Privacy Policy

We use information and data to analyze trends to help us better understand how our website is being used, how to make it more effective and how to provide our users with a better experience.

As part of this process, we track the domain from which you accessed our website and the specific pages that you accessed.  Under this Policy, “Personal Information” is considered data that reasonably can be used to identify an individual. We may collect and process the following data about you:

• Information that you provide to us by completing forms on our website.  This includes information provided at the time of registering to use our website or subscribing to our services, including, contact details such as name, employer, job title, email address, employer and personal mailing addresses and phone number.
• Information that you share through our website by using our services, including any Personal Information in the data that you share.
• Information you provide to us when you contact us for customer or technical support or when you submit questions or comments.
• Information we receive from third party search engines relating to your search activity.
• Details of your visits to and interaction with our website including, but not limited to, traffic data, IP address, repository ID, location data, weblogs, search terms entered, account activity, and other communication data relating to the pages visited and resources that you access.
• Information you provide to us when you request information or research materials, and participate in promotions, contests or giveaways.

Please note that we do not attempt to collect Personal Information from children under the age of 16.  Personal information sent to us which appears to be from a child will be deleted.  We cannot always determine if a visitor to our website or the sender of an e-mail is a child, but we will exert our best efforts to do so.

Each year, Greenwich Associates systematically conducts research in more than 80 countries, interviewing up to 60,000 key decision-makers. The information provided by these Research Participants is the core element of Greenwich Associates research based consulting business.

The research is designed to help financial services providers meet their customers' needs and provide Research Participants with an extensive resource on industry trends and best practices.

The core information collected by Greenwich Associates is done off-line in Greenwich Associates proprietary research process. However, we also gather information about Research Participants, Clients, Registered Users, and Unregistered Users via our website, which is typically presented in an aggregated form. During the initial visit to our website, Research Participants and Clients are asked to update any changes to their contact information and reset their password.

The information collected on our website will be used by us for purposes consistent with the way in which it was submitted and collected, such as to:

• determine whether you are a subscriber or an employee of a subscriber;
• identify, tailor and meet user needs;
• determine eligibility to participate in research;
• assess potential new markets to serve and new research topics to address;
• create and maintain your account or user profile;
• answer your questions or respond to your comments;
• register you in our programs or events;
• send you information about our services and resources; and
• make certain resources and research available to you depending on your membership.

To best serve our customer bases, Greenwich Associates may also use user data and Personal Information for the following activities:

• To direct editorial content and other features to users who have a strong interest in a particular area.
• To provide our editors and program developers with information that can assist in developing new tools, features, functions, and services.
• To assess usage and specific features or services on our website and to make improvements to these features or services.
• To provide you with updates and notices regarding new articles and resources that may be of interest.
• To solicit user feedback or perform market research to generate analysis on important industry trends and to assess user satisfaction or other needs and interests.
• To provide special services targeted to specific user groups, based on demographics, industry information, or other aggregate data.
• To facilitate communications with other users.

We may also provide blogs or public forums on our website.  Any Personal Information you choose to submit in such a forum may be read, collected or used by us or others who visit these forums.  We are not responsible for the Personal Information you choose to submit in these forums.

Generally, we do not reveal any personally identifiable information, unless we secure permission from the provider in advance of doing so. However, we reserve the right to share Personal Information with our service providers or other individuals and organizations that need to have access to such information in connection with the provision of services to you or to respond to your specific inquiries or requests.

This includes our vendors that provide data collection, validation, and coding services, as well as service providers or sponsors of webinar and similar services that may be offered through our website. We also reserve the right to release information as required by any governmental or law enforcement agency or under a court order issued by a court of competent jurisdiction.

All Personal Information you provide to us through our website is transmitted securely using SSL encryption. In addition, we routinely enter into confidentiality agreements which require that care and precautions be taken to guard against loss, misuse, or disclosure of your Personal Information.  We also educate our employees on our privacy guidelines and ensure that they understand their role in compliance.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential.  We ask that you do no share your password with anyone.  Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our website. No security measure is perfect or impenetrable. Any transmission is at your own risk.  We will employ appropriate procedures and security features to guard against unauthorized access.

If a formal written complaint is received regarding our protection of your Personal Information, it is our policy to contact the complainant directly to address the concern. We will cooperate with the appropriate regulatory authorities, if necessary, including all local data protection authorities, to resolve any complaints.

We take steps to ensure that the Personal Information we collect is accurate and up to date, and that you have the ability to access it and make corrections to it.

If you would like to review and update your account information, suspend or cancel your account, request that we no longer use your account data, or obtain further information about or access to your Personal Information, you can do so by contacting us by email at ContactUs@greenwich.com.

We will retain and use your Personal Information for as long as your account is active or as needed to provide you with our services and as necessary to comply with our obligations under this Privacy Policy and at law, including to resolve disputes, enforce our agreements, and for backup or compliance purposes.

We may use cookies to improve your experience on our website. Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website.  Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. 

Cookies are useful because they allow us to recognize your device and facilitate and improve your interaction with our website and services. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our website, but your ability to use some features may be limited. To learn more about cookies and how to manage them, visit https://www.aboutcookies.org/

We also collect certain limited information as you navigate through our website. These log files are used for system management and to track generic user behavior, which helps us to better understand the needs of our users and to identify demographic trends.

