Who we are
The purpose of this policy
The purpose of this policy is to explain to you what personal information we collect and how we and our associated companies may use it. Companies are associated with us if they are our subsidiaries or we are both subsidiaries of the same corporate entity. We are the controller of any personal information which you provide to us which means that we decide the purposes and means of the processing of that personal information.
How we obtain and store your information
We obtain your information through applications, emails, letters, telephone calls, SMS messages, cookies and conversations when registering for our services and during the course of our relationship (including information gained when you use our learning tools, demo accounts and trading simulators).
We may monitor or record phone calls with you and monitor (and maintain a record of) all emails and electronic communications sent by or to us.
We follow strict security procedures in the storage and disclosure of information that you have given us to prevent unauthorised access.
What types of personal information we process
We may process the following types of personal information:
- contact details including email details and phone numbers;
- age or date of birth;
- trading knowledge and experience;
- user names and passwords;
- information relating to your account including your account history, activity and orders
- IP address;
- National insurance number or other MiFIR national identifier;
- FCA approved reference number;
- Transaction reporting reference;
- Power of attorney / agent details;
- Phone device type;
- Operating system;
- Device ID;
- Cookie ID;
- Google 360 ID;
- GUID; and
- information about your use of our services, products and facilities (including information gained when you use our learning tools, demo accounts and trading simulators).
How we check your identity
To comply with money laundering regulations we need to confirm the name and address of our customers and certain third parties. We may ask you to provide physical forms of identity verification when you open your account. Alternatively, we may use a credit reference agency to verify your identity. Our search is not seen or used by lenders to assess your ability to obtain credit.
Using your personal information
As well as checking your identity, the personal information we hold may be used for:
- considering any of your applications;
- carrying out risk assessments;
- complying with our legal and regulatory obligations;
- performing our obligations under any contract we have with you;
- administering our relationship with you including resolving queries or issues;
- establishing and managing your account;
- reviewing your ongoing needs;
- providing you with the information, products and services that you request from us;
- checking your instructions to us;
- investigating any complaint you may make;
- providing evidence in any dispute or anticipated dispute between you and us;
- recovering amounts payable;
- training our staff;
- enhancing our customer service and products;
- undertaking product development and analysis; and
- detecting or preventing fraud or other crimes.
Where you have consented to direct marketing, we may send you marketing material from time to time by post, email, telephone, SMS or other electronic messaging services.
We also use technology to make decisions automatically or to build profiles about you. This technology uses logic that assesses whether our products are suitable for a potential customer, which helps us to determine whether or not it is appropriate for a potential customer to open an account with us. This means that you may not be able to open an account with us if our technology determines that it would not be appropriate for you to do so based on your financial knowledge and trading experience. If you ever think our machines have got it wrong, you can ask for a human to look into it. (See "Your Rights - Rights in relation to automated decision making and profiling".)
When we may share your information
We may share your personal information with:
- the FCA and any other regulatory or tax authority;
- such third parties as we reasonably consider necessary in order to prevent crime, e.g. the police;
- our associated companies;
- third-party service providers and advisers who provide us with administrative, financial, research or other services in connection with the services we provide to you;
- our introducing brokers and other commercial partners;
- our professional advisers;
- our auditors for the purposes of carrying out financial and regulatory audits;
- our agents, including credit reference agencies, acting on our behalf, carrying out such credit and identity checks, including money laundering checks, compliance regulatory reporting and fraud prevention checks, as we may reasonably consider necessary or desirable, including requesting a reference from your bank or any credit reference agency. Any third party referred to in this clause may share any personal information concerning you with us and other organisationsÂ involved in credit reference, the prevention of fraud and/or crime and/or money laundering or for similar purposes or to recover debts involved;
- courts, tribunals, regulatory or tax authorities and government agencies to enable us to enforce our agreement with you or to comply with the requirements of a court, regulator, tax authority or government agency;
- the purchaser or potential purchaser of one or more of our businesses or product/service lines and their professional advisers; and
- our trade repository.
