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Legal

Privacy Notice

Effective: August 23, 2024

DRW Holdings, LLC, and its affiliates (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 such information. This Privacy Notice also describes your data protection rights and how you may exercise them, as set out below.

This Privacy Notice applies to all visitors to DRW’s website, located at https://drw.com/ (the “Website”).

California residents, please review the California Privacy Notice for information about your rights under California’s privacy laws.

COLLECTION AND USE OF INFORMATION

DRW may collect and use personal information, such as your name, address, email address, signature, and other information, in connection with the following:

  • Visiting our Website;

  • Applying for a job with us;

  • Communicating with us (e.g., contacting us with a comment, question, or complaint);

  • Safety and security; and

  • Complying with applicable laws and regulations.

Candidate Information: To apply for a job on our Website, you (or a recruiter acting on your behalf) will be asked to provide us with certain information, including, but not limited to, your full name, email address, city, country, phone number, mailing address, educational background, and resume information, as well as your employment eligibility information. This information will be used in our recruitment and hiring process once submitted.

If you choose to “Apply with LinkedIn” or otherwise provide us with your LinkedIn profile web address as part of your application, we may obtain access to certain LinkedIn profile information (consistent with your LinkedIn privacy settings), including, but not limited to, your profile information, full name, username, and email address. All such information is provided directly by LinkedIn, whose use of your personal information is subject to LinkedIn’s privacy policy and terms of use. Similarly, if you apply for a job with us through a third-party job board, your information will be provided to us according to the privacy policy and terms of use of the applicable job board. We are not responsible for the processing of your personal information by LinkedIn or any other third party, including any recruiters acting on your behalf.

As part of your application, you will have the option of completing a voluntary self-identification survey for the purposes of government reporting. Your responses to the survey will be stored in a confidential file and not considered by us in the hiring process or thereafter.

Following the submission of your application, we may also obtain information about you from other sources, including recruiters, employment research firms, identity verification services, the references you provide to us, 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, sanctions with professional bodies, and financial checks or criminal convictions where you have consented to background checks.

For candidates located in certain jurisdictions, DRW may use data analytics for recruitment purposes. Candidate selection and hiring decisions are reviewed and conducted by DRW's talent acquisition team and not by automated means.

Recruiting Communications: We may offer you the ability to sign up to receive recruiting communications through our Website or connect with us on third party websites (including through social media sites). If you sign up 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 concerning DRW 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 answer your question or respond to your comment or complaint.

Social Media Information: If you interact with us through social media or other channels, we may store the details of these interactions.

Automatically-Collected Information: We may collect the IP (Internet Protocol) addresses of 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.

Information Collected with Consent: Where your consent is required by law, we may seek to obtain your consent to collect and use certain types of personal information. If we ask for your consent to process this personal information, you may have the right to withdraw your consent.

PURPOSES & LAWFUL BASIS

Purpose: Recruitment activities

Lawful basis for data processing:

  • Processing is necessary for the performance of a contract

  • Processing is necessary for compliance with a legal obligation to which DRW is subject

  • Processing is permitted with your consent

  • Processing is necessary for the legitimate interests pursued by DRW or others, which include applicant recruiting, evaluation, and selection, protecting our legal rights in case of recruitment discrimination claims, use in connection with legal and compliance, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation), and other ethics and compliance reporting requirements

Purpose: Communicating with you by email, phone, or other means

Lawful basis for data processing:

  • Processing is necessary for the performance of a contract

  • Processing is necessary for compliance with a legal obligation to which DRW is subject

  • Processing is permitted with your consent

  • Processing is necessary for the legitimate interests pursued by DRW or others, which include communicating with you by mail, phone, email, or other means, use in connection with legal and compliance, auditing, and compliance reporting requirements

Purpose: Safety and security

Lawful basis for data processing:

  • Processing is necessary for the legitimate interests pursued by DRW or others, which include protecting the safety and security of DRW, its personnel, property, and others

Purpose: Compliance with applicable laws and regulations

Lawful basis for data processing:

  • Processing is necessary for compliance with a legal obligation to which DRW is subject

Purpose: Website related activities (e.g., dealing with inquiries, running analytics)

Lawful basis for data processing:

  • Processing is necessary for the performance of a contract

  • Processing is necessary for compliance with a legal obligation to which DRW is subject

  • Processing is permitted with your consent

  • Processing is necessary for the legitimate interests pursued by DRW or others, which include operating the Website and its related functionalities, improving the Website, analyzing Website visitor and usage data, and protecting our systems and networks

DISCLOSURE AND TRANSFER OF INFORMATION

We do not sell, rent, or trade your personal information. However, we may disclose, transfer or otherwise make your personal information available as follows:

Service Providers: Your personal information may be disclosed, 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 for detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable 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.

