Your privacy and trust are important to us. This Statement explains how Lotus Fiduciary Services (“Lotus ” “we”, “us” or “our”) collects, handles, stores, and protects personal information about you in the context of our services. It also provides information about your rights and about how you can contact us if you have questions about how we handle your information. This statement provides adequate transparency into how we obtain, store, transmit, share, and use the personal information you provide.
Who this statement applies to
This Statement applies to individuals who use our website, online applications, or services provided by us (we call these our “Services”).
Within our Services, there may be links to third-party websites or applications. We are not responsible for the content or privacy compliance of third-party websites or applications. You should check those websites or applications for their privacy statements and terms that apply to them.
Children’s Privacy. Lotus provides services for clients and businesses and our services are not aimed at children and we do not intentionally collect personal data on minors.
Sources of personal information and why we collect it
The personal information we process is provided to us, often directly by you, for one of the following reasons:
You have made an information request to us – When you request information from us with your consent, we may also capture your personal information for later use in sharing information about our products and services.
You have attended, an event – Information we collect about you comes from our direct interactions with you. When you register for an event, we may collect information (online or offline) in relation to the event organization, and during an event, such as participation in sessions and survey results.
You subscribe to our newsletter – Lotus has regular email communications that we send to clients and other interested parties. These are opt-in only and you must complete our request form to opt-in.
You are representing your organization – In our relationship with clients or prospects, partners, and suppliers, they also provide us with business contact information (such as name, business contact details, position or title of their employees, contractors, advisors and authorized users) for purposes such as contract management, fulfillment, delivery of products and services, provision of support, invoicing and management of the services or the relationship.
Our servers, logs and other technologies automatically collect system/device and usage information to help us administer, protect, and improve our Services, analyze usage and improve users’ experience. When visiting our websites or using our Services we may provide you with personalized information. See more information regarding cookies and similar technologies below.
The personal information we collect consists of the following:
Name and contact data, such as first and last name, email address, phone number, and other similar contact information
Account Credentials, such as passwords and other security information for authentication and access
Device information, such as information about your device (i.e., IP address, location, or provider)
Usage information and browsing history, such as, information about how you navigate within our Services, your browsing history, and which elements of our Services you use the most.
How we use personal information
Some laws require us to explain our lawful reason for processing your personal information.
We process personal information about you on the basis that it is:
where you give us your consent: we only ask for your consent in relation to specific uses of personal information where we need to and, if we need it, we will collect it separately and make it clear that we are asking for consent
for legitimate interests: in specific situations, and where we have assessed the appropriateness of this lawful basis, we may process data based on legitimate business interests. Details of those legitimate interests are set out in more detail below
necessary for the performance of a contract: where we have a contract with you, we will process personal information in order to fulfil that contract
for compliance with a legal obligation (e.g., to respond to a court order or a regulator)
You can choose to receive information about our products and services or sign-up for subscriptions. In these instances, we request your consent for processing.
Where we reference that we use your personal information in connection with a request, survey, or to provide you with Services that you requested (such as a website), we do this based on your consent or because it is necessary for the performance of an agreement with you.
Where we reference that we use your personal information in relation to marketing, improvement or development of our website or services, for reasons of safety and security, or regulatory requirements other than in connection with your agreement or request, we do this on the basis of legitimate interests. We may assess the personal information we collect to develop aggregate analysis and business intelligence for conducting our business and for marketing purposes.
You are welcome to contact us for further information on the legal grounds that we rely on in relation to any specific processing of your personal information. Under certain laws you also have the right to object to or modify the way in which your personal data is processed. Details on these rights and how to contact us is included below.
How and with whom we share your data
Regardless of how you interact with Lotus we do not sell ANY information collected to any third parties. This includes but is not limited to newsletter subscribers and event attendees.
There may be instances in which we share your information with others. We may share your information as required by law, to comply with legal process, to protect our legal rights, to protect the safety or security of a person, or to protect against fraud, criminal acts, or misconduct. We may also share your information with companies that provide services to us directly.
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related functions or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated to maintain appropriate protections and not to disclose or use it for any other purpose.
How we safeguard personal information
How we store and delete personal information
We will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims.
Under data protection law, you have rights we need to make you aware of. We will honor your rights under applicable data protection and privacy laws. You have the following rights under United States laws and may have similar rights under the laws of other countries.
Right of subject access: The right to make a written request for details of your personal information and a copy of that personal information
Right to rectification: The right to have inaccurate information about you corrected or removed
Right to erasure (‘right to be forgotten’): The right to have certain personal information about you erased
Right to restriction of processing: The right to request that your personal information is only used for restricted purposes
Right to opt out of marketing: You can manage your marketing preferences by unsubscribe links found in the communications you receive from us or by visiting the applicable preference center
Right to object: The right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interest
Right to data portability: The right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable format
Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent
These rights are not absolute, and they do not always apply in all cases. In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better.
To object to or modify the way in which your personal data is processed, please contact us using the information below.
To opt out, click on the preferences link at the bottom of the email that you received from us, call us at the number provided below or send us an email at the address below.
Please provide us with your exact name, email address and physical address and indicate the update you wish us to make.