NYL Investors (U.K.) Limited Privacy Notice

NYL Investors (U.K.) Limited (referred to as "we", "us" or "our") is committed to respecting the privacy of individuals, including its clients.

Our affiliate NYL Investors LLC operates this site, which is owned by our affiliate New York Life Insurance Company.

This Privacy Notice ("Notice") sets out the basis on which NYL Investors (U.K.) Limited processes personal data. Please read the following carefully to understand our views and practices regarding how we handle personal data.

For the purposes of applicable data protection law (in particular, the General Data Protection Regulation (EU) 2016/679 (the "GDPR")), NYL Investors (U.K.) Limited is the "data controller" of your personal data.

Personal Data We collect

We may collect and process the following personal data:

  • Information you give us:
    • If you are enquiring about NYL Investors LLC’s capabilities (including where you are inquiring on behalf of your employer), then we may process your personal data - including your name, address, e-mail address and phone number, financial information, personal description, photograph, marital status, information about you dependents or beneficiaries.

    • You or your employer may give us information about you during our due diligence of your employer or by corresponding with us by phone, e-mail or other electronic means, or in writing. This may include your name, email address, gender, postal address, telephone and fax.

  • Information we collect about you: With regard to each of your visits to our site we may automatically collect the following information:
    • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and

    • Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products, services or issues you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call us.

  • Information we receive from other sources:
    • We work closely with third parties (for example, banks and other financial institutions and placement agents, business partners, legal or other consultants, search information providers) and may receive information about you from them.

  • Information about other people: If you provide information to us about any person other than yourself, such as other employees of your employer, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.

Legal Basis

We may ask you for consent to collect or process your personal data on certain occasions, for example, and as stated below, where necessary in order to contact you with information about events and capabilities that might be of interest to your employer. We also process your personal data when we need to do this to fulfil a contract with your employer or when required by law, such as if we receive a request from law enforcement or other government officials.

We also process your personal data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, we have a legitimate interest in the activities and condition of your employer.

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this Notice.

Disclosure of Your Personal Data

We may share your personal data with our subsidiaries and/ or affiliates. You can see more about our group companies https://www.nylinvestments.com/investmentsgroup.

We may also share your personal data with trusted third parties including:

  • Legal or other advisers, consultants and other professional experts, complainants, correspondents and enquirers, and suppliers and service providers of any of the above, and each of their associated businesses;
  • Business partners, suppliers and sub-contractors only for the purposes of performance of any contract we enter into with them or your employer. We take reasonable steps to ensure that our staff protect your personal data, and are aware of their information security obligations; and
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may disclose your personal data to third parties:

  • If we or any our affiliates sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • If NYL Investors LLC, its business, or its assets are acquired by a third party, in which case personal data held by it about its users, suppliers, or customers will be one of the transferred assets;
  • If we or any our affiliates are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce agreements; or if we reasonably consider this necessary; or to protect the rights, property, or safety of NYL Investors (U.K.) Limited or others; and
  • For the purposes of crime prevention and fraud protection.

Communications

We may contact you by email or post with information about events and capabilities that might be of interest to you or your employer.

You can unsubscribe from this at any time by emailing us using the contact details provided below.

Where We Store Your Personal Data and How We Protect it

The affiliates and third parties to whom NYL Investors (U.K.) Limited discloses your personal data (as described above) are located in countries outside the EEA that do not provide a level of protection to personal data equivalent to that provided by your home country.

In order to provide adequate protection for these transfers, NYL Investors (U.K.) Limited utilizes transfer mechanisms recognized by your home country, which may include executing appropriate contractual clauses based on and conforming to the EU model clauses. To obtain a copy of the transfer mechanism, please contact us using the details provided below.

We take reasonable steps to protect your personal data from loss or destruction. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data provided to us; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

Your Rights

You have various rights with respect to our use of your personal data:

  • Access: You have the right to request a copy of the personal data that we hold about you. Please note that there are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information. You are entitled to see the personal data held about you. If you wish to do this, please contact us using the contact details provided below.

  • Accuracy: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date. You can also review and correct/ update some of your personal data by contacting us using the contact details provided below.

  • Objecting: In certain circumstances, you also have the right to object to processing of your personal data and to ask us to block, erase and restrict your personal data. If you would like us to stop using your personal data, please contact us using the contact details provided below.

  • Porting: You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format.

  • Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority or to seek a remedy through the courts.

Please note that there are exceptions to these rights, if, for example, we are under a legal obligation to continue to process your personal data.

When we ask you to supply us with personal data we will attempt to make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you or your employer, or whether the supply of any personal data we ask for is optional.

How Long We Keep Your Personal Data

We will retain your personal data for as long as we believe it necessary or desirable to fulfil our business purposes or to comply with applicable law, audit requirements, regulatory requests or orders from competent courts.

Personal Data collected will be retained pursuant to our record retention policy, and in most instances will not be retained longer than nine (9) years from the date of last use.

Changes to our Privacy Notice

Any changes we may make to our Notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our Notice.

Contact Details

Questions, comments and requests regarding this Notice are welcomed and should be addressed to Alpesh Rathod, (212) 576-7965, alpesh_j_rathod@newyorklife.com.