Privacy Policy

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

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• Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender
• Contact Data includes billing address, email address and telephone numbers
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website
• Profile Data includes your username and password, your interests, preferences, feedback and survey responses
• Usage Data includes information about how you use our Website, products and services
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences

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We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. We do not collect any Financial Data (this includes bank account and payment card details) or any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

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• Direct interactions. You may give us your data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • Apply for our products or services
  • Create an account on our website
  • Subscribe to our service or publications
  • Request marketing to be sent to you
  • Give us feedback or contact us

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• Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

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• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from analytics providers
  • Contact and Transaction Data from providers of technical, payment and delivery services
  • Identity and Contact Data from data brokers or aggregators
  • Identity and Contact Data from publicly available sources

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where we need to comply with a legal obligation

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Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Our Website uses certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage them.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

It is likely that the Website will contain links to third party websites and services. Please remember that when you use a link to go from our Website to another website or you request a service from a third party, this privacy policy no longer applies. Your browsing and interaction on any other website, or your dealings with any other third-party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices. This privacy policy applies solely to personal information collected by us through our Website and functionality and does not apply to these third party websites and third party service providers.

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy. It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data. As we are based in the UK we will also transfer your personal data from the EEA to the UK. Other than as set out above, we do not transfer your personal information outside of the EEA or UK. If you would like further information about data transferred outside the UK/EEA, please contact us via legal@tradeteq.com.

We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• Unauthorised access
• Improper use or disclosure
• Unauthorised modification
• Unlawful destruction or accidental loss

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All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the Site.

You have the following rights in relation to the personal information we hold about you:

• Your right of access. If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Your right to rectification. If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
• Your right to erasure. You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
• Your right to restrict processing. You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
• Your right to data portability. With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.Your right to object. You can ask us to stop processing your personal information, and we will do so, if we’re:
  • Relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing
  • Processing your personal information for direct marketing
  • Processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest

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• Your rights in relation to automated decision-making and profiling. You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
• Your right to withdraw consent. If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
• Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

We may make changes to this privacy policy from time to time. To ensure that you are always aware of how we use your personal information, we will update this privacy policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by e-mail of any significant changes. However, we encourage you to review this privacy policy periodically to be informed of how we use your personal information.

If you have any questions about this privacy policy or want to exercise your rights, please contact us by:Sending an e-mail to privacy@tradeteq.com; or to address 10 Devonshire Square, London, EC2M 4YP

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Last update: September 2023