September 2023
The Tudor Group (comprised of a number of companies under common control, including but not limited to Tudor Investment Corporation (“TIC”), Tudor Capital Europe LLP (“TCE”), Tudor Capital Australia Pty Ltd (“TCA”), Tudor Capital Singapore Pte. Ltd. (“TCS”), Tudor Capital France S.A.S (“TCF”), their affiliated companies (collectively, “Tudor”, “our”, “we” or “us”) are committed to respecting your privacy and will only collect and use your personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under applicable Privacy Laws.
About this privacy notice
This privacy notice describes how Tudor collects, uses and discloses the information you provide to us and the information we collect in the course of operating our business and our website.
This privacy notice applies to all natural persons whose personal data Tudor handles and who are not covered by either our Investor Privacy Notice or our Employee Privacy Notice and: (i) have had contact with Tudor for business purposes, either on their own account or on behalf of third parties; (ii) are employed by or otherwise associated with Tudor’s suppliers, vendors or professional advisors; (iii) individuals who are involved in transactions or potential transactions which are evaluated or conducted by Tudor or its sub-advisors; (iv) individuals that have had contact with Tudor during a recruitment process, and (v) individuals who have opted to receive communications from Tudor. It does not apply to your use of Tudor’s financial services, including any investments. Users of our financial services should refer to our Investor Privacy Notice.
The privacy notice sets out:
- the basis on which any personal data that you provide to us, will be collected, used, disclosed and processed by us;
- the purposes for which we will process such data;
- your privacy rights under applicable privacy laws from time to time in force, including, where applicable, under the General Data Protection Regulation (the “GDPR”), the Cayman Islands Data Protection Act (2021 Revision), Singapore’s Personal Data Protection Act 2012, California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020), the UK GDPR and Data Protection Act 2018 (together, the “Privacy Laws”); and
- how we protect your personal data.
Maintaining your privacy is important to us and we hold ourselves to high standards in the safekeeping and use of your personal data. Please take the time to read and understand this privacy notice, together with any other privacy notice we will provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information. This privacy notice does not form part of any contract of employment or other contract to provide services.
For the purposes of relevant Privacy Laws, the relevant Tudor company with which you are dealing with, as applicable, is the controller in respect of your personal data and so responsible for this privacy notice. This means that we are responsible for deciding how we hold, disclose and use your personal data and for ensuring that we use your personal data in compliance with the relevant Privacy Laws.
Where required, the Tudor Group companies have each designated Tudor Capital France S.A.S. to act as their representative in the European Union, and Tudor Capital Europe LLP to act as their representative in the UK, for the purposes of Article 27 of the GDPR and UK GDPR respectively. They can be contacted using the details in the “Contacting Us” section below.
Data protection principles
We will comply with the Privacy Laws. If you are located in the UK, Europe or other equivalent jurisdiction, this says that the personal data we hold about you must be:
- used lawfully, fairly and in a transparent way;
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- relevant to the purposes we have told you about and limited only to those purposes;
- accurate and to the extent appropriate, kept up to date;
- kept only as long as necessary for the purposes we have told you about; and
- kept securely.
Personal data that we collect about you
“Personal data” is any information that can be used to identify you or that we can link to you and which we have in our possession or control. It does not include anonymous data.
From time to time, we will collect, use, disclose and process your personal data in order to manage our relationship with you effectively, lawfully and appropriately. The personal data will be collected as follows:
- When you contact us with queries or respond to our communications the personal data you provide will include your full name, title, telephone number, email address and content, date and time of your email correspondence and information about your employer or your business.
- If you are a prospective or current service provider of Tudor, you will provide us with personal data when you or the company you represent becomes a service provider. We will also collect information you have allowed to be publicly available.
- When you are involved in a transaction or potential transaction with Tudor, you will provide us with personal data which includes, but is not limited to: your business and personal contact details, professional opinions and results of due diligence that is carried out.
