Privacy Notice
Creek Path Advisors MB, acting for and on behalf of creekpathadvisors.com as data controller and/or data processor (altogether “CPA”, “we”, “us”, or “our”), collects data to operate effectively and provide you (any data subject in relation with CPA) with the best services. CPA is highly committed to safeguarding your privacy. We have developed this privacy notice to explain how we may collect, use, share, protect, and retain your information, as well as your rights regarding it.
1. What Information We Collect
To provide our services, CPA needs to collect and process information about you. The data we collect depends on the context of your interactions with CPA and the choices you make, including the services provided to you.
You may choose what data you allow us to collect. When you are asked to provide personal data, you may decline. However, if you choose not to provide data necessary for a service, we may be unable to provide that service.
2. Categories of Data Processed
The data we collect and process may include, but is not limited to:
Identification data: such as first and last name, email address, postal address, phone number, date and place of birth, gender, country, and preferred language.
Electronic identification data: Cookies may be used to collect data on how you use our website and view marketing emails, such as pages visited, time spent on pages, and items clicked.
Business contact information: such as job function, job title, department, organisation name, size, location, and whether you are acting on behalf of a client.
Financial information: such as financial account information, if needed to take payment, fulfill contractual obligations, or for related purposes.
Contractual information: any information provided by the data subject allowing CPA to perform its contractual duties.
Further to the categories of data mentioned above, CPA guarantees that, except to the limited extent that may be necessary in the context of employment and in the context of performing a contract with a client, we neither request nor collect special categories of data (i.e., personal information specifying criminal offences/convictions, medical or health conditions, biometric or genetic data, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual).
Please also refer to the Job Applications section (point 15).
3. How We Collect Data
This Privacy Notice applies to personal data collected by CPA from you and other third parties that identifies you as an individual. CPA may collect your personal data in various ways.
We may collect personal data when you consent to the use of different categories of cookies on our website. Cookies are small text files stored on your computer or device that help improve user experience.
Cookies can be classified by life span:
Session cookies: deleted once the browser is closed.
Persistent cookies: remain stored on the user’s terminal device for a certain duration. They are not automatically erased. Your browser sends these cookies back to the website every time you visit it again, so it can remember your preferences and tailor what you see on the screen.
And by domain:
First-party cookies: set by the website you visit.
Third-party cookies: set by external services integrated into the website.
4. Ways of Collecting Data
Via our website: By visiting our website and accepting certain cookies, some anonymized data may be transmitted to us, depending on the categories of cookies accepted.
When you do business with CPA: We may collect and process your data during business interactions.
From other sources: We may obtain personal or non-personal information from CPA subsidiaries, affiliates, business partners, or other third parties legally authorized to share such data. This may include, but not limited to, updated business address information, identification data, financial information, and contractual information.
Job Applications: See point 15.
5. Purposes for Collection, Use, and Processing of Client Data
For a processing of personal data to be compliant with the General Data Protection Regulation (the “GDPR”), a legal basis must be identified prior to its implementation.
We use or may use your personal data for the following purposes (or as otherwise described at the point of collection) in line with the lawful basis under the GDPR:
To provide you with the service you have requested. Processing is necessary for the performance of a contract with the data subject.
To provide you with information, access to resources or other services that you have requested from us on behalf of your organisation. Processing is necessary for the performance of a contract with the data subject.
To send you client service-related communications (marketing). Processing is necessary for the purposes of the legitimate interests pursued by the controller.
To deal with communications that you send to CPA and responding to your queries, requests and complaints. Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Processing is necessary for compliance with a legal obligation.
To fulfill our legal obligations namely in respect to AML/KYC/ MAR. Processing is necessary for compliance with a legal obligation.
To carry out the recruitment process. Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
To promote our events and conferences via pictures and videos disclosed on our social medias. Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.
To manage the infrastructure and business operations of CPA and to comply with internal policies and procedures. Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.
To comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities. Processing is necessary for compliance with a legal obligation.
We may contact you by mail, telephone, video conference, email or other electronic messaging service to notify you about special events, new features or other information that may be of interest to you in accordance with your interaction with CPA. Where required by applicable law, your prior consent will be obtained before sending you direct marketing and you may object or opt out of receiving marketing messages from CPA.
CPA does not in any way sell, lease or rent your information to third parties.
6. Sharing Personal Data
CPA shares personal data only as necessary to provide services you have requested or authorized. We may share your data for:
Recruitment
AML/KYC (third parties such as notaries, domiciliation agents, and banks)
7. Disclosure of Personal Data
We may disclose or transfer personal data to:
Service providers: we may disclose/transfer your data with third parties that we refer as service providers solely to the extent necessary to enable such service providers to provide services to CPA and to assist us in providing services to you. CPA’s policy is to maintain contracts with all third parties with whom we disclose/transfer personal information that restrict their access, use and disclosure of personal data. Service providers must, in fact, abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose.
Third parties: we may disclose/transfer your data with third parties such as administration and public authorities, banking institutions, notaries, domiciliation agents and to professional advisors and auditors of CPA.
Affiliates/branches/subsidiaries: we may disclose/transfer your data, as provided in our General Terms & Conditions, with other companies under common ownership or control with CPA who will process your information in a manner consistent with this Privacy Policy.
Safety, security and compliance with law: we will access, transfer, disclose and preserve personal data to comply with applicable law or respond to subpoenas, court orders or other valid legal process, for reasons relating to national security, to defend against legal claims, to protect the rights and safety of CPA, CPA’s clients, employees or others. This may involve the sharing of your data with law enforcement, government agencies, courts and other organizations.
