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1.1 This notice (Privacy Notice) applies to personal data that iTradeDigital may collect. Wherever we have said “we”, “our” or “us”, we mean iTradeDigital.
1.2 This Privacy Notice explains what personal data the iTradeDigital collects about you and individuals connected to your business, how we’ll use that data, who we’ll share it with, the circumstances when we’ll share it, and what steps we’ll take to make sure it stays private and secure. It continues to apply even if your relationship with us ends. It should also be read alongside other documentation associated with your membership (such as your application form) as these may include sections relating to the use and disclosure of the data. Where there is any conflict between the terms of this Privacy Notice and any other document in relation to data protection the terms of this Privacy Notice shall prevail.
1.3 An “individual connected to your business” could be any guarantor, a director, officer or employee of a company, partners or members of a partnership, any substantial owner, controlling person, or beneficial owner, trustee, settlor or protector of a trust, account holder of a designated account, recipient of a designated payment, your attorney or representative (e.g. authorized signatories), agent or nominee, or any other persons or entities with whom you have a relationship that is relevant to your relationship with us. Whenever we say “you” this should be read to include “individuals connected to your business”.
1.4 Please ensure that any relevant individuals are made aware of this Privacy Notice and the individual rights and information it sets out, prior to providing their personal data to us or obtaining their personal data from another source. If you, or anyone else on your behalf, has provided or provides personal data on an individual connected to your business to us, you or they must first ensure that you or they have the authority and appropriate legal basis to do so.
2. PERSONAL DATA WE COLLECT
2.1 This Privacy Notice is concerned with personal data we collect about you. Personal data means any data by which you as an individual can be identified directly or indirectly
2.2 Some of the personal data we hold about you will have been supplied by you. Other personal data may come from your financial advisor, solicitors, broker, employer or other intermediary, our service providers or other sources you’ve asked us to obtain information from. We might also get some of it from publicly available sources.
2.3 We will usually collect personal data such as:
(a) identification materials we may need for our compliance obligations (e.g. a copy of your passport or national identity card, national insurance number, utility bills, financial details etc.);
(b) contact details (e.g. address, email address, position in company, landline and mobile numbers);
(c) other data about you which you may have provided us with during the course of our relationship with you (e.g. by filling out forms or during face-to-face contact, telephone, email and the like);
(d) Information about your relationship with us, including your ways of interacting with us;
(e) complaints or disputes you may have had with us or our service providers and details of the underlying transaction (where applicable);
(f) information about you which is a matter of public record or readily obtainable and which we deem relevant in relation to your dealings with the iTradeDigital;
(g) records of correspondence and other communications between you and your representatives and the iTradeDigital, including email, phone calls, letters and the like;
(h) information that we need to support our regulatory obligations (e.g. information about transaction details, detection of any suspicious and unusual activity and information about parties connected to you or these activities);
(i) information from third party providers who assist us to combat fraud, money laundering and other crimes; and
(j) information you asked and authorised us to collect for or about you.
3. HOW WE WILL USE PERSONAL DATA
3.1 We will only use your personal data when the Data Protection Legislation allows us to. Most commonly, we will use your personal data in the following circumstances:
(a) Where we need to comply with a legal or regulatory obligation.
(b) Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
3.2 The purposes for which we use your personal data commonly include:
(a) To carry out due diligence in respect of your membership;
(b) To facilitate your membership;
(c) To enable you to use the transaction documentation that the iTradeDigital provides;
(d) To protect our legal rights and complying with our legal obligations; and
(e) To conduct risk management.
4. WHO WE MIGHT SHARE YOUR PERSONAL DATA WITH
4.1 We may share relevant personal data of yours with other parties where it is lawful to do so, including where: (a) it is necessary to comply with your instructions;
(b) we have a public or legal duty to do so (e.g. to assist with detecting and preventing fraud, tax evasion and financial crime or compliance with a court order);
(c) we are obligated to in connection with regulatory reporting, litigation or asserting or defending legal rights and interests;
(d) iTradeDigital has a legitimate business reason for doing so (e.g. to manage risk, verify identity, enable another business to provide you with services you’ve requested; or
(e) we have asked you if we can share it, and you gave consent.
4.2 Parties we might share your personal data with can include (without limitation):
(a) Other Members and parties relevant to any transaction that you undertake;
(c) Any bank or financing entity relevant to any transaction that you undertake;
(d) Law enforcement, government, courts, dispute resolution bodies, our regulators, auditors and any party appointed or requested by our regulators to carry out investigations or audits of our activities;
(e) Other parties involved in any disputes, including disputed transactions;
(f) Fraud prevention agencies who’ll also use personal data to detect and prevent fraud and other financial crime and to verify your identity;
(g) Anyone who provides instructions to us on your behalf (e.g. under a power of attorney, solicitors, intermediaries, investment managers etc.); and
(h) Anybody else that you instructed us to share your information with.
5. RETENTION OF PERSONAL DATA
5.1 iTradeDigital keeps personal data only for as long as it is necessary for the specific purpose the data was collected for or as long as we are required by applicable laws and regulation.
5.2 We may keep personal data for longer periods where we have a legitimate interest for doing so, for instance to address complaints, assert or defend our rights in litigation or other dispute resolution procedures or to respond to requests from regulators or assist judicial authorities.
5.3 Any information we are not required to hold for any minimum period and for which there is no purpose in us holding it anymore will be deleted, destroyed or returned to you more promptly.
5.4 Where iTradeDigital shares your personal data with third parties, the privacy notices and laws and regulations of the third party will determine how long they will have to retain your data.
6. INDIVIDUALS’ RIGHTS
6.1 As an individual or “data subject”, you have certain rights in relation to your personal data. These rights include: (a) the right to access the personal data we hold about you and to obtain information about how we process it;
(b) the right to object to and withdraw your consent to iTradeDigital’s processing of your information. This right can be exercised at any time. However, the Company may continue to process your personal data if there is another legitimate reason or legal obligation for doing so. Please also note that depending on which kind of processing you object to, the Company may no longer be able to perform its contractual obligations with you;
(c) in some circumstances, you have the right to receive certain personal data you have provided to us in an electronic format and/or request that we transmit it to a third party;
(d) the right to request that we rectify information we hold about you if it is inaccurate or incomplete; (e) in some circumstances, you have the right to request erasure or deletion of personal data we hold. We may however continue to retain it if we are entitled or required by law to do so; and
(f) the right to object to, and to request that we restrict, our processing of your personal data in some circumstances. Please note that despite this general right we may be entitled under law to continue processing the information and/or to refuse that request.
6.2 You also have the right to complain to the data protection regulator.
7. MISCELLANEOUS
8.1 Please ensure that any personal data you give us or ask third parties to provide to us is up to date, accurate and complete in all respects. Please inform us about any changes as soon as reasonably possible.
8.2 We use a range of measures to keep information safe and secure which may include encryption and other forms of security. We require our staff and any third parties who carry out any work on iTradeDigital’s behalf to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information. If you wish to know more about our data protection measures, please contact us (details provided below).
8.3 We reserve the right to make changes to this Privacy Notice, for example, as the result of government regulation, new technologies, or other developments in data protection law or privacy generally.
9. CONTACT US
For any further questions or queries in relation to this Privacy Notice, you can contact us by email: [email protected]
