We capture and use information provided from you when:
1.1.1 You use our services or products
1.1.2 You download any material from us that requires a sign in
1.1.3 You download anything from us that requires a subscription
1.1.4 You register with us (irrespective of whether you use our sevices / products)
1.4 Your data controller will be CTEXMarkets which collects your data. Information collected in relation to you will be treated in accordance with local law (GDPR) and will only be made available to other parties if we are required to do so legally.
1.6 Whilst your data controller may be a specific CTEXMarkets Group entity, your details may be held in our contact database which can be accessed and used by other entities in the CTEXMarkets Group, which may be located outside the EEA. For more information on data sharing and transfers of data outside of the EEA, please see section 5 below.
1.7 This policy comes into effect on the 23rd of June 2018
2.1.1 your name;
2.1.2 email address;
2.1.3 other personal contact details (including telephone number and postal address);
2.1.4 job title;
2.1.6 corporate contact details (including business “direct dial” or office address);
2.1.7 date of birth
2.1.8 financial information (where necessary to conclude services contracts with you);
2.1.9 your photograph (for instance, where you attend a CTEXMarkets Group event);
2.1.10 career history, professional background and other CV related information (for example, where you provide this to us in connection with an application to be a qualified advisor or register with us a regulated professional);
2.1.11 your driving license, passport and/or other residency related documents (required to confirm your identity where you visit our premises).
2.2 Your use of the Website and related online services involves the automated collection of certain types of information, some of which may be considered Personal Information under applicable laws or in specific circumstances. This information includes:
2.2.1 IP address;
2.2.2 browser type
2.2.3 operating system
2.3 In addition, the Website uses a range of cookies to improve and personalise your experience. More information about these can be found in the Cookies Policy.
2.4 We may in limited circumstances collect certain types of sensitive Personal Information which are protected more strictly by law. These include:
2.4.1 disability information (where you choose to share this with us in relation to accessing to our services or our physical premises)
2.4.2 religious affiliation (for example, where this relates to your dietary requirements for a CTEXMarkets Group hosted event).
2.5 We will only collect information that is necessary for us to provide you with the product or service that you have requested. The type of information that we may collect will depend upon the nature of that service or product.
3.1 It will often be apparent from the context how we intend to use that Personal Information.
3.2 The following is an overview of the CTEXMarkets Group’s purposes for processing Personal Information. Please remember that additional information may be provided to you in a separate notice, or in our terms and conditions. In addition to 1.5, in the event of any conflict between any separate notice and our terms and conditions, our terms and conditions shall take precedence.
3.3 All processing of Personal Information which we undertake is justified by a “condition” for processing. In addition, processing of sensitive Personal Information is always justified by a secondary condition. In the majority of cases, processing will be justified on the basis that:
3.3.1 you have consented to the processing;
3.3.2 the processing is necessary to perform a contract or to take steps to enter into a contract
3.3.3 the processing is necessary for us to comply with a relevant legal obligation
3.3.4 the processing is in our legitimate commercial interests, subject to your interests and fundamental rights.
3.4 The purposes for which we process your Personal Information are to:
3.4.1 provide you with specific services in accordance with a contract you are entering, or have entered into with us;
3.4.2 register you for client services, and to create user accounts
3.4.3 on-board you as a client and to carry out background and screening checks
3.4.4 compile and maintain files on prospective and current directors and qualified advisors, and to carry out background and screening checks on the same, in order to comply with regulatory requirements;
3.4.5 carry out regulatory reporting (for instance, under the Markets in Financial Instruments Directive, and from 2018, the Markets in Financial Instruments Regulation);
3.4.6 provide you with newsletters or alerts where you have signed-up for these on the Website;
3.4.7 conduct market research surveys, where you choose to participate in these;
3.4.8 run competitions;
3.4.9 analyse usage of the Website (see more information in relation to our use of analytics tools below);
3.4.10 arrange events hosted at our premises, where you are either an organiser or an attendee
3.4.11 control access to our premises. Your personal data may be processed either electronically or in hard copy form, both inside and outside the EU and the EEA, in accordance with paragraph 6.
3.5 We may send you direct marketing communications. Where these are electronic communications (email or telephone) we will have obtained your prior consent. In limited circumstances, where we have obtained your explicit prior consent, we may send you marketing communications in relation to carefully selected and relevant third party partners, whose products and services may be of interest to you. You may opt out of certain kinds of marketing, or all forms of marketing, by emailing us. Alternatively, you can click on the “opt-out” link provided in all our marketing emails or follow the instructions in the My Account section of the Website.
4.1 We use analytics tools on the Website to provide the service you request, identify service issues to us, improve our services, provide content tailored to your personal preferences, and to monitor the Website’s traffic and usage.
4.2 When we send you marketing emails, we may use email tracking technology, such as dynamic links and image files, to monitor engagement and to understand the relevance and effectiveness of our communications to you.
4.3 When you fill in forms or download files from the Website, we may use technologies to distinguish known from unknown Website visitors, and to monitor customer engagement with our services.