Consent: we may share your data in other ways and for new purposes if you have asked us to do so and have consented to such sharing.
The recipients may be located inside or outside the European Union. Your personal data will not be transferred to any country located outside the European Union that does not provide an equivalent level of protection, unless:
You gave us prior authorization to do so;
If specific measures, such as Standard Contractual Clauses (SCCs), have been signed, or if the concerned companies have adopted binding corporate rules, ensuring that the of the applicable data protection law have been fulfilled.
Where personal data is transferred/disclosed to CPA’s affiliates/branches/subsidiaries, such transfer is based on specific measures, specifically the model clauses issued by the European Commission with regards to transfer of personal data outside the European Union. Should you wish to consult the latter, please let us know by contacting us to the contact information provided in the section “HOW TO CONTACT US” of this policy.
8. Access to Personal Data
CPA seeks to ensure that you are able to exercise your rights at any time. CPA will address any request within the limits of its technical and organizational means.
These include:
Right to access your personal information: should you want to review the data we hold, collect and process about you, please let us know by contacting us at the contact information provided in the section “HOW TO CONTACT US” of this policy.
Right to rectification: should the data we hold, collect and process about you be inaccurate or incomplete, you have the right to update such data at any time by contacting us at the contact information provided in the section “HOW TO CONTACT US” of this policy.
Right to erasure: if at any time you decide you do not want us to retain any personal data we collected from you, you may request we delete your data by contacting us at the contact information provided in the section “HOW TO CONTACT US” of this policy. We will take reasonable measures to comply with your request in accordance with applicable laws.
Right to restriction of processing: should you wish to exercise this right, please contact us at the contact information provided in the section “HOW TO CONTACT US” of this policy. You should obtain the right to restriction of processing only where in accordance with applicable laws.
Right to object: should you wish to exercise this right, contact us at the contact information provided in section the section “HOW TO CONTACT US” of this policy. We will consider your objection and we will comply with it unless we have a compelling legitimate ground as permitted by applicable law.
Right to data portability: you may have the right to have your personal data transmitted directly from us to another controller only when you have asked us to do so and have consented to such sharing, and when technically feasible. Should you wish to exercise this right, please contact us at the contact information provided in the section “HOW TO CONTACT US” of this policy.
Right to lodge a complaint with the supervisory authority: you have the right to lodge a complaint with the State Data Protection Inspectorate (the “SDPI” - https://vdai.lrv.lt/en/) if you believe that your data is being processed in a way that does not comply with the GDPR.
Please be aware that these rights are not always absolute and there may be some situations in which, technically or legally, CPA may not be able to comply with your request.
9. How We Protect Your Data
CPA acknowledges your trust and is committed to protecting the data you provide to us. CPA pays a particular attention to work from home ethics. We avoid any hard copy to be taken at home and require from our employees that any task requiring the use of hard copies to be done from the office. We maintain appropriate organizational, physical and technical security measures (including with respect to personnel, facilities, hardware and software, storage and networks, access controls, monitoring and logging, vulnerability and breach detection, incident response, encryption of personal data) to protect against unauthorized or accidental access, loss, alteration, disclosure or destruction of personal data.
10. Notification of Personal Data Breach
CPA will only retain your personal data:
For as long as it is necessary for the purpose or purposes for which it was intended;
For the purposes of performing or fulfilling a contractual obligation with you or the organization that you represent and, therefore, legitimate business purposes;
For as long as required or permitted by law.
11. Retention Period of Personal Data
CPA retains personal data:
For as long as it is necessary for the purpose or purposes for which it was intended;
For the purposes of performing or fulfilling a contractual obligation with you or the organization that you represent and, therefore, legitimate business purposes;
For as long as required or permitted by law.
12. What We Expect from You
We expect you to inform us in writing and without undue delay of any changes of the information you provided to us, so that we can keep it up to date.
If you provide us with personal information not relating to you (e.g. information about your respective representatives, staff members and agents, beneficial owners, shareholders, etc. or about any third party), you must first inform them about this and make sure they acknowledge that we can use such information as set out in this privacy policy. In particular, you must provide them with the information relating to their rights as data subjects. We assume that these third parties are informed of the processing of any personal information relating to them that we may carry out and of the disclosure of the same to third parties and countries as described herein and that, as far as necessary, you obtained these data subjects‘ prior written consent.
13. Changes to This Privacy Policy
We reserve the right to amend this Privacy Policy from time to time to reflect changes in the law, our data collection and used practices, and to ensure it is accurate, complete and up to date*. You are advised to check this Privacy Policy from time to time.
*Last update: 2025/12/09
14. How to Contact Us
For questions or concerns regarding your information or this Privacy Policy, contact:
gdpr@creekpathadvisors.com
15. Job Applications
Personal data that we collect when you apply online for employment: you may submit personal data through the use of our website to be considered for employment at CPA. Such information includes, amongst others, your name, your address, your phone number, your email address, experience, education, job skills and other information contained on your curriculum vitae (CV) and/or your cover letter. CPA uses such data solely for consideration of your candidacy for employment, to communicate with you and to generate related correspondence, including offer letters and employment agreements. Such data may also be used, subject to applicable local laws, to conduct necessary background checks for compliance and other employment related purposes (including the assessment of your profile in view of the conclusion of a potential employment contract, to the extent permitted by applicable laws and regulations). Finally, CPA only retains such data for as long as is necessary to address your employment application and any questions that may arise regarding your application’s processing.
