Privacy Policy
(Effective Date: 1 st January, 2017)
“Westchester International Group” along with its shareholders, employees, subsidiaries,
affiliates (collectively, “Westchester”, “us” or “we”) fully understand and appreciate that your
privacy is important to you. We are committed to respecting your privacy and protecting your
personal data, which is any information that is capable of identifying you as an individual
person.
This “Privacy Policy” describes how we handle and protect your personal data in connection
with Westchester's business activities, like conferences and events, and client services, and on
websites, applications, and communications that post a link to this Privacy Policy (collectively,
“the Sites”), in our capacity as data controllers.
Information we Collect
Westchester collects personal data in the course of its business activities, including in
connection with some client services. We also collect personal data on certain areas of the Sites
when you register for or apply for jobs through our Recruitment Portal, create a user profile,
register for Westchester newsletters and alerts, sign up for conferences and events, and/or
participate in public user posting areas (such as bulletin boards, podcasts, discussion forums
and surveys). The personal data collected varies and may include information that you provide,
such as your name, mailing address, e-mail address, telephone number, fax number, and
background information required to apply for a job.
We may also automatically collect information about the devices you use to interact with our
Sites. The information we automatically collect may include IP address, device identifier, web
browser, and browsing information collected through cookies, web beacons, pixels, clear gifs,
and other similar technologies (collectively “Cookies and Other Tracking Technologies”) on our
Sites. We may also automatically collect information about how you use the Sites, such as what
you have searched for and viewed on the Sites. The information automatically collected may be
associated with a unique identifier as well as with any other personal data you have provided.
Westchester may also collect personal data about you from third parties, such as data brokers
or aggregators, in the course of its business activities including in connection with some client
services. This includes demographic, professional and other information that is publicly
available online, including information you choose to make public through social media
platforms and other public online forums. We may combine this data with existing information
we have about you or use it independently, for the purposes of our benchmarking and data
analytics activities (e.g., analysis of recruiting practices across an industry, detecting fraud
patterns in connection with financial transactions, foot traffic in retail environments). We will
always seek to confirm that the third party has provided transparent information about its use
of this data, including its disclosure to third parties, in compliance with applicable law.
Use of information
Westchester uses your personal data to fulfill your requests for information, process your
requests to participate in conferences and events, personalize content that you view or receive
on the Sites, evaluate and improve our services, distribute newsletters and alerts to you, recruit
and evaluate job applicants, analyze the Sites’ performance and functioning, publish your
letters to the editor or comments, prevent fraud, enforce our terms of use, comply with all
applicable laws and corporate reporting obligations, enforce Westchester’s agreements, and
accomplish other purposes you may initiate or request. In some situations, the collection of
personal data may be required for the operation of the Sites, or we may use it in the course of
our business activities, including in connection with some client services, for example, to
provide certain services or products such as our benchmarking products. We may combine
and/or analyze personal data to evaluate and offer content and services most relevant to you.
We may keep any of your personal data on file and use it to contact you.
Westchester and its service providers may use first and third party Cookies and Other Tracking
Technologies, including web beacons, to manage our Sites and our services and collect analytics
about how you use them. Westchester and its service providers may collect information about
whether you open or click any links in the knowledge, research or event communications that
we send to you. The information provided throughout this Privacy Policy about cookies also
applies to these other tracking technologies.
Our Sites do not track you by collecting personal data about your online activities over time and
across third party websites or online services. Accordingly, we do not alter our data collection
and use practices in response to “do not track” signals transmitted from web browsers.
Use of information collected via mobile devices
In connection with our mobile applications, we may use third party service providers to analyze
user activity to fix errors, monitor usage, and improve the performance of the mobile
applications. For example, Westchester receives reports on some of our mobile applications’
aggregate usage and browsing patterns, including information about the type of device used,
articles accessed, and other events occurring within our apps. Westchester also receives
reports on certain errors occurring within mobile applications.
