Additional EEA Privacy Disclosures

The Following EEA Privacy Disclosures (the “Disclosures”) provide information about the collection, use, processing and sharing of data about individuals located in the European Union, Iceland, Liechtenstein or Norway (European Economic Area” or “EEA”).

In these Disclosures,

“GDPR” means the European Union’s General Data Protection Regulation;
“Personal Data” means information that relates to an individual who is directly or indirectly identified or identifiable; and
“EEA Processing Activities” means the collection, use, processing or sharing of Personal Data when those activities are within the scope of the GDPR.

These Disclosures apply only to the use of Personal Data in EEA Processing Activities. Further, these Disclosures apply only to parties that link to these Disclosures or expressly adopt them in writing. In these Disclosures the words “we” or “our” refer to each such expressions or activities.

These Disclosures apply to EEA Processing Activities by any means, including hardcopy (such as paper applications or forms) and electronic means (such as websites and mobile applications).

How We Collect and Use Personal Data

Brun Lubert Global Debt Securities LLC (“Brun Lubert”, “we”, or “us”) collects several categories of Personal Data in Circumstances that may involve EEA Processing Activities, including data you provide, data collected automatically (potentially including location data), and data we obtain from third party sources.

We use the Personal Data that we collect to carry on various activities related to the preparation, execution and distribution of our media entertainment productions. As described in more detail below, we rely on a number of legal bases to lawfully process your Personal Data.

The ways in which Brun Lubert collects and uses your data vary depending on the relationship between you and us. The following sections of these Disclosures describe in more details how we collect and use Personal Data in various circumstances that may involve EEA Processing Activities. Please note that, depending on the situation, some of the processing of Personal Data we do in the various circumstances described below may not fall within the scope of the GDPR.

1. Personal Data We Obtain from You

Websites and Mobile Applications

As is true of most digital platforms, we gather certain data automatically when you use one of our website or mobile applications, such as your IP address, browser type and device type. Certain web-forms also collect Personal Data you provide, for example when you enter the data into form fields on a feedback page. If we also process data through our website or mobile applications for one of the activities described further below, those sections will provide additional information about how data are collected and used. We and our third-party vendors collect Personal Data for the primary purposes of conducting analytics, responding to your requests and providing you with relevant information.

Research

Brun Lubert may collect, use, and share your Personal Data as part of a research study in which you have agreed to participate as a research subject, or in which your existing data are used. Most often, before any Personal Data are collected for research purposes, you will be provided a consent and/or authorization form relating to the specific research project that explains the types of data collected and the purposes for which such data are processed and shared. In such cases, the description of the collection and use of your Personal Data provided in the consent and/or authorisation form will replace the information provided here.

Examples of Personal Data that may be collected for research purposes are listed below. Not every research study will collect each of these types data. If you have questions about the processing of your data in connection with a research study, you should contact our persons who are conducting the research or the contact persons named in any consent form you signed when you joined the study

2. Personal Data We Obtain from Third Party Sources

As part of our EEA Processing Activities, we may obtain certain Personal Data about you from third party sources, which we may use for the purpose and in the ways described in “How We collect and Use Personal Data” above and in “Additional Uses of Personal Data “below. In some cases, we may obtain your consent for additional uses.

Partners and Service Providers

Brun Lubert may use partners and service providers, such as application facilitators and analytics providers (for example Google Analytics), to perform services on our behalf. Some of these partners have access to Personal Data about you that we may not otherwise have (for example, when you sign up directly with that provider) and may share some or all these data with us.

Single Sign-On

Some of our online services or research activities may allow you to register and login to those services through a third-party platform. When you login to our service through a third-party platform, you allow us to access and collect any Personal Data from your third-party platform account permitted under the settings and privacy statement of that platform.

Supplemental Personal Data

Brun Lubert may receive additional Personal Data from third-party sources, such as public or private databases (for example, compilations of email or postal addresses), or companies or institutions which we may also append to existing Personal Data.

