LOAN SYNDICATIONS AND TRADING ASSOCIATION WEBSITE PRIVACY POLICY
Welcome to the Loan Syndications and Trading Association, Inc. (the “LSTA”) Website. The LSTA can be contacted by mail at 366 Madison Avenue, 15th Floor, New York, New York 10017; by telephone at 212-880-3000 and by email at lstanews@lsta.org. This Website is hosted on servers owned and maintained by Amazon Web Services (AWS). The following applies to the Website located at the uniform resource locator, www.lsta.org.
1. COLLECTION OF PERSONAL INFORMATION FROM WEBSITE VISITORS
The LSTA automatically collects and/or tracks (1) the home server domain names, e-mail addresses, type of client computer, and type of Web browser of visitors to the LSTA’s Website, (2) the e-mail addresses of visitors that communicate with the LSTA, (3) information knowingly provided by the visitor in registration forms, and surveys, and (4) information on what pages visitors access.
The LSTA does place Internet cookies on visitors’ hard drives. Internet cookies save the visitor’s name, password, user-name, screen preferences, the pages of the LSTA’s Website viewed by the visitor, and the advertisements viewed or clicked by the visitor. One reason for cookies is that the user will not be prompted to enter a username and password each time he wishes to view a protected area of the Website. When the visitor revisits the LSTA’s Website, the LSTA will recognize the visitor by the Internet cookie and customize the visitor’s experience accordingly. Internet cookies are stored on the visitor’s hard drive and are not stored, in any form, by the LSTA. Visitors may decline the Internet cookie by using the appropriate feature of their Web client software, if available.
When a visitor performs a search on the LSTA’s search engine, the LSTA records information identifying the visitor or linking the visitor to the search performed. As necessary to provide service, the LSTA does record limited information for every search request and uses that information only to solve technical problems with the service and to calculate overall usage statistics.
2. USE OF PERSONAL DATA COLLECTED
Personal data collected by the LSTA will be used by the LSTA for editorial and feedback purposes, for marketing and promotional purposes, for a statistical analysis of users’ behavior, for product development, for content improvement, to inform advertisers as to how many visitors have seen or clicked on their advertisements, and to customize content and layout of the LSTA’s Website. Data on visitors’ home servers is aggregated for internal review and then discarded. Names, postal and e-mail addresses, and phone numbers collected may be added to the LSTA’s databases and used for future calls and mailings regarding site updates, new products and services, upcoming events, and status of orders placed online.
If you are resident in the UK or European Economic Area (together “Europe”) at the time that the LSTA provides services to you, the data processing information below applies to the use of your data. If you are resident in California, the data processing information below applies to the use of your data.
3. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
By accessing and using the LSTA Website, you understand and agree that the LSTA may post on its Website any information collected from you, and may share or otherwise disclose data to third parties other than specified in this Policy or without further notice to you.
Through the use of third party cookies, advertisers will be electronically notified when visitors view or click on their advertisements.
4. COLLECTION OF PERSONAL DATA FROM CHILDREN
The LSTA’s Website is not intended for use by children under the age of 18. The LSTA does not intentionally collect or post personally identifying information from children under the age of 18. The LSTA does not intentionally provide any personally identifying information collected from children under the age of 18, regardless of its source, to any third party for any purpose whatsoever.
5. LSTA’S RIGHT TO CONTACT USER
The LSTA reserves the right to contact site visitors regarding membership status and changes to the subscriber agreement, privacy policy, or any other policies or agreements relevant to site visitors.
6. LSTA’s RIGHT TO CHANGE PRIVACY POLICY
The LSTA reserves the right to change this policy at any time by notifying visitors of the existence and location of the new or revised privacy policy. The effectiveness of any notification of policy changes by the LSTA is not conditional upon any acknowledgement from visitors.
7. EUROPEAN RESIDENTS PRIVACY INFORMATION
If you are a European resident individual, you have certain rights in relation to your personal information under the applicable European data privacy laws. This section only applies to such users. Under applicable European data privacy laws, the LSTA is the data controller.