4.4 We may use IP lookup technology to determine your general location so that we can customise the Website for you. We may also use IP lookup to determine how our known clients engage with different parts of the Website.
4.5 All of these tools may be provided by third-party service providers and may include the collection and tracking of certain data and information regarding the characteristics and activities of visitors to the Website. We may disclose data, including Personal Information, to certain such third-party services providers in order to obtain such services.
4.6 One of our providers is Google Analytics and more information about the ways in which they collect and process your Personal Information can be found here: https://www.google.com/policies/privacy/partners.
5.1 We may share your personal information within the CTEXMarkets Group in order to provide you with our services. Access to your Personal Information is limited to those employees, agents and contractors of the CTEXMarkets Group who need access to it in order to provide you with our services; to communicate with you (including, with your consent, to send you marketing communications); and to carry out legal or regulatory obligations.
5.2 We may also employ the services of third party service providers to help us in certain areas, such as website hosting, physical security, marketing and market research. Where third party service providers receive your information we will remain responsible for the use of your Personal Information. We take appropriate steps to ensure that such third parties treat your Personal Information with the same consideration that we do.
5.3 We may from time to time be required to disclose your Personal Information to law enforcement bodies, regulators, agencies or third parties under a legal requirement or court order. We will act responsibly and take account of your interests when responding to any such requests.
6.1 Cookies are small text files that are placed on your computer or mobile device by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide web services and functionalities for users. For example, they enable you to improve your experience on the Website and enable the Website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the Website or browse from one page to another.
6.2 You do not need to have cookies turned on to visit most of the Website. However, having cookies switched on should allow for a smoother and more tailored browsing experience, and is required for certain parts of the Website’s functionality. In the majority of cases, a cookie does not provide us with any personal information.
7.1 We apply a general rule of keeping your Personal Information for as long as required to fulfil the purposes for which it was collected. However, in some circumstances we may retain Personal Information for longer periods of time, for instance where we are required to do so in accordance with legal, tax or accounting obligations.
7.2 In specific circumstances we may also retain your Personal Information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges.
7.3 We maintain a retention procedure which we apply to records in our care. In all cases, where your information is no longer required we will ensure it is disposed of in a secure manner and, where required by applicable law, we will notify you when such information has been disposed of.
8.1 We will hold your Personal Information securely whilst it is under our control, including where it is processed by third party service providers on our behalf. We train our employees in respect of their obligations under data protection laws, and we ensure that only relevant CTEXMarkets Group employees, contractors and agents have access to your personal information.
8.2 We take the security of our physical premises, our servers and the Website seriously and we will take all appropriate technical measures using recognized security procedures and tools in accordance with good industry practice to protect your personal information across all of these platforms.
8.3 Whilst we use all reasonable endeavours to protect your security in the manner described above, we consider that it is only appropriate to advise you that data transmission over the Internet and the World Wide Web cannot always be guaranteed as 100% secure, and therefore that you use the Website at your own risk.
10.1 Subject to applicable law, you may have some or all of the following rights in respect of your personal information:
10.1.1 to obtain a copy of your personal information together with information about how and on what basis that Personal Information is processed;
10.1.2 to rectify inaccurate Personal Information (including the right to have incomplete Personal Information completed);
10.1.3 to erase your Personal Information (in limited circumstances, where it is no longer necessary in relation to the purposes for which it was collected or processed and is not required for regulatory reasons);
10.1.4 to restrict processing of your personal information where:
10.1.4.1 the accuracy of the Personal Information is contested;
10.1.4.2 the processing is unlawful but you object to the erasure of the Personal Information;
10.1.4.3 we no longer require the Personal Information but it is still required for the establishment, exercise or defence of a legal claim
10.1.5 to challenge processing which we have justified on the basis of a legitimate interest (as opposed to your consent, or to perform a contract with you);
10.1.6 to prevent us from sending you direct marketing;
10.1.7 to withdraw your consent to our processing of your personal information (where that processing is based on your consent);
10.1.8 to object to decisions which are based solely on automated processing or profiling.
10.1.9 In addition to the above, you have the right to lodge a complaint with the supervisory authority. This will vary from country to country although all European countries (and Switzerland) have embraced GDPR.
10.1.10 If you wish to investigate the exercising of any of these rights, please contact us using the details set out below.
13.1 In relation to this Website, your data controller will be CTEXMarkets. However, if your data controller is another member of the CTEXMarkets Group, we will make that information clear to you at the time your Personal Information is collected.
13.2 In all cases, if you have any complaints or queries relating to the processing of your Personal Information by any member of CTEXMarkets, or to exercise any rights in respect of your Personal Information, you should contact us in one of the following ways: By email: DPO@CTEXMarkets.com
13.3 In relation to the Website, you can update, correct or delete your Personal Information by referring to the “My Account” section of the Website. You can also use this area of the Website to prevent us from sending you direct marketing communications.