DRW Holdings, LLC and its affiliated companies, including DRW Canada Co., DRW UK Partners LLP, DRW Investments (UK) Limited, DRW Investments L.L.C., DRW Securities, LLC, and DRW Singapore Pte. Ltd., (collectively, “DRW”, “we”, “us”, or “our”), are committed to transparency in the collection and use of your personal information.
This notice (the “Privacy Notice”) sets forth a description of how we collect and use personal information, and the circumstances under which we may share this information. This Privacy Notice also describes your data protection rights, including your right to object to some of the processing which DRW carries out. More information about your data protection rights and how to exercise them is set out below. This Privacy Notice applies to all visitors to DRW’s website, located at https://drw.com/ (the “Website”).
Collection and Use of Information
Information That You Provide: DRW may collect and use the personal information such as your name, address, email address, signature, and other information that you provide in connection with the following:
- Visiting our Website;
- Applying for a job with us; and
- Contacting us with a comment, question or complaint.
Candidate Information: To apply for a job posted on our Website, you are required to create a candidate account (the “Account”) through our Website or one of our third party service provider’s website. You may also be asked to choose a username, password and security questions. This information is used to create your Account and/or otherwise manage the recruitment process. This information may also be provided by a recruiter acting on your behalf.
Once your Account has been created, you will be asked to create a profile. To create your profile, you may be asked to provide us with your full name, email address, city, country, phone number, mailing address, educational background, resume and a list of your relevant skills and certifications. This information will form the job application that you submit to DRW in response to a job posting and will be used in our recruitment process once submitted.
We also obtains data about you from other sources, including recruiters, employment research firms, identity verification services, the references you provide to us, websites and other publicly accessible data on the Internet. We will also receive data you submit to us through third-party websites. Where permitted, we collect details of professional registrations, and sanctions with professional bodies, financial checks or criminal convictions where you have consented to background checks.
Recruiting Communications: We may offer you the ability to signup to receive recruiting communications through our Website or connect with us on third party websites (including through social media sites). If you signup through our Website, we collect certain personal information (such as first and last name and email address) which we use to send you email and other communications containing DRW’s updates and other content that may be of interest to you.
Contact Information: When you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name and email address) along with additional information we need to help us promptly answer your question or respond to your comment or complaint.
Automatically-Collected Information: In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand activity on our Website and to monitor and improve our Website.
Purposes & Lawful Basis
|Purpose||Legal basis for data processing|
|Website related activities (e.g. dealing with enquiries, running analytics)||
Note: We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this Privacy Notice.
Disclosure and Transfer of Information
We do not transfer, sell, rent, trade or otherwise disclose your personal information, except as described in this Privacy Notice. We may transfer or disclose your personal information as follows:
Service Providers: Your personal information may be disclosed, stored and / or transferred (or otherwise made available) to our affiliates and other third parties who provide services such as recruiting, background checks, cloud-based information hosting and maintenance, website hosting, record keeping and analytics.
Legal and Compliance: We and our service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable European, Canadian, Singapore, United States, or other law or legal process. Your personal information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Sale of Business: Your personal information may be provided to third parties in connection with a business transaction, including a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of DRW or as part of a corporate reorganization, or stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
Safeguarding and Retention of Personal Information
We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We have employed reasonable measures designed to restrict access to your personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.
We have personal information retention processes designed to retain personal information for specified periods of time necessary for legal and business purposes.
Where we process data for recruitment purposes:
- For successful job applicants who become employees of DRW: for as long as you are an employee of DRW and for ten (10) years after the end of your employment.
- For unsuccessful job applicants who apply for a position in our London office: we keep your information for the period of time required for the purposes for which it was collected, any new purposes to which you subsequently consent, or to comply with legal, regulatory and DRW policy requirements.
Where we process contact information and analytics data provided by using and visiting our Website, we do this for as long as you are an active visitor of our Website and for three (3) years after this or as we are required by law.
Where we process personal information for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
Your Rights Relating to Personal Information
You have the right to access (ask for a copy of your personal information), update, correct or delete your personal information in our custody and control, and restrict (stop any active) processing of your personal information, subject to certain exceptions prescribed by law. You may request access, updating, deletions and corrections of inaccuracies in other personal information we have in our custody or control by emailing or writing to us at the contact information set out below. You may also obtain the personal information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller. We may request certain personal information for the purposes of verifying your identity when seeking access to personal information records.
In addition, you can object to the processing of your personal information in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time.
If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
Cookies and Additional Information about our Website
Session Management: On the pages on our Website where you are prompted to log in or that are customizable. If you have registered with our Website, these cookies (1) may let us know who you are, (2) may be necessary to access your account information (stored on our computers) in order to provide personalized services, and (3) will provide us and our service providers with information that we will use to personalize our Website in accordance with your preferences and interests.
You can manage your cookie preference by using our cookie consent management solution accessible here. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the features of our Website.
To opt-out of using cookies on this site, please click here.
Tracer Tags & Web Beacons: Our Website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on our Website. These tracer tags are used to help us optimize and tailor our Website.
Do Not Track Signals: We do not collect information about your online activities over time or across third party websites or services, and our Website does not recognize or process any web browser’s “do not track” signals or similar mechanisms.
Third Party Websites
We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture and gender) to deliver the content or as part of the operation of the Website, plug-in or application. For example, if you chose to sign-in to the Website through Facebook, you may authorize us to collect certain information from your Facebook profile.
Use by Minors Prohibited
The Website is not designed or intended for use by children under the age of 18, and we do not knowingly collect information from children. If you are under the age of 18, do not use the Website.
Updates to the Privacy Notice
We may update this Privacy Notice from time to time to reflect changes to our privacy practices. We encourage you to periodically review this page for the latest information on our privacy practices, and any use of our Website after any updates constitute your acknowledgement that you have read the updated Privacy Notice.
Please contact us if:
- you have any questions or comments about this Privacy Notice;
- you wish to access, update, and/or correct inaccuracies in your personal information; or
- you otherwise have a question or complaint about the manner in which we or our service providers treat your personal information.
You may contact us by email at firstname.lastname@example.org or by mail at the following addresses:
540 West Madison Street, Suite 2500
Chicago, IL 60661
The Leadenhall Building
122 Leadenhall Street
London, England, EC3V 4AB
Last updated: May 25, 2018