Please also note that disclosure to the trade repository or regulators may also result in certain anonymous transaction and pricing data becoming available to the public.
Generally, we require that organisations outside our associated companies with whom we share your personal information acknowledge the confidentiality of your data, undertake to respect your right to privacy and comply with the data protection principles and this policy.
Information, which we obtain indirectly
In some cases, we are also provided with your name and contact details by our introducing brokers.
We also gather information relating to you and your online behaviour:
- to help optimise our website, to give you a good user experience and to personalise your use and our communications to you;
- to help us monitor, support and improve the performance of our site (by analysing your use and experience of our site);
- to help us understand more about you and the products and services you use and are interested in; and
- to tailor the online advertising you receive.
Knowing more about you helps us to understand our customers better, and means we can give you recommendations about products and services you may be interested in, and provide you with relevant advertising and customised communications that are of interest to you.
We combine information that you provide to us with information that is publicly available and/or that we receive from third parties such as advertisers and/or other reputable sources who have obtained your permission to do so, or have otherwise explained to you that this may happen.
You should only give us personal information about someone else (such as a joint applicant) with their permission. Where information is provided by you about someone else, or someone discloses information about you, it may be added to any personal information that is already held by us and it will be used in the ways described in this privacy notice. Sometimes, when you open a joint account or product, this may mean that your personal information will be shared with the other applicant. For example, transactions made by you will be seen by your joint account holder and vice versa.
The legal basis for our processing of personal information
The legal basis for our processing of personal information will depend on why we process your information.
Where you wish to enter into or have signed a contract to receive services from us, we will process your personal information to enable us to enter into and perform our contract with you. If you don't provide the personal information requested then we may not be able to provide some or all of those services to you.
We may also need to process your personal information to comply with our legal and regulatory obligations including in relation to:
- performing anti-money laundering, terrorism prevention and sanctions screening checks, complaints and investigations or litigation;
- obtaining information about your relevant investment knowledge and experience as required by the FCA so that we can assess whether a service is appropriate for you;
- obtaining information about your other investment activities in order to ascertain your status for the purposes of regulations which apply to trading in over-the-counter derivatives; and
- submitting and disclosing reportable data to our trade repository.
We also have a legitimate interest to process your personal information for:
- performing the services or supplying the products or information you have agreed to receive from us;
- ongoing management of our relationship with you and to maintain contact with you;
- our internal business purposes which may include business and disaster recovery, document retention/storage, IT service continuity (e.g. back-ups and helpdesk assistance) to ensure the quality of the services we provide to you;
- corporate transactions;
- marketing analytics including marketing campaign optimisation and web analytics to enable us to develop and target the marketing of our products and services;
- keeping our records updated and studying how customers use our products/services;
- developing our products and services, growing our business and informing our marketing strategy;
- defining the types of customers for our products and services and keeping our website(s) and platform(s) updated and relevant; and
- portfolio analysis and experience studies to enable us to improve the products and services we offer to customers.
If you have consented to direct marketing, we will use relevant personal information to enable us to provide you with personal information about products, news and services that may be of interest to you.
Using companies to process your information outside the EEA
All countries in the European Economic Area ("EEA") have similar standards of legal protection for your personal information. The personal information that we collect from you may be transferred to, and stored in, the United States of America, Australia, Japan, Singapore, China and the UAE. It may also be processed by staff operating outside the EEA in the United States of America, Australia, Japan, Singapore, China and the UAE who work for us. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. Where we transfer personal information or share it with others outside the EEA, we will ensure that we and those persons or companies who receive your personal information agree to protect it from improper use or disclosure, in accordance with data protection law by use of model clauses approved by the European Commission.
How long will we keep it?
We shall hold information about you on electronic and/or paper files whilst you are a customer and for at least six years after you cease to be a customer.
How to get more help
If you are unhappy about any aspect of the way we collect, share or use your personal information, we would like you to tell us. You can contact us using the details above.
If you are not happy with our response, you have a right to complain to the Information Commissioner at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Tel: 0303 123 1113 or on its website at www.ico.org.uk.