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Privacy policy

Introduction

At Chatham Financial, we know you care about how your personal information is used and shared, and we take your privacy seriously. We believe it is important for you to understand when, how, and why we collect personal information as you use our websites, utilize our products and services, contact us, attend our events, or interact with us in any manner.

This Privacy Policy outlines the scope of our relationship with you and your personal information, and details your rights to control how we use your data. We recognize that one of our fundamental responsibilities is to protect the privacy of the information provided by you, and we endeavor to always be good stewards of your data.

Contents

1. Who is Chatham?
2. What information does Chatham collect and what are the legal bases for such collection?
3. How does Chatham use the information we collect?
4. How do we share and disclose information?
5. What happens if you don’t give us your data?
6. How can you opt out or unsubscribe from Chatham marketing emails?
7. Where is your personal information stored?
8. How long does Chatham retain personal information?
9. Who can access your personal information?
10. How does Chatham use cookies?
11. Does Chatham’s Privacy Policy cover other websites?
12. Important information for UK, EU and Swiss residents
13. Important information for California residents
14. How can you learn if Chatham has updated our Privacy Policy?
15. Who can you contact regarding your personal information?

1. Who is Chatham?

Chatham Financial (“Chatham”) is the largest independent financial risk management advisory and technology firm. A leader in debt and derivative solutions, Chatham provides clients with access to in-depth knowledge, innovative tools, and an incomparable team of nearly 700 employees to help mitigate risks associated with interest rate, foreign currency, and commodity exposures. Founded in 1991, Chatham serves more than 3,500 companies across a wide range of industries — handling over $1 trillion in transaction volume annually and helping businesses maximize their value in the capital markets, every day. To learn more, visit chathamfinancial.com.

The Chatham Financial group of companies are owned by Chatham Financial Corp., which is a United States corporation registered in the Commonwealth of Pennsylvania. As used in this Privacy Policy, Chatham (also “we”, “us”, or “our”) includes all affiliated companies of Chatham Financial Corp.

This privacy policy (“Privacy Policy”) applies to the collection and use of personal information by Chatham, chathamfinancial.com, chathamdirect.com, their subdomains and other affiliated pages. Chathamfinancial.com and chathamdirect.com are comprised of various global, regional, or practice-specific websites and web pages provided by Chatham, one of its affiliated companies, or its subsidiaries (the “Website”).

While the transactional data we collect and store for our clients is not considered to be personal information, please know that we will provide the same care, discretion, and rigorous protection with transaction data as we will with any personal information we collect.

Chatham is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

2. What information does Chatham collect and what are the legal bases for such collection?

Chatham collects certain personal information about our clients, potential clients, and partners. The type of information we collect is based on how you interact with us, including by retaining our services or using our website. You are always welcome to explore our Website without providing any personal information about yourself.

Our legal bases for processing your personal information include our legitimate interests in running and promoting our business; the performance of a contract; legal or regulatory obligations; and/or client consent.

We collect information about our users in the following ways:

A. Information you give us
We will collect any personal information you choose to provide to us, for example, to sign up for an email subscription, request gated content (e.g., download a white paper), register for an event, visit our offices, or contact a Chatham representative. If you contact us, we will retain the correspondence and use any relevant information to respond to your inquiry, inform you of our services, or keep a record of your request.

Examples of the personal information we collect from you include:

  • Name
  • Job title
  • Company name
  • Email address
  • Postal address
  • Telephone number
  • Any other information you choose to provide to us

If you choose to do business with us, Chatham also may also ask you to provide additional personal information for the purposes of on-boarding and performing AML screening as required by applicable law.

B. Information we collect about you
As is typical of most websites, we use cookies, pixel tags, and other similar technologies on our Website to automatically collect certain information about the way you use our services. These tools help us improve the quality, usability, and performance of the services we offer to you through aggregate information that does not reveal your specific identity and cannot reasonably be used to identify any particular individual user.

To learn more about the cookies we use, click here.

Examples of the data we automatically collect include:

  • Device information. We collect specific information about the device you use to access our Website, including device type, model, screen size, operating system, IP address, and network carrier.
  • Usage information. We collect data about each visit to our Website such as your IP address, geographical location, browser type, pages viewed, length of session, time of visit, and referring website.
  • Other information. We collect demographic information, interests information (like market affinity categories), and other information.

