Greyline Privacy Notice for Subscribers, Website Users and Marketing Contacts

This Privacy Notice explains what personal data (information) we hold about U.K. and EU contacts who are not clients, including where individuals register to receive Greyline Updates or Regulatory News Updates or request to be contacted via our website, how we collect it, and how we use and may share information about you.

We are required to notify you of this information under the EU General Data Protection Regulation (GDPR). Please ensure that you read this notice and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

Who Collects the Information

Greyline Partners, LLC is the operator of the website and is a ‘data controller’ that gathers and uses information about individuals in certain circumstances.

Greyline Partners, LLC is a Delaware incorporated limited liability company based at 44 Montgomery Street, Suite 1900A, San Francisco, CA 94104, United States.

Greyline Partners, LLC has appointed its affiliate Greyline Solutions Ltd to as its EU Representative with respect to fulfilling its obligations under the EU General Data Protection Regulation and acting as a point of contact. Greyline Solutions Ltd, a private limited company incorporated in England and Wales with its registered address at Tower 42, 25 Old Broad Street, London, United Kingdom, EC2N 1HQ. Greyline Solutions Ltd acting in its capacity as the EU Representative of Greyline Partners, LLC can be contacted at EUrep@greyline.co.

How We Collect Information About You

We collect this information from you directly when you sign up to receive Greyline Updates or Regulatory News Updates or request to be contacted via our website. Information may also be obtained during direct contact with Greyline staff, including via email and through the exchanging of business cards at events, and we may also collect and cross-reference against open source and non-confidential information from the internet.

What Information We Collect About You

We collect your name, contact details and information about your preferences on how and when to be contacted and for what purposes. We may also seek to understand and record other details, such as the name and type of company being represented, where applicable.

How We Will Use Information About You

We collect and use this information to send you only the Greyline Updates or Regulatory News Updates that you have expressed an interest in, and where appropriate to facilitate direct outreach by an appropriate member of Greyline staff. Where individuals have signed up via our website, we will obtain and rely upon their explicit consent to allow us to use this data. Where data has been obtained from other sources, we will rely on legitimate business interests to permit the processing of this information and provide a copy of this privacy policy to the individual at the earliest opportunity.

Where appropriate, we may send you information about our products and services that are likely to be of interest to you. If you have consented to receive marketing updates from us, you may opt out later. You have the right to stop us from contacting you for marketing purposes at any time. If you no longer wish to be contacted for marketing purposes, please contact EUrep@greyline.co.

We will not share your information for marketing purposes with other organisations outside of Greyline.

How We May Share the Information

Our outsourced IT service providers may have access to your information by virtue of our data being hosted on their servers. Any such, third parties will be bound by confidentiality obligations by way of contract. We may also be required to share some personal information if required to do so to comply with applicable law.

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

Where Information May Be Held

Information may be held at our offices and those of our group companies, along with on their email and IT servers, some of which are hosted by third-party service providers.

This may involve transferring information internationally to other countries around the world, with Greyline offices currently being located in the United States and the United Kingdom. In all cases, we have security measures in place to seek to ensure that there is appropriate security for information we hold.

How Long We Keep Your Information

We will continue to process your information until you request to unsubscribe from receiving the Greyline Updates or Regulatory News Updates, you request not to be contacted for marketing purposes, or until we have dealt with your request to be contacted. Residual information may be retained after this time as part of our normal business records, but no further processing will take place.

Your Rights as a U.K. or EU Data Subject

You have the following rights in relation to your personal information:

  1. The right to access your personal information;
  2. The right to rectify your personal information;
  3. The right to request the restriction of the use of your personal information;
  4. The right to request that your personal information is erased;
  5. The right to object to the processing of your personal information; and
  6. The right to request the transfer of your personal data (“data portability”).

Please contact us at EUrep@greyline.co if you would like to correct or request access to information that we hold relating to you, or if you have any questions about this notice. We may charge a fee for responding to such a request, but only a reasonable fee for responding to access requests in cases where the request is manifestly unfounded or excessive, especially if it is repetitive, or the request is for further copies of the same information.

You also have the right to request the information we hold to be erased (the ‘right to be forgotten’) in certain circumstances. Note that erasure may not be immediate and may not be possible in some situations where continuing legal obligations apply.