The legal basis by which we process your personal data
Our processing of your personal data for the purposes mentioned above is based:
– in part, on our legitimate interests in promoting and protecting Westchester, building
and maintaining relationships. recruitment, and providing our services;
– in part, on your consent, for example if you create a user profile, or register for our
newsletters or alerts, or for business purposes that support web operations such as
understanding and enhancing the quality of your experience on our web-sites;
– in part, to comply with the law, when certain information is necessary to satisfy our
legal or regulatory obligations.
Legal
Westchester International is a Limited Liability (SMC Private) Company duly incorporated, licensed, and regulated by the Securities and Exchange Corporation of Pakistan (SECP).
Disclaimer
We are neither a financial institution nor an NBFI. Our services are limited to providing ‘best practice consulting’ to our clients on ‘good faith basis’ based on the data and information provided by our clients. Our consulting services and advice should not be deemed as a guarantee for business success or monetary gains. We and/or our employees, affiliates, partners, and advisers are not liable or responsible for any direct or indirect loss incurred or damage caused to our clients and/or their owners or employees or any related parties thereof.
Disclosure of personal data: data recipients and international data transfers
Personal data collected in the course of our business activities, including in connection with
some client services, as well as on the Sites may be transferred from time to time to
Westchester subsidiaries and affiliates and their personnel across our global organization, as
well as to our third party service providers located throughout the world, including in countries
where the local law may grant you fewer rights than you have in your own country.
Additionally, the Sites may be viewed and hosted by Westchester and our third party service
providers anywhere in the world. Where required by law, we have put in place legal
mechanisms designed to ensure adequate data protection of your personal data that is
processed by Westchester subsidiaries, affiliates and third party service providers, including the
transfer of your personal data to countries other than the one in which you reside. If you would
like more information about these legal mechanisms, which may include the EU’s Standard
Contractual Clauses, please contact us at the address below. By using any of the Sites and
providing information on any of them, you voluntarily consent to such trans-border transfer
and hosting of such information.
Westchester will not intentionally disclose or transfer (and will take reasonable steps to prevent
the unauthorized or accidental disclosure of) your personal data to third parties without your
consent or as otherwise permitted by law, whether for such third parties’ own marketing
purposes or otherwise, except as follows. We may provide access to your personal data to third
party service providers engaged by us to provide services related to the Sites as well as related
to our business activities, including in connection with some client services, in the manner
agreed upon in our client services agreements.
We maintain processes designed to ensure that
any processing of personal data by third party service providers is consistent with this Privacy
Policy and protects the confidentiality, availability, and integrity of your personal data.
We also may share your personal data with third party service providers who perform services
and functions on our behalf to support our interactions with you, including, for example,
processing recruitment materials, administering surveys or contests, or communicating with
you.
In addition, we may disclose information about you:
– If we are required to do so by law or legal process;
– To law enforcement authorities or other government officials;
– When we believe disclosure is necessary or appropriate to prevent physical harm or
financial loss or in connection with an investigation of suspected or actual illegal activity;
– If disclosure is necessary to protect the vital interests of a person;
– To enforce our terms and agreements;
– To protect our property, services and legal rights;
– To prevent fraud against Westchester, our shareholders and employees, our
subsidiaries, affiliates and/or business partners;
– To support auditing, compliance, and corporate governance functions; or
– To comply with any and all applicable laws.
– In addition, we may disclose or transfer your personal data in the event of a re-
organization, merger, sale, joint venture, assignment, or other transfer or disposition of
all or any portion of our business.
User forums
You should be aware that whenever you publicly disclose information online, that information
could be collected and used by others. Westchester is not responsible for any action or policies
of any third parties who collect information that users publicly disclose in any such forums on
the Sites.
Link to third party sites
We may provide links to third party websites or information as a service to our users. If you use
these links, you will leave the Sites. Such links do not constitute or imply an endorsement,
sponsorship, or recommendation by Westchester of the third party, the third party website, or
the information contained therein, and we shall not be responsible or liable for your use
thereof. Such use shall be subject to the terms of use and privacy policies applicable to those
sites.
