Zoom AI Privacy Notice

What information do we collect about you?

Regarding the use of Zoom and Zoom’s AI Companion during client review calls, we collect the following types of information:

• Audio and video data: Recordings of your voice and video during the call.
• Transcription and translation: Live Transcription: Converts spoken words into text in real-time, making it easier to follow along and review later.
• Screen sharing data: Content shared via screen sharing.
• Real-time summaries: Provides a summary of the meeting as it progresses, helping participants stay on track without taking extensive notes.
• Post-meeting summaries: Generates a detailed summary after the meeting, including key points, decisions, and action items.
• Information about other people: If you provide information to us about any person other than yourself, such as your employees, relatives, next of kin, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.
  This list is not exhaustive.

• Special category personal data: Under UK GDPR, Special Category Data is identified as data likely to be more sensitive and therefore warrants additional protections.
  Biometric data is personal data, as it relates to an identified or identifiable individual. When this data is processed for the purposes of uniquely identifying a natural person, this becomes known as Special Category Data.
  For further information please see Special Category Data.

On what basis do we use your personal data?

The following describes the ways in which we use your personal data for the purposes of using Zoom’s AI Companion.

Where Required by Law

We may also process your personal data if required by law, including registering your details with relevant regulatory bodies, governmental or quasi-governmental bodies; responding to requests by regulatory bodies, government or law enforcement authorities, or for the prevention of crime or fraud.

We are required by regulations to record calls. This ensures that there is a record of communications, which can be reviewed if necessary for compliance purposes.

This list is not exhaustive.

Legitimate Interests

Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests are:

Improving the quality of experience when you interact with our products and/or services.

In relation to the provision of the contracted products and services

During meetings, Zoom’s AI Companion will transcribe the conversation. This transcription helps the meeting host create an accurately documented summary.

AI Companion identifies action items of the meeting.

If you wish to withdraw/deny the use of Zoom’s AI Companion, please contact your Wealth Manager.

This list is not exhaustive.

Consent

Data processed for this specific purpose allows the right to withdraw/deny the use of Zoom’s AI Companion for the purposes in which it is intended to be used through Client Review Calls. A process is in place to ensure alternative methods for undertaking this process.

Special Category Data is processed under a condition of processing of “Explicit Consent”. For further information please see Conditions for Processing.

Who do we share your information with?

The account owner can watch this recording when stored in Zoom’s cloud. Participants granted permission can record and share recordings.

The sharing of your personal data with other members of the Raymond James group is governed by an Intragroup Agreement.

Zoom has a clear policy that it does not use any of the meeting content (audio, video, chat, screen sharing, attachments, poll results, whiteboard, reactions) to train its AI models or those of third parties.

Please see Zoom’s Privacy Statement for further information.

We will not lend or sell your information to third parties.

Where a third party recipient is located outside the UK, we will ensure that the transfer of personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the Information Commissioner’s Office/European Commission (as appropriate) where the data protection authority does not believe that the third country has adequate data protection laws.

We will share personal data with law enforcement or other authorities if required by applicable law.

How long do we keep this information?

Where there is a contract between us, we will retain your personal data captured within the voice/video recordings for a period of 5 years in line with the Company’s Retention Policy.

Zoom will retain the data pertaining to the video/voice calls for a period of 90 days and deleted thereafter.

Transcripts and verified summaries are subject to archiving rules, 15 years after account closure, to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities.

Where do we store personal data and how is it protected?

We take reasonable steps to protect your personal data from loss or destruction.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Data collected and processed through Zoom’s AI Companion is stored in the United States. Zoom complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF and our agreement with them also includes standard data protection clauses adopted or approved by the Information Commissioner’s Office/European Commission.

The storage of your personal data in the United States by members of the Raymond James group is governed by an Intragroup Agreement. Access is restricted to person(s) necessary to perform their tasks within this process.

What are your data protection rights?

You have certain rights in respect of the data we hold relating to you. Further details of these rights can also be found on the Information Commissioner's website.

• The right to access - you are entitled to a copy of the information we hold about you in a portable format or otherwise, this is known as a Subject Access Request.
• The right to request rectification - you can request we correct any information you believe is inaccurate or incomplete.
• The right to erasure – you can ask us to delete your data under certain circumstances but we may be legally entitled to retain it so will not be able to erase or modify the data.
• The right to object and the right to restrict processing – you can object or request we restrict the processing of the information we hold about you, again under certain circumstances but we may be legally entitled to continue processing and/or may refuse your request.
• The right to data portability – you can request we transfer the data we have collected on you to another organisation or directly to you in a reasonable format specified by you.

• In order to exercise these rights or if you have any concerns about our use of your personal information, please contact the Data Protection Officer using the information at the end of this notice. You can also contact the ICO in its capacity as our supervisory body.

We will endeavour to keep your information accurate, however, if at any time after giving us this information it becomes out of date, then we ask you to notify us directly and we shall remove or amend the information within a reasonable time frame and in accordance with legislative requirements.