Internet Privacy and Cookies Policy
At TradingHub Group Limited (TH) we are committed to safeguarding and preserving the privacy of our visitors.
This document (Policy) explains what happens to any personal data that you provide to us, or that we collect from you while you visit our websites.
TH does update this Policy from time to time so please do review this Policy regularly (see Modifications to Policy below). This Policy supplements any other privacy notices we may provide on specific occasions when we are collecting or processing personal data about you and is not intended to override any such notices.
Our websites are not intended for children and we do not knowingly collect data relating to children.
Information That We Collect
In running and maintaining our websites TH may collect and process the following data about you:
- Personal information including name, date of birth, title, marital status and gender and contact data including address, email address and telephone number.
- Information about your use of our websites including details of your visits such as pages viewed and the resources that you access. Such information includes traffic data, location data, IP address, login data, browser type and version, operating system and platform, other information about the technology on the devices you use to access our website, information about your use of our site including details of your visits, the resources that you access and other communication data.
- Information received from third parties such as search information providers or from publicly available sources.
- Information provided voluntarily by you. For example, when you register for information or make a purchase.
- Information that you provide when you communicate with us by any means.
- Where applicable, profile data including username and password.
Use of Your Information
We will only use your personal data in accordance with applicable law. We will most commonly use your personal data where we have your consent to do so, 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 or where we need to comply with a legal or regulatory obligation.
Specific examples of the way in which we plan to use your personal data are as follows:
- To provide our services to you.
- To manage our relationship with you.
- To keep our records updated.
- To provide information to you that you request from us relating to our products or services.
- To provide information to you relating to other products that may be of interest to you.
- To inform you of any changes to our website, services or goods and products.
- To administer and protect our business and our websites.
- To use data analytics to improve our website, products and services, marketing, customer relationships and experiences.
- To ensure network security.
- To prevent fraud and to recover amounts due to us.
- To comply with a legal obligation.
If you have previously purchased goods or services from us TH may provide to you details of similar goods or services, or other goods and services that you may be interested in. Please let us know if you wish to opt out of such communications. Where you opt out of such communications this will not apply to personal data provided to us as a result of a product or service purchase or other transaction.
TH will never give your details to third parties to use your data to enable them to provide you with information regarding goods or services.
Storing Your Personal Data
We only transfer your personal data outside of the European Economic Area when it is necessary to do so in order to either fulfil the terms of a contract or in the legitimate interest of TH.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it considering the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use 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 requirements.
Disclosing Your Information
TH will not disclose your personal information other than in accordance with this Policy and in the circumstances detailed below:
- In the event that TH sells any or all of our business to a buyer.
- Where TH is legally required by law to disclose your personal information.
- To further fraud protection and reduce the risk of fraud.
- To our permitted third party service providers.
- To professional advisers, HM Revenue & Customs, regulators and other authorities.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Third Party Links
Your Legal Rights
You have certain rights under data protection laws in relation to your personal data. The key rights that may be applicable to our use and processing of your personal data are as follows:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing. You have the right to object to our processing of your personal data where we are relying on your consent to process your data and you withdraw your consent or where we are relying on legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have legal grounds to process your information which override your rights and freedoms. Where you withdraw your consent to processing, we may not be able to provide certain products or services to you and your withdrawal of consent will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent,
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; or (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- Request the transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Please contact us if you wish to exercise any of these rights. You will not have to pay a fee to access your personal data (or exercise any of your other rights), however we may charge a reasonable fee or refuse to comply if your request is clearly unfounded, repetitive or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to exercise your rights. We aim to respond to all legitimate requests within one month, though occasionally it may take us longer, in which case we will notify you and keep you updated.
Modifications to Policy
TH reserves the right to change this Policy at any time by posting revisions on this web page. Such changes will be effective upon posting.
Subcontractors / Subprocessors
TradingHub’s subcontractors / subprocessors are listed below:
- Amazon Web Services – cloud provider
- Microsoft – email services
- Swisscom (Switzerland) Ltd (where requested by a client)
- TradingHub group companies:
• TradingHub Group Limited, Hong Kong Branch (Hong Kong)
• TradingHub International LLC (United States)
• TradingHub Canada Limited (Canada)
As required pursuant to applicable data protection laws, on 1 January 2021, we appointed Symmetry Solutions Ltd (“Symmetry”) as our representative in the EU. If you are based in the EU and have any questions about this Policy, your rights regarding your personal data or how we use your personal data, you may contact Symmetry at:
FAO TradingHub EU Rep
Symmetry Solutions Ltd
The Tara Building
11-15 Tara Street
Dublin 2, D02RY83
If you have any questions regarding this Policy please do not hesitate to contact the Data Protection Officer at:
TradingHub Group Limited
21st Floor, Broadgate Tower
20 Primrose Street
London EC2A 2EW