C. Information we receive from other sources
In order to enhance our ability to provide relevant services and offers to you, we obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, as well as other third parties.

3. How does Chatham use the information we collect?

A. Website administration

We utilize your data to better understand how people use our services so that we can continue to improve the Website to ensure that content is presented in the most effective manner. We collect IP addresses to identify the general locations of our users and block disruptive or improper use of our Website. We also use your personal information to tailor the content and information that we may send or display to you and otherwise personalize your experience while using our Website.

B. Marketing
We collect your personal information to determine the effectiveness of our campaigns. We also use your personal information to market to you, including sending you promotional materials or communications regarding services by us, or to send you information which we think may be of interest to you – but only if this in accordance with your marketing preferences. You will always be able to opt-out of such communications at any time by visiting our Email Preference Center.

C. Service Administration
We collect your data to help us manage our relationship with you, including responding to your requests or queries, meeting our obligations under any contracts we have entered into with you, billing and invoicing, seeking feedback on the services we have provided to you, or providing you with information about other services we offer that are similar to those that you have already engaged or inquired about. We also collect your data for security-related processing (e.g., automated scanning of incoming and outgoing e-mails for viruses), to provide customer support, including to manage your use of services and send customer updates and administrative communications, such as changes to our terms, conditions, and policies. We may also use your data to investigate and prevent fraudulent activities, unauthorized access to our services, and other illegal activities. We may collect your data for any other purposes for which we will notify any impacted clients.

D. Legal and Regulatory

We collect your personal information to comply with our legal and regulatory obligations, including in relation to financial crime laws and regulations and establishing, exercising and defending legal claims.

E. Prospective Employees

We process your personal information during the recruitment process collected either directly from you, sometimes from a third party such as an employment agency or via internet search engines or public databases. The purposes for processing your personal information are to:

  • Manage the recruitment process and assess your suitability and fitness for employment
  • Comply with statutory and/or regulatory requirements and obligations
  • Ensure effective HR, personnel management and business administration

Your personal information may be shared internally within our group companies for the purposes of the recruitment exercise. We will not share your personal information with, or collect information from, third parties, such as current and former employers, background check providers and credit reference agencies, during the recruitment process unless your job application is successful and we make you an offer of employment. If you become an employee, worker, temp or a contractor for us, we will issue you with a further privacy notice setting out, amongst other things, what personal information we process, why we process it and your rights.

4. How do we share and disclose information?

We do not rent or sell your personal information to anyone under any circumstances. We will share and disclose information about our clients in the following limited circumstances:

A. Affiliates
We will share your personal information with any Chatham entity for purposes consistent with this Privacy Policy.

B. Third-Party Service Providers
We will also share your information with consultants, professional advisers (such as accountants, lawyers and auditors), and certain vendors and service providers to process your personal information on our behalf. These companies are not permitted to use your information for their own purposes and may only handle your data at our express direction. We use these companies to provide products, services, communication, marketing offers, and customer services, among other tasks. We utilize payment processing vendors, web analytics companies, CRM service providers, email service providers, third-party site advertising platforms, AML and sanctions screening providers, technical service providers, and others. We assess the technical and organisational security measures of all third-party service providers Chatham engages to ensure the protection of your personal information.

C. Business Partners
We will also share your data with third-party business partners who sponsor events and other offerings with us. We share personal information with these co-sponsors when you sign up for events or offerings to allow our partners to send you marketing communications and information that may be of interest to you, as permitted under applicable law.

D. Business Transfers
In some cases, we buy or sell assets or businesses. In these types of transactions, personal information is typically one of the business assets that is transferred. We may disclose personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

E. Protection of Chatham and Others
We will share your personal information where we have under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce any contract or other agreements; or to protect the rights, property, or safety of Chatham, our clients, or others.

F. Disclosures required by Law, Rule or Regulation

Under certain circumstances, we may be required to disclosure your personal information if we are under a legal or regulatory obligation to do so including to meet security or law enforcement requirements.

G. Google Advertising and Google Analytics
We use the full suite of Google Advertising and Google Analytics features and products, including Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. Based on your use of this website, Google Advertising may use cookies to show you ads for Chatham Financial on sites across the internet.

H. Cookies
We use cookies to identify targets, place advertisements, and judge how well our marketing campaigns are reaching relevant audiences. You can opt out of all Google Analytics Advertising Features using NAI’s consumer opt-out, as well as Google Analytics’ opt-out.