International Transfer: Your personal information may be stored and processed by us, our affiliates, and other third-party service providers in the United States and other countries outside of the United Kingdom and the European Economic Area. With respect to transfers out of the United Kingdom and the European Economic Area, we have taken steps to provide an adequate level of protection for your personal information in accordance with applicable law, including, for example, using an approved transfer mechanism (e.g., Standard Contractual Clauses). You may obtain further information by contacting us using the details set out later in this Privacy Notice.

SAFEGUARDING AND RETENTION OF PERSONAL INFORMATION

We have implemented reasonable administrative, technical, and physical measures 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 to employees and authorized service providers who require access to fulfill their job requirements.

We retain personal information for a length of time commensurate with the purposes of the processing, which may include legal and compliance purposes, in compliance with applicable privacy laws. Personal information may also be stored, but no longer actively processed, for additional periods of time in the form of data backups and archives.

RIGHTS RELATING TO PERSONAL INFORMATION

Under applicable privacy laws, you may have the right to access, update, correct, and delete your personal information in our custody and control, object to and/or restrict processing of your personal information, and obtain a copy of your personal information in a portable format, subject to certain exceptions prescribed by law. You may exercise these rights by emailing or writing to us at the contact information set out below. Prior to authorizing a request, we may request certain information from you for the purposes of verifying your identity.

These rights may be limited, for example, if the request is manifestly unfounded or excessive, if fulfilling the request would adversely affect the rights or freedoms of others, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

Where we rely on your consent, you may have the right to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above.

If you have unresolved concerns, you have the right to complain to the relevant data protection authority of your applicable jurisdiction.

CALIFORNIA PRIVACY RIGHTS

California residents, please review the California Privacy Notice for information about certain legal rights.

COOKIES POLICY

Cookies: Our Website may use a technology called “cookies” or similar types of technologies to improve your experience and provide analytics on website interactions. A cookie is a tiny element of data that our Website can send to your browser, which is then stored on your device so that our systems can recognize you when using our Website.

Our Website may use the following types of cookies:

  • Essential Cookies: Essential cookies are always active and necessary for our Website to function.

  • Functional Cookies: Functional cookies allow us to personalize our Website in accordance with your preferences and interests and support enhanced functionality.

  • Analytics Cookies: Analytics cookies help us understand our website activity and to improve our Website, including through the use of Google Analytics. For more information about how Google Analytics may use your personal information, please see  www.google.com/policies/privacy/partners/.

Depending on your location, you may be able to manage your preferences in relation to Functional and Analytics cookies using our cookie preferences center, which is accessible here: Cookie Preferences. Please note that if you decide not to accept certain cookies from our Website, you may not be able to take advantage of all of the features of our Website.

Do Not Track Signals:  Our Website does not recognize "do not track" signals or similar mechanisms of most web browsers.

THIRD PARTY WEBSITES

Our Website may contain content and links to third party websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our Website and go to another site. During this process, another entity may collect personal information from you, and that collection is subject to the third party’s privacy policy/notice, so please refer to those third-party privacy policies/notices to understand how those parties may collect and/or process your personal information.

SOCIAL MEDIA

We may offer you the opportunity to engage with our content on or through third-party social media websites, plug-ins, and applications, such as Instagram, Twitter, and YouTube. When you engage with our content on or through third-party social media websites, plug-ins, or applications, certain information associated with your social media profile (e.g., name, username, email address, profile picture, and birthdate) may be made available to us.

USE BY MINORS PROHIBITED

The Website is not designed or intended for use by persons under the age of 18, and we do not knowingly collect personal information from minors. If you are under the age of 18, do not use our 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.

CONTACT US

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 privacy@drw.com or by mail at the following addresses:

540 West Madison Street

Suite 2500

Chicago, IL 60661

Or

The Leadenhall Building

122 Leadenhall Street

36th Floor

London, England, EC3V 4AB