- When you apply for a role with us (directly or via a recruitment agency or via a recommendation), depending on which office you apply to, you will need to provide us with your full name, date of birth, nationality, education and qualification details, your gender, your CV, remuneration details, photograph, passport details, driving licence details, marital status, home address (including proof) and home telephone number, mobile telephone number, immigration status and evidence about your entitlement to work in the location of the vacancy and other details set out in your application. We will also collect information you have allowed to be publicly available.
- Visitors to Tudor’s offices (CCTV, access key card, guest book, dietary preferences for meetings/events etc.).
- People Tudor does business with, excluding investors (KYC/DD/AML activities etc.).
- Information collected automatically on our website. For information about how we use cookies and similar technologies, refer to our Cookie Notice. Our website does not respond to Do Not Track Signals.
Please note, you are under no obligation to provide us with personal data when applying for a role with us. However, if you do not prove/provide certain information when requested, we will not be able to process your application for employment properly or at all.
You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for you if this information is not provided.
There are more sensitive types of personal information which require a higher level of protection under certain applicable laws. We do not collect such more sensitive information about you except for information about religious beliefs in the context of dietary requirements, and, where applicable, health information in the event that you require special assistance or we have to give you first aid on site for events and meetings that you voluntarily provide to us. Nor do we collect any information about criminal convictions and offences unless revealed by due diligence conducted to comply with a legal obligation or given to us in connection with our role, or potential role, as financial adviser in connection with a transaction, in order to comply with a legal obligation.
Legal basis for processing your personal data
Your personal data will be collected, used, stored, disclosed and/or processed by us in the following ways:
- use it as part of our business relationship;
- where you have applied for a position with us directly or through a recruitment agency, to review and process your job application;
- making a decision about your recruitment or appointment;
- to comply with legal and regulatory obligations that we, or one or more of our affiliates have to discharge;
- use it to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
- record and monitor your use of our websites or our other online services for our business purposes which will include analysis of usage, measurement of site performance and generation of marketing reports;
- use it for our legitimate business interests, such as performing transactions, undertaking business research and analysis, managing the operation of our websites and our business;
- processing, evaluating, and communicating with you about your job application and communicate with you about other jobs that will interest you;
- use it to look into any complaints or queries you will have;
- in the event that we sell or buy, or one or more of our affiliates sells or buys, 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 we or our assets, or one or more of our affiliates or our affiliates assets’ are acquired by a third party, in which case personal data held by it about its clients may be one of the transferred assets;
- in order to enforce or apply our terms of use and other agreements or to protect our rights, our customers or others; or
- use it to prevent and respond to actual or potential fraud or illegal activities.
Also, we will collate, process and disclose any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.
We rely on the following legal grounds to process your personal data, namely:
- Consent – we will (but usually do not) need your consent to use your personal data. You can withdraw your consent at any time by contacting us (see below).
- Performance of a contract – we will need to collect and use your personal data to enter into a contract with you or to perform our obligations under a contract with you.
- Legitimate interest – we will use your personal data for our legitimate interests, some examples of which are given above.
- Compliance with law or regulation – we will use your personal data as necessary to comply with applicable law/regulation.
Disclosure of your information to third parties
We will disclose your personal data internally and with employees, agents or contractors of our affiliates, including international offices (“Authorised Individuals”) where it is necessary to fulfil the purpose for which it was collected. As a result, your personal data will be transferred to locations outside of the locations in which our offices are located (including locations outside the UK, EU/EEA and Singapore) as well as within those locations for the purposes described above.
We will take steps to ensure that the personal data is accessed only by Authorised Individuals that have a need to do so for the purposes described in this notice and that the Authorised Individuals use your personal data in accordance with Privacy Laws.
