Pastel Fund Services, LLC and/or affiliates thereof (collectively, “Pastel”) are committed to protecting the privacy of all the users of the www.pastelfundservices.com website (the “Site” or “Sites”). This Privacy Policy applies to the use of the Site and to Pastel’s use of data and/or information gathered.
PASTEL PRIVACY PLEDGE
Pastel’s fundamental goal is to provide asset managers around the world with comprehensive fund administration and middle office solutions. As we build on the Pastel suite of services, we are committed to the principles of respecting your privacy, keeping your data safe and keeping the decision as to how your information is used and shared in your hands.
Our privacy pledge:
- Pastel will only collect data that is of legitimate interest and which is useful and necessary for improving its products, services and your experience.
- Pastel will maintain fairness and transparency at all times with regards to how we collect and process data at all times.
- Pastel will never sell your data and will only share your personal data when given your explicit consent to do so for a specific reason.
- Pastel will never make decisions based solely on automated processing or profiling of data.
- Pastel will always take the security of your data seriously.
To learn more about the data collected by Pastel, please read the entirety of our Privacy Policy below.
DATA COLLECTION AND PROCESSING
Subject to the relevant local laws, Pastel may process certain information about you if this information is of legitimate interest. This data may include what is known as Personal Data under Data Protection Laws and/or Personally Identifiable Information (PII). Data Protection Laws mean any Laws applicable to Pastel, relating to data security, data protection, and/or privacy, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to processing of Personal Data and the free movement of that data (“GDPR”).
Pastel processes your personal information in line with its Privacy Policy and Terms of Use to provide you with the information that is of most interest to you and deliver the services you have requested.
AUTOMATED PROFILING
Pastel does not carry out automated profiling and will not make any decisions based on the automated processing of data.
SENSITIVE DATA
Pastel does not seek to collect special categories of personal data (“sensitive data”), including but not limited to data revealing racial or ethnic origin, nationality, political opinions or affiliations, gender, sexual orientations, religious or philosophical beliefs or affiliations, health, genetic and biometric data, or trade union memberships, through this site. Please note that, by freely providing Pastel with an unsolicited sensitive data, subject to the relevant laws, you are consenting Pastel to use the said data in conformity with this Privacy Policy.
Pastel understands the importance of protecting children’s privacy. For the avoidance of doubt, it is not our policy to intentionally collect or maintain information about anyone under the age of 13 years old.
VISITING A PASTEL WEBSITE
We collect some relevant data from anyone who visits our Site. When you enter a Pastel Site, we collect industry standard log data that records information about your visit, such as your browser type, the URL of the page that referred you, the different pages you visited, and time spent on those pages. Pastel uses Google Analytics to gather this data and we use this type of information to ensure our Site is working properly and make improvements; for example, we may expand upon the information on the most frequently visited pages. We also collect data for cookies. For more details on what cookies are and how they are used, please ready our full Cookie Policy below:
LINK TO THIRD PARTIES WEBSITES
Pastel Privacy Policy does not apply to third parties’ websites which Pastel website link to or which advertise on Pastel website. These third-party websites will have their own cookies and operate their own Privacy Policy which we encourage you to read before disclosing any of your personal data.
COOKIE POLICY
This Cookie Policy is part of our Privacy Policy. Pastel uses cookies on its websites while you browse, use our services, read our emails or newsletter to provide better service, facilitate your use of the website or our service, store online preferences and track usage of the site or services.
This includes open and click through rates of emails to tailor the marketing of business services to our institutional clients or enhance securities.
DEFINITION
Cookies are text files that are sent by servers to web browsers and stored on your computer. The cookies tell us which parts of the Pastel Site you have visited so that we can ensure we provide you with information that you are interested in and make any future visits to our website simple and easy for you. The information and data collected by Pastel cookies expire after two years.
