Data Privacy Policy
What data do we collect?
EFSI collects the following data:
- Personal identification information (Name, email address, phone number, social security number, etc.).
- Bank account information (Name of financial institution, name of account holder, account number, wire instructions)
- Copy of driver’s license and/or passport
How do we collect client data?
Data is directly provided to EFSI either by our clients or by our clients’ investors. EFSI collects and processes data when:
- Onboarding a new fund launch and/or when onboarding an established fund as a conversion from another fund administrator
- A client receives an initial subscription from a new investor
- A client’s investor submits a redemption request or transfer of shareholder interest request
How will we use client data?
EFSI collects client data so that we can:
- Conduct anti-money laundering due diligence reviews on new investors subscribing to a client’s investment fund
- Review and process initial investor subscriptions and subsequent additional subscriptions
- Review and process investor redemptions
- Review and process investor transfers of shareholder interests
If a client agrees, EFSI will share certain personal data with other third-party services providers engaged by our clients such as:
- Audit Firms
- Tax Accounting Firms
- Financial institutions providing banking services to our clients
How do we store client data?
EFSI securely stores data on the cloud via Amazon Workspace (“AWS”). Access to EFSI’s data network first requires an AWS authentication key, and then user authentication against the Microsoft Windows domain by entering a valid user ID and confidential password.
Access to critical folders may be restricted by utilizing Windows groups established on the domain, which are based on department access privileges. The network user ID’s are associated with a user group(s) to control access to associated network resources and data.
EFSI will retain client data for a minimum of seven (7) years and will continue to do so for as long as the client remains engaged with EFSI. Once an EFSI client engagement has terminated (assuming the seven (7) year minimum retention period has been met, EFSI will delete the client’s personal data.
Marketing
EFSI does not use client personal data for marketing purposes.
What are your data protection rights?
EFSI would like to ensure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access – EFSI clients have the right to request copies of client personal data.
The right to rectification – EFSI clients have the right to request that EFSI correct any information our clients believe to be inaccurate. EFSI clients also have the right to request that EFSI complete any information our clients believe to be incomplete.
The right to erasure – You have the right to request that EFSI erase client personal data, under certain conditions.
The right to restrict processing – You have the right to request that EFSI restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to EFSI’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that EFSI transfer to another organization, or directly to you, the personal data we have collected, under certain conditions.
If you make a request, we have thirty (30) days to respond to you. If you would like to exercise any of these rights, please contact us at:
Email: investorservices@essentialfsi.com
Phone: 646-948-6500
Privacy policies of other websites
The EFSI website may contain links to other websites. EFSI’s privacy policy applies only to EFSI’s website, so if you click on a link to another website, the user should read that particular website’s privacy policy.
Changes to EFSI’s privacy policy
EFSI keeps its privacy policy under regular review and places any updates on its website. This privacy policy was last updated on September 23, 2019.
How to contact EFSI
If you have any questions regarding EFSI’s privacy policy, the personal data we hold, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.
Email: investorservices@essentialfsi.com
Phone: 646-948-6500
How to contact the appropriate authority
Should you wish to report a complaint or if you feel that EFSI has not addressed your concerns in a satisfactory manner, you may contact the regulatory authority of the applicable jurisdiction.