5. What happens if you don’t give us your data?

You can enjoy many of Chatham’s services without giving us your personal information. You can still visit our site, but we may not be able to provide certain services or offers to you without your personal information. Some personal information is necessary so that Chatham can supply you with the services you have requested, and to enable authentication for authorized system users.

6. How can you opt out or unsubscribe from Chatham marketing emails?

You can opt out of receiving any marketing emails by visiting our Email Preference Center and unsubscribing. You can also unsubscribe by clicking on the unsubscribe link at the bottom of any marketing emails you receive from us. While you may opt out of receiving any marketing emails from us, you cannot opt out of receiving any business emails from us, including those dealing with administrative or transactional matters.

7. Where is your personal information stored?

Your personal information is stored by Chatham on its servers, located in the United States and the United Kingdom, and on the servers of the cloud-based database management services Chatham engages. These third parties may be located in jurisdictions which do not have privacy laws that provide equivalent protections to those in your home country. They do not use or have access to your personal information for any other purpose than cloud storage and retrieval.

In addition, Chatham is a global company with affiliates located in the United States, United Kingdom, European Union, Australia, and Singapore. Your personal information may be transferred to, accessed from, or stored and processed in these countries or any other country where Chatham or its third-party service providers are located for the purposes set out in this Privacy Policy. To protect intra-group transfers of personal information from our UK and EU offices to Chatham’s offices in the United States and elsewhere, we have provided appropriate contractual safeguards in this regard through an intra-group data transfer agreement (IGDTA) executed by Chatham’s trading entities incorporating the new EU standard contractual clauses approved by the European Commission and the UK Commissioner for controller-to-controller transfers. You may request a copy of the IGDTA by contacting your representative in the EU or UK using the contact details provided in Section 15.

Please be assured that we will protect all personal information under our control in accordance with this Privacy Policy and take reasonable steps to ensure that as good stewards we protect your data using physical, technical and administrative safeguards, training, internal policies, procedures and controls, industry best data security practices as identified by reputable sources, including NIST and ISO.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect the confidentiality and security your personal information, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. Chatham has in place procedures to deal with a suspected or actual data security breach, and we will notify the applicable supervisory authority and you of a suspected or actual breach where we are legally required to do so.

In addition, Chatham and Chatham Hedging Advisors comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Chatham has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Chatham has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Chatham commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.

8. How long does Chatham retain personal information?

We retain personal information about you for the period necessary to fulfill the purposes outlined in this Privacy Notice or until you notify us to remove you from our database, unless a longer or shorter retention period is required or permitted by applicable law, rule, or regulation.

9. Who can access your personal information?

To help protect the privacy of data and personal information in our possession, Chatham maintains multiple physical, technical, and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal information to those employees who need to know that information in order to perform their responsibilities. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

10. How does Chatham use cookies?

This Website uses cookies to improve the user experience and ensure that it is functioning effectively. In order to provide you with a more personalized and responsive service, we need to remember and store information about how you use this Website. This is done using small text files called cookies.

Cookies are designed to contain a small amount of information specific to a particular user and website. Cookies are stored on the web server as well as a user’s device and allows the server to deliver a website experience tailored to a particular user’s preferences.

Whenever you use this Website, information may be collected through the use of cookies and other technologies. We use cookies to evaluate your use of the website, compile statistical reports on activity, identify targets, place advertisements, and judge how well our marketing campaigns are reaching relevant audiences.

You are able to opt out of cookies on our Website by category, except for those that are deemed strictly necessary, by visiting our Cookie Settings.

Do Not Track or DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks, and analytic companies. This website does not currently respond to DNT requests.

11. Does Chatham’s Privacy Policy cover other websites?

Our Website may, from time to time, contain links to other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to those websites. Our link does not equal an endorsement of those sites, their owners, or their practices. This Website uses interfaces with social media sites such as Facebook, LinkedIn, Twitter, and others. If you choose to share information from this Website through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your site visit to your personal information.

