Privacy Policy

This privacy policy explains how Remi & Co NY Family Office Limited collects and uses your personal information through your use of this website, including data you provide when you register with us, apply for a service, sign up to a newsletter, or otherwise engage with us.

This website is not intended for children, and we do not knowingly collect personal information from children under the age of 13 (see Section 9 for more on children’s privacy under the Children’s Online Privacy Protection Act (COPPA)).

Who is responsible for your personal information

Remi & Co NY Family Office Limited (“Remi Family Office”, “we”, “us” or “our”) is the organization responsible for your personal information. We are incorporated in the State of New York, with our registered office at 17 State St, Suite 4000, New York, NY 10004, United States.

Which privacy law applies

Unlike Canada or the EU/UK, the United States does not have one comprehensive federal privacy statute. Instead, obligations come from a mix of federal sectoral laws, state law and general consumer-protection law:

• Gramm-Leach-Bliley Act (GLBA) and its implementing rules (the FTC Safeguards Rule, or SEC Regulation S-P/S-P if Remi Family Office is SEC-registered) impose privacy-notice and data-security obligations on “financial institutions.” Whether this applies depends on Remi Family Office’s regulatory status.
• Children’s Online Privacy Protection Act (COPPA) applies if we knowingly collect personal information from children under 13.
• The New York SHIELD Act (NY General Business Law, Article 39-F) requires reasonable administrative, technical and physical safeguards for the private information of New York residents, and imposes breach-notification obligations.
• Section 5 of the FTC Act prohibits unfair or deceptive practices, including inaccurate privacy representations.
• New York does not currently have a comprehensive consumer privacy statute of the kind now in force in states such as California, Colorado, Virginia and Connecticut, so New York residents do not, as a matter of state law, currently have general statutory rights of access, correction, deletion or opt-out of the kind available under, for example, the California Consumer Privacy Act (CCPA).

Where this policy refers to “privacy law,” it means whichever of the above applies to the activity in question.

Privacy Officer

We have designated a Privacy Officer who is responsible for this policy and for handling requests concerning your personal information (see Section 10).

Personal information means information about an identifiable individual. We may collect, use, store and share the following categories:

• Identity Data — first name, last name, any previous names, username, marital status, title, date of birth and gender.
• Identification / Due Diligence Data — government-issued identification details, date and place of birth, and other information we collect for identity verification, due diligence and fraud-prevention purposes.
• Contact Data — billing address, delivery address, email address and telephone numbers.
• Financial Data — bank account and payment card details.
• Transaction Data — details of payments to and from you and of products and services you have purchased from us.
• Technical Data — IP address, login data, browser type and version, time zone, location, device ID and other technology on the devices you use to access this website.
• Profile Data — your username and password, purchases or orders, interests, preferences, feedback and survey responses.
• Usage Data — information about how you interact with and use our website, products and services.
• Marketing and Communications Data — your preferences for receiving marketing and your communication preferences.

We also collect, use and share aggregated data (such as statistical or demographic data) which does not directly or indirectly identify you.

Your interactions with us

You may give us personal information by filling in online forms or corresponding with us by post, phone, email or otherwise, including when you apply for our products or services, create an account, subscribe to our service or publications, request marketing, or give us feedback or contact us.

Automated technologies or interactions

As you interact with our website we automatically collect Technical Data using cookies, server logs and similar technologies. See our Cookie Policy for details.

Third parties or publicly available sources

• Technical Data from analytics providers, advertising networks and search information providers, based inside or outside United States.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services, based inside or outside United States.
• Identity and Contact Data from US public and corporate registries (for example, the New York Department of State) or a credit bureau such as Equifax, Experian or TransUnion.

Purposes and ground for use

US law does not generally require us to state a formal “legal basis” for each use of personal information in the way the GDPR does. In the interests of transparency and consistency with our group’s wider privacy practices, we nonetheless set out below the main purposes for which we use your data and the basis on which we do so.

Direct marketing, CAN-SPAM and the TCPA

Where we send you commercial electronic messages (email, SMS or similar) we comply with the CAN-SPAM Act and, for calls or texts, the Telephone Consumer Protection Act (TCPA), as well as applicable privacy law. Every commercial email we send will accurately identify us and include a functioning opt-out/unsubscribe mechanism, which we will honor within the time required by law. Calls or texts for marketing purposes will only be made with any consent required by the TCPA and in accordance with the National Do Not Call Registry, where applicable.

You can withdraw your consent to marketing at any time by using the unsubscribe link in any marketing message, adjusting your preferences in your account, or by contacting us at info@remi.family

If you opt out of marketing you will still receive service-related communications essential to administering your account or agreement with us.

Third-party marketing

We will obtain your express consent before sharing your personal information with any third party for that third party’s own direct marketing purposes.

Cookies

For more information about the cookies we use and how to change your preferences, see our Cookie Policy.