We will also disclose your personal data to third parties outside of our corporate group for the following purposes:
- to third party agents and contractors for the purposes of providing services to us, including, IT and communications providers, law firms, accountants and auditors and recruitment agencies. These third parties will be subject to confidentiality and data protection requirements and they will only use your personal data as described in this privacy notice;
- to third parties relevant to the investment management services that we provide. This will include, but is not limited to, counterparties, current investors regulators, authorities, governmental institutions and stock exchanges;
- to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation; and
- in order to establish, exercise or defend our legal rights.
International transfers of personal data
The personal data that we collect from you will be transferred to, and stored at, a destination outside your home country. It will also be collected, used, disclosed and processed by individuals operating outside of your home country who work for us, our affiliates or for one of our suppliers.
Where we transfer your personal data outside of the jurisdiction or area in which it was collected, we will ensure that it is protected and transferred in a manner consistent with applicable Privacy Laws. This can be done by implementing one of the following appropriate safeguards:
- The country that we send the data to is approved by the European Commission as offering an adequate level of protection. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- The recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- We will enter into a data transfer agreement with the recipient.
- Where we use third-party service providers based in the US, we will transfer data to them if they are part of the EU-US Data Privacy Framework (or any future scheme which requires them to provide similar protection to personal information transferred between the Europe and the US, as and when this is approved by the US and the EU). For further details, see the Data Privacy Framework website and European Commission: EU-US Data Transfers.
In other circumstances, the law will permit us to otherwise transfer your personal data outside the jurisdiction or area in which it was collected. In all cases, however, any transfer of your personal data will be compliant with applicable Privacy Laws.
You can obtain more details about the protection given to your personal data when it is transferred outside your home country by contacting us using the details below.
Personal data security
We will ensure that the personal data that we hold is subject to appropriate security measures.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Retention of personal data
We will only hold your personal data for as long as is necessary to fulfil the purposes for which we collected it. The retention period will be determined by the following criteria:
- the purposes for which we process your personal data;
- the establishment, exercise or defence of Tudor’s rights, which will require us to store your personal data as archives;
- the amount, nature, and sensitivity of the personal data;
- the potential risk of harm from unauthorised use or disclosure of your personal data; and
- legal obligations – laws or regulation will set a minimum period for which we have to keep your personal data.
Job Applications
If you are unsuccessful, we will retain within our internal and/or external HR database your CV, or job application and any related ancillary documentation (for example, interview notes) for 12 months unless, following an unsuccessful application, you specifically consent to us holding it for longer for the purpose of contacting you in the event that any similar jobs / roles become available, from time to time, or we are required to do so for compliance with applicable laws or regulations.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and we shall issue a new privacy notice which sets down how we will collect, use, disclose and process your personal data and your rights in relation to this, including the periods for which your personal data will be held.
Change of purpose
To the extent required by relevant Privacy Laws, we will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we will if necessary process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Automated decision-making
Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes and will only do so if we have a lawful basis and in accordance with Privacy Laws.
Your rights
It is important that the personal information we hold about you is accurate. We ask that you keep us informed if your personal information changes during the course of your relationship with us.
You will have a number of legal rights in relation to the personal data that we hold about you and you can exercise your rights by contacting us using the details set out below. Under certain circumstances, and depending on applicable Privacy Laws, these rights will include:
- obtaining information regarding the processing of your personal data and access to the personal data which we hold about you (please note that there will be circumstances in which we are entitled to refuse requests for access to copies of personal data. In particular, information that is subject to legal professional privilege will not be disclosed.);
- requesting that we correct your personal data if it is inaccurate or incomplete;
- requesting that we erase your personal data in certain circumstances. Please note that there will be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
- objecting to, and requesting that we restrict, our processing of your personal data in certain circumstances. Again, there will be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to refuse that request;
- in some circumstances, receiving some personal data in a structured, commonly used and machine-readable format and/or requesting that we transmit that information to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
- to stop direct marketing;
- withdrawing your consent, although in certain circumstances it will be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so;
- lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us;
- in certain jurisdictions like France, you have the right to provide directives on the processing of your personal data after your death; and
- to be informed about the purposes for which your personal data is processed.