SOCIAL MEDIA
Social media tools, like widgets and plug-ins, are sometimes used so that you can share information from Pastel on other sites such as Twitter. These interactive mini-programs collect your IP address, record the pages you visit on our site, and set cookies that will enable the widget to function properly. Your interactions with these widgets are governed by the privacy policy of the company providing them, not by Pastel’s Privacy Policy. We may also use Twitter, Facebook and LinkedIn and/or any other relevant social media service’s pixel tags to help us understand how effective our marketing is on those sites.
BROWSER CONTROL
You can decline the use of cookies at any time by modifying your browser settings. By deleting or declining cookies, you may not be able to use some interactive features or access certain areas of the site that depend on cookies. If you do wish to decline the use of cookies, please refer to the instructions for your file management software.
Most browsers allow you to see what cookies you have and delete them on either an individual basis or block them. You can block cookies for specific websites or for all websites, depending on your preferences.ANALYTICS
As aforementioned, Pastel uses Google Analytics. You can opt-out of having your anonymized browsing activity within websites tracked by Google Analytics cookies by clicking on the following link: Google Analytics Privacy
EMAIL MARKETING
If you are subscribed to one of Pastel’s marketing lists, we may occasionally send you relevant updates. When you receive marketing emails from Pastel, we may use web beacons, customized links, or similar technologies to determine whether the e-mail has been opened and on which links you click, to provide you more focused e-mail communications or other information in the future.
UNSUBSCRIBE FROM EMAILS
You can stop the delivery of marketing emails from Pastel at any time by Unsubscribing/Opting Out. We include a link at the bottom of every marketing email which you can utilize to update your preferences by selecting and de-selecting lists based on your personal interests, or you can decide to unsubscribe from ALL marketing communications. Alternatively, you can make a direct request to unsubscribe by sending an email to info@pastelfundservices.com.
INFORMATION SECURITY
Pastel is committed to protecting the security of your personal information. Pastel has implemented generally accepted industry-standards of technology and operational security to protect personal data and information from loss, misuse, alteration or destruction. Pastel ensures that all appropriate confidentiality obligations and technical and organizational security measure are in place to prevent any un-authorized or un-lawful disclosure or processing of such information and data and the accidental loss or destruction of or damage to such information and data.
Only authorized Pastel employees and services providers are allowed to access the data and they are legally obliged to ensure confidentiality of this information.
DATA RETENTION
The data you submit to Pastel will only be retained for as long as is required for the purposes for which it was collected or as required by the relevant laws. When the data is no longer necessary to the purpose for which it was collected; Pastel will proceed to erase all your personal data held in its systems without undue delay.
RIGHT TO ACCESS AND CORRECT YOUR PERSONAL INFORMATION
Subject to the relevant laws, you have the right to know what personal information we hold about you. If you would like a copy of the information you are entitled to, you may send an email to info@pastelfundservices.com. Please note that for the execution of this request, you must provide with a clear identification of yourself and the information you require.
Also, you have the right to request rectification of inaccurate personal data concerning to you. If you would like to exercise this right, you may provide Pastel with a supplementary statement by email to info@pastelfundservices.com. Please note Pastel does not assume responsibility for verifying the ongoing accuracy of the personal information provided.
RIGHT TO BE FORGOTTEN
If at any point you wish to withdraw your consent for Pastel holding your data, you can send a request by email to info@pastelfundservices.com.
LEGAL DISCLOSURE
Pastel may disclose your personal information to law enforcement, regulatory, or other government agencies or to other third-parties are required by, and in accordance with, applicable local, state, federal laws or regulations.
AMENDMENTS
Pastel may update the terms of this Privacy Policy, within reason, in line with new regulation or directives at any time and without notice. When we make changes to this Statement, we will amend the revision date at the top of this page, and such modified or amended Privacy Statement shall be effective as to you and your information as of that revision date. We encourage you to periodically review this Privacy Policy to be informed about how we protect your data and your information.
CONTACT
If you have any questions about this Privacy Policy, you may contact us via info@pastelfundservices.com or via regular mail to:
Pastel Fund Services, LLC | 6800 Westgate Blvd. | Suite 132284 | Austin, TX 78745 (USA)