We may share your personal information, where necessary, with:

• Internal third parties, including other members of our corporate group.
• External third parties, such as service providers, payment networks, regulators (including, if applicable, the SEC, FINRA or NYDFS), and professional advisers.
• Third parties in connection with a sale, transfer, merger or reorganisation of our business or assets.
• Law enforcement, regulators or government authorities, where required or permitted by law.

We require third parties to respect the security of your personal information and to treat it in accordance with applicable law, and we do not permit our service providers to use your personal information for their own purposes.

We may transfer personal information to members of our corporate group and service providers located outside the United States, including in the United Kingdom and Canada. These recipients may process personal information to provide and support our services, process transactions, prevent fraud, maintain our systems and records, meet legal and regulatory obligations and administer our group operations.

We remain responsible for personal information under our control. We use written agreements, due diligence and other safeguards appropriate to the sensitivity of the information and the circumstances to require recipients to protect personal information and use it only for authorised purposes.

Personal information processed outside the United States may be subject to the laws of the destination country and may be accessible to its courts, law-enforcement agencies, national-security authorities or other government authorities. For more information about our use of service providers outside the United States, the countries involved, or our related policies and safeguards, please contact our Privacy Officer using the details in Section 10.

We have put in place appropriate physical, technical and organisational security measures to protect your personal information against loss, misuse or unauthorised access, alteration or disclosure, consistent with the reasonable-safeguards requirements of the New York SHIELD Act and, if applicable, the FTC Safeguards Rule or NYDFS Cybersecurity Regulation (23 NYCRR 500). We limit access to personal information to those employees, agents, contractors and other third parties who have a business need to know, and they are subject to a duty of confidentiality.

If a security breach occurs affecting private information of New York residents, we will notify affected individuals and, where required, the New York Attorney General, the NYS Department of State’s Division of Consumer Protection and the NYS Office of Information Technology Services, in accordance with the SHIELD Act’s breach-notification requirements (NY General Business Law §§ 899-aa, 899-bb). We keep a record of security incidents involving personal information under our control for a reasonable period.

We retain personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, tax or accounting requirements, or where we reasonably believe there is a prospect of litigation.

Where applicable, we retain records required under the Bank Secrecy Act, GLBA, SEC/FINRA recordkeeping rules (for example, SEC Rule 204-2, if applicable) or other applicable financial-services law for the periods those laws prescribe.

Tax records and supporting documents are generally retained for the periods required by the Internal Revenue Code and applicable New York State tax law. We may retain information for a longer period where required or permitted by law, where directed by a competent authority, or where reasonably necessary to establish, exercise or defend a legal claim. When personal information is no longer required, we securely destroy, delete or anonymise it in accordance with our retention procedures.

Where appropriate we anonymise personal information so it can no longer be associated with you, in which case we may use it indefinitely without further notice.

Under current New York and federal law, individuals do not have a general statutory right to access, correct or delete personal information held by a business of this kind, in contrast to the position under Canada’s PIPEDA or the EU/UK GDPR. Certain narrower rights may apply in specific circumstances — for example, under the Fair Credit Reporting Act (FCRA) if a consumer report is used to make a decision about you, or under GLBA if you are a “consumer” of a GLBA-regulated financial institution.

As a matter of good practice, and for consistency with our group’s wider privacy standards, we will nonetheless consider reasonable requests to access, correct, or stop using your personal information; please contact our Privacy Officer using the details in Section 10.

If you are a resident of a state with its own comprehensive privacy law (for example, California, Colorado, Connecticut or Virginia), you may have additional statutory rights under that state’s law, and we will honor validated requests made under that law.

No fee usually required

You will not generally have to pay to exercise these rights. In limited circumstances permitted by law we may charge a minimal fee, in which case we will give you notice of the estimated cost in advance so you can decide whether to proceed.

Time limit to respond

We will respond to your request as soon as reasonably possible, and in any event within a reasonable time (and, for any request made under a state law that prescribes a specific response period, within that period).

If you have questions about this policy, or wish to exercise your rights, please contact our Privacy Officer at legal@remi.family

Remi & Co NY Family Office Limited

17 State St, Suite 4000, New York, NY 10004, United States

If you have a concern about our handling of your personal information, please contact our Privacy Officer first so that we have an opportunity to address it.

If you are not satisfied with our response, you may contact:

• The Federal Trade Commission: reportfraud.ftc.gov
• The New York Attorney General’s Office: ag.ny.gov
• If applicable, the SEC, FINRA, or NYDFS, depending on our regulatory status

The appropriate regulator will depend on applicable law and the circumstances of the matter.

Our complaints process: legal@remi.family

We keep this policy under regular review. It is important that the personal information we hold about you is accurate and current. Please tell us if your details change during your relationship with us.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control third-party websites and are not responsible for their privacy practices. We encourage you to read the privacy policy of every website you visit.

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