(a) Rights to Control Your Personal Information
Applicable European data privacy laws give certain users the right to access their personal information. Your right of access can be exercised in accordance with the European data privacy laws. If you would like to request a copy of your personal information being held by us, or request that it is deleted or to update and/or correct your personal information or request that we provide a copy to another data controller of your personal information that you have provided to us, please contact us. We will need enough information to ascertain your identity as well as the nature of your request. We will aim to respond to your request within one calendar month of receipt of the request. Where we were unable to do so within the calendar month, we will notify you of the soonest practicable time within which we can respond to your request (and within three months from the date of your request). There are certain exemptions and restrictions of these rights under the European data privacy laws that enable personal information to be retained, processed or withheld from access and we will inform you of these if applicable. If you would like to exercise any of these rights, please contact us at lstanews@lsta.org.
(b) We use your Personal Information for the following key purposes:
• to contact you: subject to applicable law, we or our third-party service and business providers may send you communications, especially if you have subscribed to one of our services. Such communications are designed to make your experience of our Website more efficient and may include, but are not limited to: communications about our organization and other notifications including important news that could affect your relationship with us. Where required under applicable data privacy laws, we will not send you marketing communications without your prior consent;
• for legal purposes: we may use and share personal information for legal purposes, including financial, regulatory, tax and other legal obligations and to respond to governmental or regulatory requests or subpoenas or for litigation purposes;
• for our legitimate interests and those of a third party: we may use your personal information to manage our legal, regulatory, financial and business requirements, including obtaining legal advice, in the course of disputes and litigation, internal and/or regulatory investigations and other legitimate interests; we also use your personal data for our legitimate marketing purposes and we may share your data with third parties, such as our sponsors, where we consider this meets our legitimate interests or those of our sponsors, whilst respecting users’ data privacy rights;
• for our business purposes: we may use your personal information to help us manage the objectives of our organization;
• for other purposes: subject to applicable law, we may use your personal information for additional purposes in connection with the Website or our organization, where you have provided your prior consent.
(c) International Transfers
Your personal information will be processed in the US (which may have less stringent data privacy laws compared to those in your country of residence) and we also transfer your personal information to the recipients described in this Privacy Policy including those recipients located in countries which may also have a less stringent standard of data privacy laws compared to those in your country of residence. Where this occurs, you acknowledge and where required, consent to such transfer in accordance with this Privacy Policy.
(d) Sharing your personal information
We share your personal information with third parties to help us use your personal information, as described in the Privacy Policy and in addition, we may need to share your personal information with our professional tax, legal, audit or financial advisors as well as sponsors, members and other organisations in the proper course of our business. We may also share your personal information when we receive requests for information in the context of legal disputes, investigations, regulatory enquiries or similar requests.
(e) Tracking Tools
This Website collects cookies and may use cookies for reasons including, but not limited to:
• Analyze our web traffic using an analytics package
• Identify if you are signed in to the Website
• Test content on the Website
• Store information about your preferences
• Recognize when you return to the Website
In addition, this Website uses Google Analytics and other analytics programs to collect information about you and your behaviors. If you would like to opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaopto. If you choose to block or delete cookies, certain features of our Website may not operate correctly. For more information, see www.allaboutcookies.org.
(f) Retention of personal information
We will only retain your personal information for as long as reasonably necessary. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and applicable legal requirements.
(g) Data Security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
(h) Complaint Process
If you have any concerns regarding how we are handling your personal information, please contact us at lstanews@lsta.org. We will strive to deal with your concerns promptly. If you wish to complain about the handling of your personal information outside of the LSTA, you have the right to raise a complaint with a supervisory authority in your country of residence under European data privacy laws.
8. CALIFORNIAN RESIDENTS PRIVACY INFORMATION
California law permits our users who are California residents to request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. To make such a request, please write to us at lstanews@lsta.org.
If you are a California resident, California law also provides you with the following additional rights with respect to your personal information:
• The right to know what categories or specific personal information we have collected, used, disclosed and sold about you. You also may designate an authorized agent to make a request for access on your behalf.
• The right to request that we delete any personal information we have collected about you. You also may designate an authorized agent to make a request for deletion on your behalf.
To submit a request, you may email us at lstanews@lsta.org. When you exercise these rights and submit a request to us, we will verify your identity by asking you for your email address, telephone number or other information. We also may use a third party verification provider to verify your identity. We will endeavor to honor client’s requests unless such a request conflicts with certain lawful exemptions under the California Consumer Privacy Act of 2018. Please note that we are only required to honor such requests twice in a 12-month period. For the 12-month period prior to the date of this Privacy Policy, the LSTA has not sold any personal information about its users and nor does it have any plans to do so in the future.