12. Important information for UK, EU and Swiss residents

If you are a data subject located in the United Kingdom, Switzerland, or European Union, then you have additional rights in regards to your personal information:

  • To receive a copy of your personal information
  • To be informed about the collection and use of your personal data
  • To request that we correct any errors, outdated information, or omissions in your personal information
  • To request that we no longer use your personal information to contact you for marketing purposes or otherwise restrict or object to any processing of your personal information
  • To request that we provide the personal information you have provided to us to a third party
  • To request that we delete your personal information
  • To not be subject to a decision based solely on automated processing, including profiling

Please note that while we will strive to meet your request regarding your rights to your personal information, there will be instances where local laws and regulations will require us to maintain your records despite your request.

13. Important information for California residents

If you are a resident of the State of California, you have additional rights regarding your personal information under the California Consumer Protection Act (CCPA), specifically:

  • To request that we disclose to you the categories and specific pieces of personal information we have collected about you, the categories of the sources of our information, how we use the information, the categories of any personal information disclosed or sold to third parties, and the categories of third parties to whom such information was disclosed or sold;
  • To request that we delete any personal information we have about you; and
  • The right not to be discriminated against because you exercise any of these rights, including by denying services, providing a different level or quality of services, or charging different prices by virtue of exercising these rights.

To exercise any of your rights under the CCPA please email us at [email protected], or contact us at +1 877 553 1146.

A. Collection of Personal Information
As defined by the CCPA, Chatham has collected the following categories of personal information in the past 12 months:

  • Identifiers such as names, addresses, online identifier, IP addresses, email addresses, and similar identifiers;
  • Commercial information, including products or services purchased, obtained or considered;
  • Internet or other electronic network activity information, including browsing history and the consumer’s interaction with the Website;
  • Geolocation data;
  • Professional or employment-related information; and
  • Education information.

B. Disclosure of Personal Information
As defined by the CCPA, Chatham has disclosed the following categories of personal information for a business purpose in the past 12 months:

  • Identifiers such as names, addresses, online identifier, IP addresses, email addresses, and similar identifiers;
  • Commercial information, including products or services purchased, obtained or considered;
  • Internet or other electronic network activity information, including browsing history and the consumer’s interaction with the Website;
  • Geolocation data;
  • Professional or employment-related information; and
  • Education information.

C. Sale of Personal Information
Chatham does not sell or rent your personal information to anyone under any circumstances and has not sold any personal information in the past 12 months.

14. How can you learn if Chatham has updated our Privacy Policy?

Chatham may modify this Privacy Policy from time to time to reflect our current privacy practices. When we make changes to this Privacy Policy, we will revise the updated date at the bottom of this page. We encourage you to periodically review this Privacy Policy to keep informed about how Chatham is protecting your information.

15. Who can you contact regarding your personal information?

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Chatham commits to resolve DPF Principles-related complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, including individuals from the EU, UK and Switzerland, should first contact us at [email protected].To exercise any of your rights, please contact us at [email protected].

In addition, data subjects also have the right to submit a complaint concerning Chatham’s processing of their personal information to the appropriate supervisory authority. In the UK, this is https://ico.org.uk/make-a-complaint and in the EU, https://www.uodo.gov.pl/en/p/complaints. In Switzerland, this is https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt/anzeigeformular_betroffene.html.

Chatham has further committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit www.bbbprograms.org/dpf-complaints for more information or to file a complaint. This service is provided free of charge to you. If your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a National Programs Panel. Please note that as a DPF adherent, Chatham is responsible for the processing of personal information it receives under the DPF and subsequently transfers to a third party agent acting on its behalf. Chatham remains liable under the DPF Principles if our agent processes such personal information in manner inconsistent with those principles, unless Chatham establishes that it is not responsible for the event giving rise to the damage.

Chatham is committed to protecting the privacy of your personal information. If you have questions or comments, please contact us at:

If you reside in the European Union:

Chatham Financial Europe Sp. z o.o.
ul. Kotlarska 11,
31-539 Kraków
Poland
Telephone: +48 12 349 8800
Fax: +48 12 294 6161
Email: [email protected]

If you reside in the United Kingdom:

Chatham Financial Europe, Ltd.
12 St James’s Square
London, SW1Y 4LB
United Kingdom
Telephone: +44 (0) 20 7766 5700
Fax: +44 (0) 20 7766 5701
Email: [email protected]

If you reside anywhere else:

Chatham Financial Corp.
235 Whitehorse Lane
Kennett Square
PA 19348
USA
Telephone: +1 610 925 3120
Fax: +1 610 925 3125
Email: [email protected]

Last Updated: 27 October 2023