3. Additional Uses of Personal Data

In addition to the uses described above, including under “How We collect and Use Information” and “Personal Data We Obtain from Third Party Sources”, Brun Lubert may use your Personal Data for the following purposes. These additional uses may under certain circumstances to you, may be necessary for legal compliance, or are necessary to serve our legitimate interest in the following operations:

Conducting our business operations;
Contacting you to respond to your requests or inquiries;
Providing you with newsletters, articles other information that we believe may be of interest to you;
At your request, processing and fulfilling transactions;
Alerting you about a safety or security announcement;
Conducting research, surveys and similar inquiries;
Disclosing directory information as described here;
Performing marketing, promotion and advertising, either directly or through third-parties;
Preventing, investigating, taking action regarding or providing notice of fraud, unlawful or criminal activity, other misconduct, security or technical issues, or unauthorised access to or use of personal Data, our website or data systems; or
Responding to subpoenas, court orders, or other legal process; enforcing our agreements, protecting the health, safety, rights or property of you, us or others; and meeting legal obligations.

4. Legitimate Interest

We rely on several legitimate interests in using and sharing your Personal Data. These interests include:

Providing, improving and customising our and third parties’ services and products;
Administration of our operations;
Promoting the success of our past, current and future services and products;
Furthering research and understanding in regard to our past, present, and future services and products;
Requesting gifts or donations;
Offering attendance to events and opportunities to volunteer;
Conducting research relevant to our services and products;
Understanding how our online platforms are being used;
Exploring ways to develop and grow our operations;
Ensuring the safety and security of our employees and others;
Cybersecurity;
Enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and
Meeting our obligations and enforcing our legal rights.

5. Data Retention

Brun Lubert will retain your Personal Data for as long as is necessary for the purposes set out in these Disclosures unless a longer period is required under applicable laws, or is needed to resolve disputes or protect our legal rights or otherwise to comply with legal obligations. Where we are processing Personal Data based on your consent, we generally will retain the information for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Data erased (see “Your Rights “below).

Where we are processing Personal Date on contract, we generally will retain the information for the duration of the contract plus some additional limited period for legal claims that could arise from the contractual relationship.

Where we are processing Personal Data based on the public interest, we generally retain the information for the period of that continues to serve that underlying interest.

How we share and Disclose Personal Data

Brun Lubert shares your Personal Data with third-parties in the ways described in these Disclosures. We may share your Personal Data with third parties as described in the “How We collect and Use Personal Data” section above. Additionally, we may share information as described below.

Service Providers

We share your Personal Data with third-party service providers that complete transactions or perform services on our behalf or for your benefit, such as:

Payment and contribution processing;
Customer relationship management (CRM) services;
Marketing and analytics;
Public outreach and engagement;
Events registration and coordination;
Providing platforms or tools that enable or enhance our offerings;
Research insight and analytics;
Research collaboration;
Product and services operations and collaborations;
Performing human resources administration; and
System maintenance and security.

Partners

We may share your Personal Data with others in the course of our day-to-day business, such as events and activities of Brun Lubert Limited and special interest groups or otherwise.

Third-Party Mobile App Providers

With your knowledge and consent, our services on your mobile device may gather and transfer your Personal, including location information, from and to other applications, functions and tools within your mobile device if you use our mobile applications.

Social Media Platforms

We may also use services provided by third parties (such as social media platforms to serve targeted ads or sponsored content on third-party platforms. For more information regarding our use of coolies and similar technologies, see the “Cookies and Similar Technologies” section below.

Legal Process, Safety and Terms Enforcement

We may disclose your Personal Data to legal or government regulatory authorities as required by applicable law. We also disclose your Personal Data to third parties as required by applicable law in connection with claims, disputes or litigation, when otherwise required by applicable law, or if we determine its disclosure is necessary to protect the health, safety, safety, rights or property of you, us or others, or to enforce our legal rights or contractual commitments that you have made.

International Data Transfers

Brun Lubert may transfer your Personal Data between itself and/or to the third parties discussed above. We may transfer your Personal data outside the EEA relying on appropriate or suitable safeguards or Specific derogations recognised under data protection laws, including the GDPR.

The European Commission has adopted standard data protection clauses, which provide safeguards for Personal Data transferred outside of the EEA. We may use Standard Contractual Clauses when transferring Personal Data from a country in the EEA to a country outside the EEA. If your Personal Data are affected, you can request a copy of our Standard Contractual Clauses by contacting us as set forth in the Contact Us section below.