You can exercise your rights by contacting us using the details set out below.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we will charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we will refuse to comply with the request in such circumstances.
We will need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
California consumers
Whilst the categories of personal data we collect, the sources of that personal data, the business and commercial purposes for which we collect it, who we disclose it to, and how long we retain it, are set out in the sections above, California law requires that we use certain categories specific to California law:
Category of personal data: Identifiers
Examples as defined in California law: Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Collected? Yes
Category of personal data: Personal information categories listed in the California Customer Records statute, Cal. Civ. Code § 1798.80(e)
Examples as defined in California law: Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Collected? Yes
Category of personal data: Protected classification characteristics under California or federal law
Examples as defined in California law: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected? Yes
Category of personal data: Commercial information
Examples as defined in California law: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected? Yes
Category of personal data: Biometric information
Examples as defined in California law: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected? No
Category of personal data: Internet or other similar network activity
Examples as defined in California law: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Collected? No
Category of personal data: Geolocation data
Examples as defined in California law: Physical location or movements.
Collected? No
Category of personal data: Sensory data
Examples as defined in California law: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected? No
Category of personal data: Professional or employment-related information
Examples as defined in California law: Current or past job history or performance evaluations.
Collected? Yes
Category of personal data: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
Examples as defined in California law: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected? No
Category of personal data: Inferences drawn from other personal information
Examples as defined in California law: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected? No
Category of personal data: Sensitive personal information
Examples as defined in California law: Social security, driver’s license, state identification card, or passport number; user name, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; contents of consumer’s mail, email, and text messages unless we are the intended recipient of the communication; processing of biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.
Collected? Yes
In the preceding 12 months, we have collected and used Personal data in the manner described above and we may have disclosed to the categories of third parties listed under “Disclosure of your information to third parties”, for the purposes there provided, all of the categories of Personal Data as described above. We will not discriminate against you for exercising consumer rights.
California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what Personal Data is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not share Personal Data with outside parties for their direct marketing.
You must provide us with enough information that we can verify your identity and that you are a California resident. If you designate an authorized agent to make an access or deletion request on your behalf, we will require the agent to show written authorization from you and require you to verify your identity with us.
We have not “sold” personal information as defined by the CCPA. For this purpose, “sold” or “sale” means the disclosure of personal information for monetary or other valuable consideration but does not include, for example, the transfer of personal information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.
We have not “shared” personal data as defined by the CCPA. For this purpose, “share”, “shared” or “sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, your personal data in writing or by electronic or other means, to third parties for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions in which no money is exchanged.
We do not use personal data for automated decision-making or data profiling.
Supervisory Authorities
You can find out more information about your rights by contacting the applicable supervisory authority below:
We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority so please contact us in the first instance.
Contacting us
If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or, if applicable, the exercise of any of the rights listed above, please address questions, comments and requests to the
Tudor Group Data Privacy Team:
Tudor Investment Corporation
200 Elm Street, Stamford, CT 06902
Telephone: +1 203 863 8677
Toll-Free: +1 888 31 TUDOR (888 318 8367)
Email: dataprivacy@tudor.com
Tudor Capital Australia Pty Ltd
c/o DLA Piper Australia
Level 22
1 Martin Place
Sydney NSW 2000 Australia
Email: dataprivacy@tudor.com
Tudor Capital Europe LLP
10 New Burlington Street
London W1S 3BE
United Kingdom
Telephone: +44 207 518 5151
Email: dataprivacy@tudor.com
Tudor Capital Singapore Pte. Ltd.
Marina One West Tower
08-10 at 9 Straits View
Singapore 018937
Phone: +65-6932-6270
Email: dataprivacy@tudor.com
Tudor Capital France S.A.S,
12 Place Dauphine, 75001 Paris,
Email: dataprivacy@tudor.com
Changes to this Privacy Notice
Tudor may change this privacy notice from time to time by posting an updated version on its website. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes to this privacy notice will apply to you and your data immediately.