Effective May 2020
Wheelhouse Advisors Limited and its subsidiaries (hereinafter referred to collectively as “Wheelhouse Advisors,” “we” or “us”; each doing business as Wheelhouse Advisors) are committed to respecting confidentiality and the privacy of all corporate and individual contacts, including users of our website(s), suppliers, clients, prospective clients, as well as our clients’ and prospective clients’ employees, directors and members, customers and suppliers.
Across all of its activities and actions Wheelhouse Advisors complies with the Professional Conduct in Relation to Taxation guidelines (“PCRT”) prepared by the Institute of Chartered Accountants in England & Wales in conjunction with the Chartered Institute of Taxation. The principle of confidentiality (see box below) is one of the central tenets of both the PCRT and how we do business:
To respect the confidentiality of information acquired as a result of professional and business relationships and, therefore, not disclose any such information to third parties without proper and specific authority, unless there is a legal or professional right or duty to disclose, nor use the information for the personal advantage of the member or third parties.
As part of our commitment to confidentiality and privacy, Wheelhouse Advisors has developed this policy (the “Policy”) to advise you of the ways in which we collect, use, share and protect information you share with us through our website, www.wheelhouse-advisors.com, and any other website or application where the Policy is posted (each, a “Site”). Any person accessing, browsing or otherwise using a Site, either manually or via an automated device or program, is a “User” for purposes of the Policy.
User Consent to Policy
By accessing, browsing, or using a Site, or following links through the Site to apply for employment with Wheelhouse Advisors, each User acknowledges that he or she has read, understands, agrees and consents to all terms and conditions set out in the Policy. Each User consents to the collection, use, and disclosure of his or her information, including personal information, non-personal information, and anonymous browsing information (“User Information”), pursuant to the terms of this Policy. If you do not consent to these terms and conditions, you should not access, browse, or use any Site.
Following links from the Sites
Accessing, Changing or Deleting Your User Information
Wheelhouse Advisors allows you to make a request to correct inaccuracies in or make other changes or delete your User Information by sending an email to firstname.lastname@example.org. We will use commercially reasonable efforts to promptly accommodate such requests.
Users are responsible for the accuracy of any User Information that they provide to Wheelhouse Advisors. We will use reasonable efforts to maintain the accuracy and integrity of Information based on the input received from Users.
Each Site has commercially reasonable security measures to protect against the loss, theft, misuse, and alteration of User Information and remains under the control of Wheelhouse Advisors. You should be aware, however, that we have no control over the security of other websites that you might visit or use, even when a link to those websites is available on or through any Site. If you share your equipment or use equipment that is accessed by the general public, remember to sign off and close your browser when you finish using any Site.
Wheelhouse Advisors wants you to feel confident using each Site; however, no system can be completely secure. Therefore, Wheelhouse Advisors makes no representations or warranties regarding the sufficiency of any Site’s security measures. Wheelhouse Advisors shall not be responsible for any damages, including without limitation consequential damages, resulting from a lapse in compliance with this Policy as a result of a security breach or technical malfunction. As the operator of each Site, Wheelhouse Advisors may need to review or monitor your communications through each Site from time to time as may be required by law.
In the event of a breach of the confidentiality or security of User Information, Wheelhouse Advisors will notify you if reasonably possible and as reasonably necessary under applicable law so that you can take appropriate protective steps. We may notify you under such circumstances using the email address or addresses that we have on record for you.
We may occasionally update the Policy, as noted by any “updated date” at the beginning of the Policy. If we update the Policy in a manner that allows us to collect, use, or disclose your personal information in a materially less restrictive manner than under a prior version of the Policy, we will provide you with prior notice of the pending update and seek your consent by posting notice on www.wheelhouse-advisors.com or by contacting you using the email address or addresses that we have on record for you. Wheelhouse Advisors encourages you to periodically review this Policy to stay informed about its collection, use, and disclosure of User Information. Your continued use of any Site constitutes your agreement to the Policy and any updates.
Enforcement and Dispute Resolution
If you have any questions, complaints, or disputes regarding how we handle or protect User Information, please bring it to our immediate attention (see “How to Contact Wheelhouse Advisors” below).
Wheelhouse Advisors retains sole and absolute discretion in resolving all questions relating to the administration, interpretation and application of the Policy, except as required by law. This authority includes construing the terms of this Policy, including any disputed or doubtful terms.
No Rights of Third Parties
The Policy does not create rights enforceable by third parties.
How to Contact Wheelhouse Advisors
If you have any questions about the Policy, please email email@example.com
EU GDPR Privacy Notice
Wheelhouse Advisors has developed an EU GDPR Privacy Notice (the “GDPR Notice”), available at www.wheelhouse-advisors.com/gdpr-notice, which supplements the Policy. The GDPR Notice contains additional information regarding how we handle personal information that is subject to the EU General Data Protection Regulation (“GDPR”) and related privacy laws when we are the controller or processor of such information. User Information may be subject to the GDPR Notice, which explains we handle the personal information we collect through Sites, the personal information we collect when individuals engage with us or use our products or services (our “Services”), the personal information we receive about individuals as a result of providing Services to our clients, and the personal information we receive from applicants for employment opportunities with Wheelhouse Advisors, whenever such personal information is subject to GDPR. For the purposes of the GDPR Notice, “personal information” means information relating to an identified or identifiable person who is a resident of the European Union.
Written Terms of Business
Written terms of business, forming part of each of our contracts to deliver Services, supplement the Policy by providing further details on our confidentiality obligations to our clients during and beyond the course of our engagement.