Cookies and Similar Technologies

Brun Lubert may collect Personal Data about you, or information that becomes Personal Data if combined with other information, when you visit or use our websites and online services.

This information may be collected through the use of cookies, which are small data files placed on your computer or mobile device that allow us to collect certain information whenever you visit or interact with our websites or online services. Some of these cookies are managed by us (first-party cookies). This information may also be collected through the use of other data collection technologies (such as web beacons, pixels or tags) that embed graphic files in our websites and online services. These graphic files contain a unique identifier that enables us to recognise when someone has visited our website or online services, or in the case of web beacons, opened an email that we have sent them.

These small data files or graphic files serve various functions:

Strictly Necessary: Necessary to deliver our services and products;
Performance and Functionality: Enhance the performance and functionality of our services and products but are non-essential to their use;
Analytics and Customisation: Allow us to understand the effectiveness of our services , products and marketing campaigns, as well as to customise our services and products based on this information; or
Advertising: Make advertising messages more relevant to you and your interests.

These small data files or graphic files serve various functions:

Opting out of target online advertising through advertising networks (please visit http://www.aboutads.info/choices/, http://optout.networkadvertising.org/?c=1#!/ or http://www.youronlinechoices.com for more information);
If you choose to reject certain cookies and similar technologies, you may still use our websites and online services through your access to some functionality and features may be restricted. If you have any questions regarding our use of cookies and other similar technologies, please contact us as set forth in the “Contact Us” section below.

Your Rights

We will provide you upon your reasonable, good faith request with information about whether we hold any of your Personal Data as part of our EEA Processing Activities, to the extend required by and in accordance with applicable law. In certain cases, you may also have a right, with respect to your Personal Data collected and used in the EEA Processing Activities to:

Correct or update any of your Personal Data that is inaccurate;
To restrict or limit the ways in which we use your Personal Data;
To object to the processing of your Personal Data;
To request the deletion of your Personal Data; and
To obtain a copy of your Personal Data in an easily accessible format.

To submit a request, please send an email to info@brunlubert.com Because we want to avoid taking action regarding your Personal Data at the direction of someone other than you, we will ask you for information verifying your identity. We will respond to your request within a reasonable timeframe.

You also have the right to withdraw your consent to our processing of your Personal Data as part of the EEA Processing Activities, where our processing is solely based on your consent, subject to certain limitations at law. In same cases, you can do this by discontinuing use of the services involved in the EEA Processing Activities. This would include by closing all of your online accounts with us and contacting us at info@brunlubert.com to request that your Personal Data be deleted. If you withdraw your consent to the use or sharing of your Personal Data for the purposes set out in these Disclosures or the Brun Lubert Privacy Policy that link to or expressly adopt these Disclosures, you may not have access to all (or any) of the related services, and we might not be able to provide you all (or any) of the services. Please note that, in certain cases, we may continue to process your Personal Data, if we have a legal basis to do so. For example, we may retain certain data if we need to do so to comply with an independent legal obligation, if we still need the data for the lawful purposes for which we obtained the data, or if it is necessary to do so to pursue our legitimate interest in keeping our services and operations safe and secure.

If you have any complaints regarding our privacy practices, you have the right to make a complaint with your national data protection authority (i.e. supervisory authority).

User Generated Content

Some of our services involved in EEA Processing Activities may enable users to submit their own content. Unless otherwise indicated, please remember that any Personal Data you submit or post as user-generated content could become public information. You should exercise caution when deciding to disclose your personal, financial or other information in such submissions or posts. Brun Lubert cannot prevent others from using that information in a manner that may violate these Disclosures, the law or your personal privacy and safety. We are not responsible for the results of such postings.

Update to the Disclosers

We may update these Disclosures from time to time without prior notice by posting revised Disclosures to this site. You can determine when these Disclosures were last revised by checking the Last Updated date in these Disclosures.

Contact Us

If you have any questions, comments, requests or concerns about these Disclosures or other privacy-related matters, you may contact us in the following ways:

Email: info@brunlubert.com
Attention: GDPR Coordinator