Client and third party privacy notice

Effective date: May 2018

AME is committed to collecting, maintaining, and using personal information about our clients and business contacts responsibly. The provisions of data protection laws strict conditions on AME.

This privacy notice explains how we may collect, use and disclose information about clients and other business and firm contacts, and describes the rights you may have in respect of your own personal information.

AME

AME operates worldwide as a technical orientated research company specialising in the resources sector. Contact details for our offices around the world can be found on our website www.amegroup.com.

Clients

This notice applies to the individual client contacts with whom we deal, including prospective clients. It applies to personal information that is collected as part of our client on-boarding process and disengagement, as well as to the information gathered during the course of a client relationship.

It also applies to the personal information of employees at client entities whose details we may receive as part of the provision of legal services. In these circumstances our main client contact is responsible for ensuring that all affected individuals are made aware that their personal details will be provided to us and of the purposes for which we will use that information, for example by showing them a copy of this notice.

Business contacts

In addition, this notice covers the personal information of individuals who are not existing or former clients but who engage with the firm by signing up to receive communications such as email alerts and publications, or who attend events run by the firm (either alone or in conjunction with partner organisations).

Personal information

In this privacy notice, “personal information” means any information (whether electronic or written) relating to an individual who can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

Research or advisory

AME is committed to collecting and using only the personal information that is necessary for the provision of research or advisory services to our clients; to establish and/or maintain its business relationship with business and/or firm contacts; and to keep individuals informed of services and events which it reasonably considers may be of interest to them and/or which they have otherwise confirmed their preference to receive from the firm.

In some cases, it will be mandatory for you to provide personal information to the firm to enable us to provide services to you (or your employer), engage with you or to comply with the firm’s legal obligations.

Due diligence

AME collects a variety of information about clients and client contacts as part of our new client on boarding process. This may be referred to as due diligence or “Know Your Client.” The checks may include some or all of the following:

  • Identity verification:proof of name and address
  • Ultimate beneficial ownership of corporate and other legal entities
  • Confilcts checks:to avoid a conflict of interest with any other client
  • Anti-money laundering, proceeds of crime and terrorist financing checks

These checks are made for legal, regulatory or business reasons and may need to be repeated during the course of our engagement. It is important that you provide us with all necessary information and documents or this may affect our ability to provide services.

Providing research or advisory services

AME may collect or generate additional details about you during the course of our engagement, for the purpose of providing research or advisory services. As part of this we may collect information about employees of client organisations, for example when advising on a business sale, relocation programme or share scheme.

We may also use your personal information:

To administer our relationship and maintain contractual relations

  • For accounting and tax purposes
  • For marketing and business development
  • To comply with the firm’s regulatory obligations
  • To establish, exercise or defend legal rights
  • For the prevention and detection of crime
  • For historical and statistical purposes

Other business interactions

As part of your business or other commercial dealings with the firm, we may collect or generate details about you. We may use this personal information to administer our relationship and maintain contractual relations, for accounting and tax purposes and to comply with our regulatory obligations.

Information collected at our premises

If you visit our premises, your image may be captured on CCTV systems operated by the firm or the entity which manages our premises. Building access control systems may also capture the location, time and date of your entry and exit to our offices.

Marketing and business development

AME collects information for marketing and business development purposes and as part of the general administration of client relationships. We may use some personal information for client entertainment purposes, including recording your interests and preferences. We may use your personal details to send you information by email or post, or using social media or social networking sites, about our services, developments in law and practice, brochures, press releases, invitations to seminars and talks. You can select the practice areas and subjects you are interested in when you sign up on our website. You may update your preferences or opt out at any time.

International

AME is an international firm operating on a global basis. Like most international businesses, AME has centralised certain aspects of its client administration and records management. In addition, where client projects span more than one jurisdiction, information will need to be accessed by all those within the firm who are working on the matter. As a result, your personal information may be transferred outside the country of origin (which includes transfers outside the European Economic Area) and may be accessed across the firm on a global basis.

Disclosures

The firm may disclose your personal information (i) if required by applicable law; (ii) in connection with a reorganization or combination of our firm with another firm, (iii) if we believe that such disclosure is necessary to enforce or apply terms of engagement and other agreements or otherwise protect and defend AME’s rights, property or safety; (iv) in order to comply with a judicial proceeding, court order or other legal obligation, or a regulatory or government inquiry; or (v) with your consent.

Third party recipients of personal information relating to clients, business and firm contacts may include:

  • Tax and Customs & Excise authorities
  • Regulatory and other professional bodies
  • Stock exchange and listing authorities
  • Public registries of company directors and shareholdings
  • Providers of identity verification services
  • Credit reference agencies
  • The courts, police and law enforcement agencies
  • Government departments and agencies
  • Auditors and professional advisers (including professional indemnity insurers and advisers)

AME will use all reasonable efforts to disclose the minimum personal information necessary in each case.

Keeping your information up to date

The firm may disclose your personal information (i) if required by applicable law; (ii) in connection with a reorganization or combination of our firm with another firm, (iii) if we believe that such disclosure is necessary to enforce or apply terms of engagement and other agreements or otherwise protect and defend AME’s rights, property or safety; (iv) in order to comply with a judicial proceeding, court order or other legal obligation, or a regulatory or government inquiry; or (v) with your consent.

Retention

The firm will retain personal information only for as long as it is needed for the purposes described in the section above: Personal Information. Note that retention periods may vary in different jurisdictions. The retention period for client files is detailed in our Engagement Letters.

We may need to retain information for significant periods of time in order to establish, exercise or defend our legal rights, and for archiving and historical purposes. Where possible and practical, personal information will be rendered anonymous through the removal, substitution or blocking of details which enable individuals to be identified.

Your rights

You have the following rights in relation to your personal information:

  • to access the personal information held by AME about you;
  • to have your personal information corrected, for example if it is incomplete or incorrect;
  • to opt out of receiving marketing communications at any time;
  • in certain circumstances and subject to applicable law, the right to restrict or object to the processing of your personal information, or request that your personal information is erased;
  • in certain circumstances and subject to applicable law, the right to receive a copy of the personal information which you have provided to the firm, in a structured, commonly used and machine-readable format (known as “data portability”);
  • where you have provided personal information voluntarily, or otherwise consented to its use, the right to withdraw your consent;
  • the right to complain to a Data Protection Authority (see further below).

If you have a query about this statement or wish to exercise your rights, please feel free to Contact Us