Strictly Necessary Cookies

Performance Cookies

Functionality Cookies

Targeting Cookies

Our website may contain links to other third party websites and applications. We are not responsible for the privacy practices of these parties, their websites or applications. We do not review or control such websites and suggest that you review these third party privacy policies before using the links, websites or associated applications.

You have a choice about how we use your Personal Information to communicate with you, and you may opt out at any time by deactivating your account or changing your account preferences. When you deactivate your account, you will not be able to use our services and your information will not be capable of being viewed through our site. However, even after you deactivate your account, your information including, name and email address, may be retained by us as backup copies for legal and compliance reasons.

To deactivate your account or to notify us of a profile created without your knowledge or authorization, please contact us at ContactUs@greenwich.com.

We are headquartered in the United States and our servers are located in the United States. Personal Information may be accessed by us or transferred to us in the United States or to our affiliates, partners, or service providers elsewhere in the world. By providing us with Personal Information, you consent to this transfer.

We will protect the privacy and security of Personal Information according to this Privacy Policy, regardless of where it is processed or stored. However, you explicitly acknowledge and consent to the fact that Personal Information stored or processed in the United States will be subject to the laws of the United States, including the ability of governments, courts, law enforcement, or regulatory agencies of the United States to obtain disclosure of your Personal Information.

Greenwich Associates complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Greenwich Associates has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Mr. Timothy Sangston
Managing Director and COO
tim.sangston@greenwich.com
+1 203.625.5024

Greenwich Associates has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.

Greenwich Associates’ commitments under the Privacy Shield, and compliance with the Principles, are subject to the investigatory powers of the U.S. Federal Trade Commission.

If you have any complaint regarding Greenwich Associates’ compliance with the Privacy Shield Principles, please contact us using the details set out in Contact Us below. We will respond to your complain within 45 days. If you feel that Greenwich Associates has not satisfactorily resolved your complaint or has failed to respond to your complaint within 45 days, you may bring your complaint to the attention of your local data protection authority (“DPA”). The DPAs will establish a panel to act as an independent dispute resolution body who will investigate and resolve complaints brought under the Privacy Shield free of charge to you. Greenwich Associates commits to cooperate with this panel as an independent body to resolve disputes relating to its compliance with the Principles. Greenwich Associates will comply with any binding advice given by DPAs where they take the view that specific action is necessary to comply with the Principles and will provide the DPAs with written confirmation that such action has been taken.

With respect to transfers of Consumer Personal Data to third-party Processors, Greenwich Associates (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the Privacy Shield Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Greenwich Associates’ obligations under the Privacy Shield Principles, (v) requires the Processor to notify Greenwich Associates if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, (vi) upon notice, including under (v) above, takes 4 reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. Greenwich Associates remains liable under the Privacy Shield Principles if the company’s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Greenwich Associates proves that it is not responsible for the event giving rise to the damage.

The Modern Slavery Act of 2015 – Section 54 - requires organizations that operate in the United Kingdom having an annual revenue of £36m or above to produce a Slavery and Human Trafficking statement each year.

Greenwich Associates has a commitment towards the global eradication of human trafficking, taking specific measures to ensure no breaches of the modern slavery laws are occurring with our active suppliers.

Any potential breaches that are brought to our attention or otherwise identified within our supply chain will be reviewed with the supplier. Greenwich Associates will revisit our relationship with the supplier(s) deemed to be out of compliance with the regulations or acting in violation of the law and determine if we are able to assist them to gain compliance or whether we should continue to conduct business.

We conduct business in an industry generally recognized as low risk in relation to potential breaches in the Modern Slavery Act. Each supplier is reviewed for the likeliness of the risk associated with these laws and an assessment is made where necessary.

Firm Organization
Greenwich Associates LLC, is a privately held partnership registered in the state of Delaware. The company is managed by a subset of partners (“Managing Group”) who are responsible for ensuring that all policies are published and understood by employees within the organization and that our supplier contracts include requirements to ensure adherence to all applicable global laws and regulations including the Modern Slavery Act of 2015.

A Human Resources Department exists with the responsibility to know and understand the legal employment requirements for each location we operate in.

Employee Statement
Employees are paid no less than the applicable local minimum wage for the location they are assigned. Employees are made aware of the firms obligations through appropriate handbooks, policies and signage as required by local law.

Annual Business Conduct training includes the requirement to follow all laws and regulations including the Modern Slavery Act.

Human Resources ensures that all employees are legally able to work for the Firm and their employment meets local laws. We do not employ staff under the legal age of employment.

The standard business hours of the firm are published in the Employee Handbook provided to each new hire and published on our Intranet. Any additional hours required to complete work functions are an allowable exception managed through our management team.

A whistleblowing Policy is included in the Employee Handbook outlining the process allowing employees to report breaches of laws and regulations to the appropriate individuals in the organization or directly to the CEO.

This statement has been reviewed and approved by the COO of Greenwich Associates as of March 1, 2019. https://www.gov.uk/government/publications/transparency-in-supply-chains-a-practical-guide

We reserve the right to change this Privacy Policy at any time, without notice, by posting the new or revised Privacy Policy on our website.

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to ContactUs@greenwich.com.

You can also call us at +1 203.625.5038 or reach us by mail at Privacy Matters c/o Greenwich Associates, 6 High Ridge Park, Stamford, CT USA 06905-1327.