic/data-protection_en. Further details of the transfers of your personal information outside of the European Union and the adequate safeguards used by Sugarwood Financial in respect of such transfers (including copies of relevant agreements) are available from us by contacting email@example.com. You can also use this e-mail address to request further information about the entities that comprise the Sugarwood Financial Group and the countries in which they operate.
How long we keep your personal information
We will hold your personal information on Sugarwood Financial’s systems for as long as is necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.
Protection of your personal information
We use a range of physical, electronic and managerial measures to ensure that we keep your personal information secure, accurate and up to date. These measures include:
Although we use appropriate security measures once we have received your personal information, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal information, but we cannot guarantee the security of data transmitted to us or by us.
Your rights and how to contact us
You have various rights in relation to your personal information. In particular, you have a right to:
To exercise any of your rights, or if you have any other questions about our use of your personal information, please e-mail firstname.lastname@example.org. You may also use these contact details if you wish to make a complaint to us relating to your privacy.
If you are unhappy with the way we handled your personal information or any privacy query or request that you have raised with us, you also have a right to complain to a data protection regulator in the place where you live or work, or in the place where you think an issue in relation to your data has arisen. A list of national data protection regulators can be found here:
Changes to this privacy statement
We may modify or amend this privacy statement from time to time.
Any future changes or additions to the processing of your personal data as described in this notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.
What are cookies?
Cookies are small text files that are stored in your computer’s memory and hard drive, in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website, or other third parties which receive data obtained from that website.
When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience.
Your cookie preferences
Cookies are necessary in order for you to be able to make full use of Sugarwood Financial’s Website. In addition, cookies help us provide you with personalized features on our Website. If you chose to disable cookies, some of Sugarwood Financial’s Website’s functionality might be impaired.
Local Flash Storage
On certain pages of our Website, we include content designed for display using Adobe Flash Player, such as animations, videos and tools. Local flash storage (often referred to as “Flash cookies”) can be used to help improve your experience as a user. Flash storage is retained on your device in much the same way as standard cookies, but is managed directly by your Flash software.
If you wish to disable or delete information stored locally in Flash, please see the documentation for your Flash software, located at www.adobe.com. Please note that, if you disable Flash cookies, some site functionality may not work.
Third party cookies
Amending cookie preferences
The site www.allaboutcookies.org includes instructions for managing cookies on many commonly used browses, or you may consult the vendor documentation for your specific software.
Further information about cookies
If you would like to find out more about cookies in general and how to manage them, please visit www.allaboutcookies.org.