Privacy Notice

  1. WHO ARE WE
    1. We are Buck Consultants (Administration & Investment) Limited, a limited liability company registered in England and Wales under number 01034719 with its registered office at 20 Wood Street, London, EC2V 7AF ("Buck Consultants", "our", "us" or "we").
    2. For the purpose of UK data protection legislation, we are the data controller of the personal information provided by you for the purpose of opening and maintaining your user account on the Portal. We are registered with the Information Commissioner's Office under registration number Z6047827.
    3. Scotiabank ("Client") and the Trustees of the Plan have arranged for you to have access to the Portal, which is operated and managed for the Client by Buck Consultants.
    4. In this Privacy Notice, references to "our Group" are to the group of companies of which Buck Consultants is a member.
  2. THIS PRIVACY NOTICE
    1. This Privacy Notice explains how we collect, use and store:
      1. any personal information you provide to us for the purpose of opening and maintaining your user account on the Portal. This includes information provided at the time of registering to use this Portal and when updating your user ID, name or contact details. You are required to provide us with this information to gain access to the Portal and to comply with the Portal Terms of Use; and
      2. information about your visits to the Portal and about your computer, tablet, mobile or other device through which you access the Portal. This may include the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and geographical location, the full Uniform Resource Locators (URL), clickstream to, through and from our Portal (including date and time), pages you viewed and searched for, page response times, download errors, and length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and website navigation and search terms used.
    2. Your account on the Portal may also allow you to access, use and update other information about you that has been provided to us by our Client . Please consult their respective privacy policies for further information as to how this personal information will be held and used.
    3. By accessing and using the Portal, you signify your agreement to this Privacy Notice. If you do not agree with this Privacy Notice, please do not use the Portal.
    4. Questions, comments and requests regarding this Privacy Notice (including requests to exercise any of your rights described in this Privacy Notice) are welcomed and should be addressed to the Compliance Officer at Buck Consultants, 20 Wood Street, London, EC2V 7AF or by email to HRS-UKCompliance@buck.com.
  3. WHERE WE STORE YOUR PERSONAL DATA
    1. The data that we collect from or about you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our or our Group member's suppliers or subcontractors (for example, the third party supplier which hosts the Portal on our behalf).
    2. Where personal data is transferred to and stored in a country not determined by the European Commission as providing adequate levels of protection for personal data, we take steps to provide appropriate safeguards to protect your personal data, including entering into standard contractual clauses approved by the European Commission, obliging recipients to protect your personal data. If you would like further information on the specific mechanism used by us when transferring your personal data outside of the EEA, please contact us using the details set out at the end of this Privacy Notice.
  4. USES MADE OF YOUR PERSONAL INFORMATION
    1. We use your personal information to provide the Portal to you and other Portal users in a safe and secure way, in accordance with the Portal Terms of Use referred to above, which you are required to accept and agree to before accessing the Portal. This processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
    2. Where it is in our legitimate interest to do so, we use your information:
      1. to ensure that content from the Portal is presented in the most effective manner for you and for your computer;
      2. to help us improve our products and services and for quality control, security, internal record keeping and other business needs; and
      3. to administer the Portal to create statistical data.
  5. DISCLOSURE OF YOUR PERSONAL INFORMATION
    1. We may disclose your personal information to:
      1. any member of our Group;
      2. suppliers we or our Group engage to process data or provide services to us;
      3. any business partner of our Group; and/or
      4. auditors or contractors or other advisers auditing any of our business processes, in accordance with the purposes for which the data was originally collected or to which you have subsequently consented.
    2. We may also disclose your personal information to third parties:
      1. in the event that we sell or buy any business or assets, in which case we may disclose your information and personal data to the prospective seller or buyer of such business or assets provided that such disclosure will be conditioned on the basis that any use of your personal data will be in accordance with this Privacy Notice;
      2. if we or substantially all of our assets are acquired by a third party, in which case information and personal data held by us about our customers will be one of the transferred assets provided that disclosure of your personal data will be conditioned on the basis that any use of such data will be in accordance with this Privacy Notice; and/or
      3. if we are under a duty to disclose or share your information and personal data in order to comply with any legal or regulatory obligation, or in order to enforce or apply the Portal's Terms of Use or our separate terms and conditions of supply or other agreements; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction or law enforcement or the administration of justice. We may disclose your information and personal data to government institutions or authorities if required by law or when requested to by regulatory bodies or law enforcement organisations.
  6. HOW LONG DO WE KEEP YOUR INFORMATION?
    1. Personal information received by us will only be retained for as long as necessary to fulfil the purposes described in this Privacy Notice or for the maximum period of time as required by law, after which time it will be destroyed in a secure manner.
  7. YOUR RIGHTS
    1. You have the right to access the information which we hold about you ("data subject access request").
    2. You have the right to receive your personal information in a structured and commonly used format so that it can be transferred to another data controller ("data portability").
    3. We want to make sure that your personal information is accurate and up to date. You may request at any time that we correct or remove any information we hold about you which you think is inaccurate. Please keep us informed if your personal information changes during your relationship with us.
    4. You have the right to object at any time to our processing of your personal information for direct marketing purposes.
    5. You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
    6. In certain circumstances you have the right to:
      1. request the erasure of your personal information erasure ("right to be forgotten");
      2. restrict the processing of your personal information to processing in certain circumstances.
      3. The above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable laws apply.
    7. There is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.
  8. Complaints
    1. If you have concerns about our use of your personal data, please send an email with the details of your complaint to HRS-UKCompliance@buck.com. You also have the right to complain to the Information Commissioner's Office (https://ico.org.uk/).
  9. CHANGES TO OUR PRIVACY NOTICE
    1. We reserve the right to amend or modify this Privacy Notice at any time. If you do not agree to these changes, please do not continue to use the Portal.
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