How We Keep Your Information Secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. This also extends to any subcontractors or IT service providers.

We also have procedures in place to deal with any suspected data security breach. We will notify you and the appropriate regulator of any suspected data security breach where this is required in light of the likelihood and severity of the risk posed to your rights and freedoms.

Other Websites

Our website may contain links to other websites which are outside our control and are not covered by this Privacy Notice. If you access other websites using the links provided, you should read the privacy notices on those websites.

Changes to our Privacy Notice

We will keep this Privacy Notice under regular review. Any changes we make to our GDPR Privacy Notice will be posted on our website at https://greyline.co/GDPR/ or can be requested by email at EUrep@greyline.co.

How to Contact Us

If you have any questions about our use of your personal information or this Privacy Notice, please contact us at EUrep@greyline.co.

How to Complain

Please contact us at EUrep@greyline.co if you have any query or concern regarding how we collect or process personal data, or would like to make a formal complaint.

If we are unable to resolve any complaint to your satisfaction, you should contact the Information Commissioner online at www.ico.org.uk/concerns or by telephone at 0303 123 1113 for further information about your rights and how to make a formal complaint.

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JP Gonzalez

Partner
JP Gonzalez is a Partner at Greyline and heads the company’s technology and sales initiatives globally. He is also a member of gVue’s steering committee. Prior to joining Greyline, JP spent six years designing and evangelizing Compliance Regulatory Technology for broker-dealers, investment advisors and fund managers, where he assisted clients with all aspects of complying with FINRA, SEC and state rules and regulations related to a firm’s code of ethics. His technology background includes five years as a software developer and program manager at Microsoft, with his last two years at Microsoft as the UX/UI usability and accessibility program manager for Internet Explorer. He has a B.S. in Computer Science from Rose-Hulman Institute of Technology.

Nick Thomas

Partner
Nick Thomas is a Partner at Greyline and oversees the London office, which provides compliance support to U.K.-based hedge funds, private equity firms and other alternative asset managers. Prior to joining Greyline, Nick spent 13 years at the Financial Conduct Authority, the U.K. regulator, followed by three years at a well-known international compliance consultancy. During this time, he gained a broad and deep understanding of the U.K. regulatory environment applicable to alternative asset managers – both from the perspective of the regulator and the firms being regulated. His time at the FCA included working as a supervisor on the alternative investments team, with responsibility for supervising some of the largest and most prominent hedge funds in the U.K., and undertaking firm examinations across a broader population of alternative asset managers. Prior to this, he worked extensively on AIFMD implementation from the FCA’s perspective, as well as assessing applications from investment firms seeking to obtain FCA authorization. Nick obtained a BSc in Mathematics from Imperial College London. In addition, he holds the Investment Management Certificate (IMC), the Fundamentals of Alternative Investments Certificate and the Financial Planning Certificate (FPC). He also speaks Japanese.

Tim Goodwin

Partner
Tim Goodwin is a Partner at Greyline and the head of the Fort Worth office. Prior to joining Greyline, Tim spent two years providing ongoing compliance and consulting services to alternative asset managers, including private equity funds, venture capital funds, real estate funds and hedge funds. He worked at TPG Capital for seven years in compliance and internal audit positions. As a director in the risk management and internal audit department, Tim was responsible for documenting and testing TPG’s allocation of fees and expenses, as well as preparing the firm for possible public listing, by leading TPG’s efforts in Sarbanes Oxley testing and compliance. Before joining the internal audit team, he spent five years running TPG’s compliance testing efforts across all of TPG’s businesses, including the private equity funds, credit platform, hedge funds, a 40 Act fund and a registered broker dealer. Prior to joining TPG Capital and moving to Texas, Tim spent more than six years with UBS Wealth Management (New York and New Jersey) in various compliance roles, touching on investment company, investment adviser and broker dealer compliance. He was most recently the chief compliance officer to UBS’s unit investment trusts and a compliance director for advisory products, including the separately managed account, financial advisor discretionary and mutual fund wrap programs. He assisted UBS in its first ever required annual reviews conducted pursuant to the compliance program rule, helped design and implement compliance policies and procedures for UBS’s advisory programs, and routinely assisted in updating required disclosure documents, including the Form ADV.

