Last updated: November 11, 2020
Data We Collect
When you interact with our Website, we may collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”), as described below.
Personal Data That You Provide: If you voluntarily submit information to us (for example, when you request information by completing our “Contact Us” form), we will collect your name, contact information (e.g. email and phone number), the content of your message or request and any other Personal Data that you elect to provide. When you apply for a job at Denham, we also collect Personal Data in your resume and any other information you provide as part of your application.
Automatically Collected Data: As you interact with our Website, our server collects certain usage information, such as information about the number and frequency of visitors, how users are directed to and visitor paths through our Website. We collect the websites that you access immediately before and after your visit to our Website, the Internet browser you are using and your internet protocol (“IP”) address.
Personal Data From Other Sources: In connection with your application for a job at Denham, we also collect Personal Data from third parties in connection with your application for a job at Denham, including from referees, recruiters or recruitment platforms and organizations that provide background checks (this will include right to work, criminal, civil and regulatory reference checks, credit history, past work history, educational history, social media and professional licenses where applicable).
How We Use Personal Data
We use your Personal Data as necessary for certain legitimate business interests, which include the following:
- To respond to your inquiries or questions;
- To administer our Website and prevent fraud, criminal activity, or misuses of our Website and ensure the security of our IT systems, architecture and networks;
- To determine and validate your qualifications and suitability for employment, conduct background checks, communicate with you and if you are a successful applicant, to create an employment record; and
- To comply with legal obligations, legal process, and procedures.
For information about what we mean by “legitimate interests” and the rights of individuals in the European Union (“EU”), please see the “EU Users” section below.
How We Share Data
We share, and have shared over the past 12 months, the Personal Data outlined above as follows:
- With our service providers who assist us in meeting business operations needs and to perform certain services and functions, including analytics (e.g. Google Analytics and WordPress), search engine providers, providers of hosting, cloud services and other information technology service providers that assist us in the maintenance, improvement and optimization of the Website;
- With organizations that assist us with our recruitment processes, including recruitment agencies, professional bodies and educational establishments, background check providers and referees whose details you provide;
- With any relevant third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets, including in the event of a reorganization, dissolution, or liquidation; and
- Any relevant party, claimant, law enforcement agency, court, governmental, supervisory, or regulatory bodies, to the extent necessary for the establishment, exercise or defense of legal rights in accordance with applicable law and regulation.
We do not sell Personal Data collected about you.
What Are Cookies. A “cookie” is a piece of information sent to your browser by a website you visit.
Type of Cookies Used. The Website uses the following technologies:
- Google Analytics. The information collected by Google (including your IP address) will be transmitted to and stored by Google, Inc. on servers in the United States. Some Google Analytics cookies expire at the end of your browser session, whilst others can remain for up to two years.
Do Not Track. “Do Not Track” is a privacy preference that you can set in some web browsers, allowing you to opt out of tracking by websites and online services. Like many websites, our Website does not recognize or respond to Do Not Track requests.
International Data Transfers
We are based in the United States. Your Personal Data will be stored on servers in the United States. We will take steps to ensure that your information receives an adequate level of security protection where it is processed and your rights continue to be protected.
Scope. This section applies if you are a user in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, to the extent applicable, Switzerland).
Data Controller. Denham Capital Management LP is the data controller responsible for your Personal Data collected through this Website. We have appointed Denham Capital Management (UK) LLP, our subsidiary registered in the UK as our representative in the European Union pursuant to Article 27 of the General Data Protection Regulation, only on matters related to the processing of Personal Data collected through the Website. You may contact us or our representative as set out under the “Contact Us” section below.
Your Rights. Subject to applicable EU law, you have the following rights in relation to your Personal Data:
- Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it.
- Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent.
- Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing.
- Right to data portability: You have the right to obtain your Personal Data in a structured, commonly used and machine-readable format where our legal basis for processing your data is your consent or necessity to perform a contract with you, if applicable.
- Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so, if we are relying on the legitimate interest legal basis to process your Personal Data – unless we demonstrate compelling legitimate grounds for the processing;
- Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
- Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
You may exercise your rights by contacting us as indicated under the “Contact Us” section below.
Legitimate Interest. “Legitimate interests” means our interests in administering and conducting our business, managing risks, and delivering the best Website experience to you. This Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.
Scope. This section applies if you are a California resident visitor to our website.
Your Rights. Subject to applicable California law, including any exceptions, you may have the following rights in relation to your Personal Data:
- Right to know: You may, not more than twice in a 12 month period, request more information about the Personal Data that we collect, use or disclose, and request a copy of such Personal Data.
- Right to request deletion: You may request that we delete Personal Data that we have collected from you. However, we may not be required to delete your Personal Data under certain circumstances.
Right to non-discrimination: We will not discriminate against you for exercising your rights under the CCPA.
You may exercise your rights by contacting us as indicated under the “Contact Us” section below. To protect your Personal Data, we may need to verify your identity before processing your request to exercise your “right to know” and “right to request deletion.” In some cases we may need to collect additional information to verify your identity, such as a government issued ID. You may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.
We will keep your Personal Data for as long as reasonably necessary for the purposes described in this Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.
To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
This Website may contain links to other sites owned and operated by other parties. We are not responsible for and have no control over the privacy policies of those sites. By providing these links we do not imply that we endorse or have reviewed these sites. We encourage you to review the privacy policies of those sites prior to providing them with any information.
Changes to the Policy
We may change this Policy at any time. If we do so, we will post the updated version on our Website and notify you and follow such other steps as required by applicable law.
If you have any questions regarding our Policy or our privacy-related practices, please contact us here or at 617-531-7200.
If you are an individual in the EU, you can also contact Denham Capital Management (UK) LLP, our subsidiary registered in the UK who has been appointed as our representative in the European Union pursuant to Article 27 of the General Data Protection Regulation only on matters related to the processing of Personal Data collected through the Website. To make such an inquiry, please contact us.