Social Networking
The Sites may allow you to sign into and associate your social network accounts including, but
not limited to, Twitter, LinkedIn, Facebook, and YouTube, with Westchester. The Sites also may
allow you to log in to a Westchester account using certain social network account credentials.
By associating your social network account with Westchester or logging in to a Westchester
account using your social network account credentials, you formally give us permission to
access information that you have made available in your public profile for that social network
account. The information available in your public profile varies based on the social network and
your settings, but may include your email address, real name, profile picture, gender, and
location. We use the information we receive from your social network account in accordance
with the social network’s terms of use and this Privacy Policy. Please refer to the privacy
settings in your social network account for information about what data is shared with
Westchester and other connected applications and to manage the data that is shared through
your account, including information about your activities using our Sites.
If you would like to disconnect a social media account from us, refer to the settings of that
social network account and its provider.
Security
Westchester has implemented generally accepted standards of technology and operational
security to protect personal data from loss, misuse, alteration, or destruction. Only authorized
personnel and third party service providers are provided access to personal data, and these
employees and service providers are required to treat this information as confidential. Despite
these precautions however, we cannot guarantee that unauthorized persons will not obtain
access to your personal data.
Data retention
Westchester retains personal data, as necessary, for the duration of the relevant business
relationship.
We may also retain personal data for longer than the duration of the business relationship
should we need to retain it to protect ourselves against legal claims, use it for analysis or
historical record-keeping, or comply with our information management policies and schedules.
If you request that we delete your personal data, we will make reasonable attempts to delete
all instances of the information in their entirety. For requests for access, corrections, or
deletion, please refer to the “Your Rights” section of this Privacy Policy.
Children
The Sites are not designed for or directed at children 16 years of age or younger, and
Westchester does not intentionally collect or maintain personal data about anyone under this
age.
Westchester Recruitment portal/Training and Coaching
Through our Recruitment portal, you can apply for positions with us or sign up for job openings
or training and coaching opportunities that might be of interest.
Your rights
Where granted by applicable law, you may have the right to request access to the personal data
that we have collected about you for the purposes of reviewing, modifying, or requesting
deletion of the data. You may also have the right to request a copy of the personal data that we
have collected about you and to have any inaccuracies in that data corrected. In certain
circumstances, you may also request that we cease processing your personal data.
If you would like to make a request to access, review, or correct the personal data Westchester
has collected about you, or to discuss how we process your personal data, please contact us at
our email. To help protect your privacy and security, we will take reasonable steps to verify
your identity, such as requiring a password and user ID, before granting access to your personal
data. We will make reasonable attempts to promptly investigate, comply with, or otherwise
respond to your requests as may be required by applicable law. Different laws may prevent us
from providing access to your personal data or otherwise fully complying with your request
depending upon the circumstances and the request, such as for example, where producing your
information may reveal the identity of someone else. We reserve the right to charge an
appropriate fee for complying with your request where allowed by applicable law, and/or deny
your requests where they may be manifestly unfounded, and/or excessive, or otherwise
objectionable or unwarranted under applicable law.
In addition, and where granted by local law, you have the legal right to lodge a complaint with a
competent data protection authority.
Unsubscribe
If you have registered for Westchester newsletter, blog, podcast or alerts, or you receive
invitations to survey or events from us you prefer not to receive future email communications
from us, please review the communications settings in your profile on our portal, follow the
instructions on the page of the Site where you have provided such information, subscribed or
registered or email us to unsubscribe from communications.
Consent and changes to Privacy Policy
By using the Sites, you consent to the collection, use, and storage of your personal data by
Westchester in the manner described in this Privacy Policy and elsewhere on the Sites. We
reserve the right to make changes to this Privacy Policy from time to time. We will alert you to
any such changes by updating this Privacy Policy. If we make material changes to this Privacy
Policy that increase our rights to use personal data that we have previously collected about
you, we will obtain your consent either through an email to your registered email address or by
prominently posting information about the changes on our Sites.
Contact us
If you have any questions about our Privacy Policy or if you would like to communicate with our
EU Data Protection Officer or the Data Privacy Team, please contact us via email at:
[email protected]