Jennifer Dickinson

Partner
Jennifer Dickinson is a Partner at Greyline and heads the firm’s Chicago office, as well as its CFTC/NFA practice. Her clients include private fund managers (hedge, private equity, venture capital and real estate), traditional RIAs, CPOs, CTAs and Swap Dealers. Jennifer advises on a range of compliance matters, including code of ethics/insider trading issues, risk management, compliance training, conflicts of interest and regulatory examinations. Prior to joining Greyline, Jennifer was the managing director of Sansome Strategies, a boutique compliance consulting firm specializing in alternative asset managers. Her other consulting experience includes serving as chief compliance officer for three prominent, SEC-registered investment advisers. Jennifer has also worked at noted law firms in the financial services space, including Cole-Frieman & Mallon LLP and Pillsbury Winthrop Shaw Pittman LLP. Jennifer began her career as the legal and compliance administrator at Standard Pacific Capital LLC, a SEC-registered, multi-strategy hedge fund manager based in San Francisco. Jennifer has an undergraduate degree from DePauw University and a law degree from Golden Gate University School of Law, where she was the editor–in–chief of the Law Review.

Sean Wilke

Partner & Head of Strategic Growth
Sean Wilke is a Partner, and the Head of Strategic Growth at Greyline and its affiliate GCM Advisory, which specialize in compliance consulting and outsourced finance, accounting and operations. He has extensive experience advising various types of investment managers, including hedge funds, private equity/credit funds, wealth managers, registered investment companies, institutional allocators and family offices, on a range of regulatory, compliance, operational and management matters. Before joining Greyline, Sean was a director within the governance, risk, investigations and disputes group at Duff & Phelps, where he focused on compliance and regulatory consulting for the alternative investment space. Prior to that, he was the general counsel and chief compliance officer of Bramshill Investments, a $4 billion, multi-strategy investment manager, where he oversaw all legal and compliance affairs. Sean also spent four years as a corporate and securities attorney at a law firm, as well as three years as a compliance associate at Bear Stearns & Co., where he performed surveillance for the investment and merchant banking groups. Sean has a B.A. in Political Science from Rutgers University and a J.D. from New York Law School.

Kathy Malone

Partner & Head of Consulting
Kathy Malone is a Partner at Greyline and co-head of the firm’s New York office. Before joining Greyline, she was an examiner with the U.S. Securities and Exchange Commission’s Office of Compliance Inspections and Examinations in the Boston and New York offices, where she participated in numerous investment adviser and broker-dealer examinations. Prior to her time with the SEC, she was an examiner with FINRA, completing many examinations of broker-dealers and enforcement referrals. Most recently, Kathy worked for a consulting firm where she assisted broker-dealers, investment advisers and investment companies with the registration process, examination support and ongoing compliance needs. She has a B.S. in Finance from Villanova University and a Juris Doctor from Seton Hall Law.

Talia Brandt

Partner & Chief Operating Officer
Talia Brandt is a Partner at Greyline, and a member of gVue’s steering committee. Her team from Vista Compliance, LLC joined Greyline in May 2017. Talia founded Vista Compliance — a compliance consulting firm servicing broker-dealers, registered investment advisors and private fund managers — in April 2008. In her role with Greyline, Talia works closely with firms to ensure compliance with FINRA, state and SEC regulations. She has developed and implemented compliance and financial policies and procedures to ensure solid internal controls are in place for varying financial services firms. In addition to her compliance consulting work, Talia has served internally to firms as chief compliance officer and holds FINRA Series 7, 24, 66 and 79 registrations. Prior to forming Vista Compliance, Talia worked at Goldman Sachs in the investment management division in Salt Lake City. She then moved to the Bay area, where she went to work with smaller startup, boutique financial services firms.

Matt Okolita

Managing Partner

Matt Okolita is Managing Partner of Greyline, and a member of gVue’s steering committee. He has extensive SEC, FINRA and CFTC experience, having worked for and with premier hedge funds, private equity and venture capital firms, CLO and other debt managers, business development companies and mutual fund managers in both legal and compliance roles. Matt’s background includes undertaking a variety of legal and compliance functions, serving as counsel and chief compliance officer for startup managers, as well as international asset managers managing more than $30 billion. Matt has a Bachelor of Arts in Political Science and Economics from Bucknell University and a Juris Doctor from Suffolk University Law School, with distinction in Business Law and Financial Services.