Welcome to OTCX Trading Limited ("we," "us," "our"). We are committed to protecting and respecting the privacy of our customers, users of our website, suppliers, individuals who contact us, and those other external parties whose personal data we may otherwise process in the course of our business (“you” and “your”).
This policy outlines how we collect, use, disclose, and safeguard your information when you visit our website www.otcxtrading.com or engage with our services. Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.
In this privacy policy, “Data Protection Legislation” means the UK Data Protection Act 2018; together with all other applicable legislation relating to privacy or data protection and the terms “personal data”, “data subject”, “controller”, “processor” and “process” (and its derivatives) shall have the meanings given to them in the Data Protection Legislation.
Personal Data
We may collect and process the following personal data about you, which means information that can be used to identify you, including (but not limited to) the following types of personal information:
· Identity Data: Name, username or similar identifier, marital status, title, date of birth, and gender.
· Contact Data: Billing address, delivery address, email address, and telephone numbers.
· Financial Data: Bank account details.
· Transaction Data: Details about payments to and from you and other details of services you have purchased from us.
· Technical Data: IP address, 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: Your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
· Usage Data: Information about how you use our website, products, and services.
· Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Special Categories of Data
We do not typically collect special categories of personal data about you (e.g., race, ethnicity, religious beliefs, sexual orientation, political opinions, health data, or criminal records).
Third Party Information
If any information which you provide to us relates to any third party, by providing us with such personal information you confirm that you have obtained any necessary permissions from such persons to the reasonable use of their information in accordance with the above provisions, or are otherwise permitted to give us this information. You further agree to make such third parties aware of this privacy policy.
We use different methods to collect data from and about you, including:
· Direct interactions: You may provide data by filling in forms or by corresponding with us by post, phone, email, or otherwise.
· Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns.
· Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources.
Processing
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:
· Performance of Contract: Where we need to perform the contract we are about to enter into or have entered into with you.
· Legitimate Interests: 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.
· Legal Obligations: Where we need to comply with a legal or regulatory obligation including anti-money laundering and anti-terrorist financing (collectively “AML”) and fraud prevention purposes, including Office of Foreign Assets Control (OFAC) and Politically Exposed Persons (PEP) screening for these purposes and to comply with UN, EU and other applicable sanctions regimes.
Purposes for which we will use your personal data include:
· To manage our relationship with you.
· To manage payments, fees, and charges.
· To improve our website, services, marketing, and customer relationships and experiences.
· To prevent fraud.
· To protect our business interests.
· To ensure that complaints are investigated.
· To evaluate, develop or improve our products and services.
· To keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.
· For any other specific purposes where you have given specific consent to that processing for those purposes.
Automated Processing
When we use your information, we may use automated processes. In particular, in order to comply with our obligations under AML legislation, we are required to verify the identity of all clients and other information (including but not limited to details of any nationality, citizenship or rights of residence you hold) to satisfy our regulatory obligations. We may do this using an electronic verification system that we consider suitable or by asking you for documentary evidence.
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk:
· we may refuse to provide the services you have requested, or we may stop providing existing services to you; and
· a record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you.
Generally, we do not rely on consent as a legal basis for processing your personal data. Where we have asked for your consent and you have given it, you have the right to withdraw it at any time by contacting us. You always have the right to unsubscribe from any direct marketing that you receive from us, by clicking the link that is included in each message or by contacting us.
We may share your personal data with:
· Service providers: Acting as processors who provide IT and system administration services.
· Professional advisers: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, regulatory, and accounting services.
· HM Revenue & Customs, regulators, and other authorities: Acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
· Any other person or organisation after a restructure, sale or acquisition of any OTCX Trading Limited company, as long as that person uses your information for the same purposes as it was originally given to us or used by us (or both).
· Anyone to whom we may transfer our rights and/or obligations under our terms with you.
· Your advisers (including, but not limited to, accountants, lawyers or other professional advisers) where authorised by you.
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.
In any case where we share personal data with a third-party controller (including, as appropriate, other members of OTCX Trading Limited), the use by that third party of the personal data will be subject to the third party’s own privacy and data protection policies.
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.
We are obliged to retain certain information to ensure accuracy, to help maintain quality of service and for legal, regulatory, accounting, reporting, fraud prevention and legitimate business purposes. We will only keep the information we collect about you on our systems or with third parties for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate and up-to-date and still required.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
· Request access to your personal data.
· Request correction of your personal data.
· Request erasure of your personal data.
· Object to processing of your personal data.
· Request restriction of processing your personal data.
· Request transfer of your personal data.
· Withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at dataprivacy@otcxtrading.com and we will respond within one month. Please note that we may ask you to verify your identity and ask you for more details about your request. We will comply with our legal obligations as regards your rights as a data subject.
We will correct any incorrect or incomplete information and will stop processing your personal data, or erase it, as long as there is no overriding legitimate ground or other legal reason for us to continue to hold or use that information. There may be some information which we are not legally able to disclose to you. Also, in exceptional circumstances, it may not be practicable for us to provide you with copies of all the documents that you request. If this is the case, we will explain our reasoning to you. Please note that if you exercise some or all of the above rights, the performance of our services may be impaired or no longer possible.
If you have any concerns about our use of your information, you also have the right to complain to the data protection regulator about our information rights procedures. The regulator is the Information Commissioner’s Office and their contact details are available here: https://ico.org.uk/.
Some of your personal data that we process may consist of cookies, which are small text files that often include a unique identifier that is sent by a web server to your internet enabled device when you visit a website. For details of how we deal with cookies, please see our Cookie Policy.
We may use your information from time to time to inform you by letter, telephone, text (or similar) messages, email and other electronic methods, about similar products and services (including those of third parties) which may be of interest to you.
You may, at any time, request that we do not send such information to you by one, some or all channels, by contacting us in the way described below.
We keep our privacy policy under regular review. Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email.
If you have any questions about this Privacy Policy or our privacy practices, please contact us at:
Email: dataprivacy@otcxtrading.com
Postal Address: 49 Queen Victoria Street, London, EC4N 4SA, United Kingdom.