Privacy Policy
Version 1.0, last updated on 01/10/2021.
Introduction
The Advanced Markets Group is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, we are committed to the appropriate protection and use of personal information (sometimes referred to as “personal data”, “personally identifiable information” or “PII”).
This Privacy Statement sets out how the Advanced Markets Group (“Advanced Markets”, “we”, “us”) processes the personal data it collects, whether on individuals (including personal data in respect of individuals who are clients, intermediaries or other third parties the Advanced Markets Group interacts with, or any individual who is connected to those parties) or otherwise.
Generally, our intent is to collect only the personal information that is provided voluntarily when you visit any one of the Advanced Markets Group’s websites (regardless of where you visit it from) or provide it in the course of our client onboarding processes so that we can offer information and/or our services to those individuals or offer information about employment opportunities. Please review this privacy statement (“Privacy Statement”) to learn more about how we collect, use, and share and protect the personal information that we have obtained as well as your privacy rights and how the law protects you. This Privacy Statement is also designed to reflect the requirements of the EU General Data Protection Regulation.
Who we are
The Advanced Markets Group is a group of companies providing liquidity and technology services as well as credit solutions to facilitate trading in the over-the-counter foreign exchange and derivative markets and affiliates that provide administrative and management support to them.
The relevant Advanced Markets Group entity with which you have a primary relationship will be the entity with which you enter into a client agreement.
Our offices include jurisdictions outside the European Union which have not been deemed adequate for European Union Data Protection purposes (namely the Cayman Islands and Bermuda). However, please note that the Advanced Markets Group operates a global Data Protection Policy, and those offices are required to meet the same standard as our other offices.
1. The Data We Collect About You
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 (together “process”) different kinds of Personal Data about you which we have grouped together as follows:
- Identity Data includes: first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes: postal address, email address and telephone numbers.
- Financial Data includes: bank account; source of funds, source of wealth; payment card details.
- Transaction Data includes: details about payments to and from you and other details of products and transactions you have placed via our services and/or products.
- 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, transactions or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes: information about how you use our products and services.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature/ product or service we provide.
We do not collect 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.
2. How We Collect Your Personal Data
Direct interactions: You may give us your Identity, Contact and Financial Data as well as Marketing and Communications 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, services or an account with us;
- Subscribe to our publication;
- Request marketing be sent to you.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources, as set out below:
Technical Data from the following parties:
- Analytics providers such as Google based outside the EU;
- Advertising networks
- Search information providers
- Contact, Financial 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 availably sources, such as Companies House or equivalent
- Online identity verification tools
3. How We Process And Use Your Personal Data
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 or regulatory obligation.
We have set out below, in a table format, a description of all the ways we process your Personal Data, and which of the legal bases we rely on to do so. Where ever the legal basis is consent, we will ask you explicitly to consent on our website or otherwise.
4. Your Marketing Choices
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. For example, when subscribing for our newsletter, we offer a variety of information options you can choose from.
You can ask to stop sending you marketing messages at any time by contacting us at any time at [email protected]. Each communication we send will have an unsubscribe option in the footer.
5. Cookies
Information collected by cookies and other tracking technologies: We use various technologies to collect information on our Services and these may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve our Services and your experience. For more information about cookies, and how to disable them, please see our Cookie Policy.
6. Disclosures Of Your Personal Data
We may have to share your Personal Data with third parties set out below for the purposes set out in the table in paragraph 5 (a) above:
- Service providers who provide IT and system administration services.
- Customer Relationship Management (CRM) platforms.
- Professional advisers (acting as processors or joint controllers) including lawyers, bankers, auditors and insurers based in the EU, United States of America, Cayman Islands and Bermuda who provide consultancy, banking, legal, insurance and accounting services.
- Email marketing platforms.
- Data collection platforms and
- Analytics providers.
- Other companies in the Advanced Markets Group (acting as joint controllers or processors) and who are based in the United Kingdom, United States of America, Cayman Islands and Bermuda that provide among other things, administration and IT services.
- Regulators and other authorities (acting as processors or joint controllers) who require reporting of processing activities in certain circumstances.
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.
7. International Transfers
We share your personal data within the Advanced Markets Group and with international service providers. This will involve transferring your data outside the European Economic Area (“EEA”) Whenever we transfer your Personal Data to a party located out of the EU/EEA, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards such as the following are implemented:
- We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe (so called Standard Contractual Clauses).
Please contact us at [email protected] if you want further information.
8. Third-Party Links
This Website may include links to third-party websites, blogs, social media platforms and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
9. Data Security
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.
10. Data Retention
How long will you process my personal data for?
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements, or until you ask us to delete it.
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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
11. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data.
Particularly as an EU user of our Website, you have the right to:
- 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 the Personal Data that we hold about you. 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. Please keep us also informed if your Personal Data changes during your relationship with 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 local 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.
- 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; (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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your Personal Data to you or to a third party. 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.
- Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Object to processing of your Personal Data where we are relying on a legitimate interest (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 compelling legitimate grounds to process your information which override your rights and freedoms.
If you wish to exercise any of the rights set out above, please contact us at [email protected]
For more information on your rights and accordant requirements, please see the information provided by the EU Commission at https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
12. Advanced Markets Group Entities
Full details of certain Advanced Markets Group entities are included in the Legal and Regulatory Notice and Disclaimer section of our website.
Advanced Markets, LLC is the ultimate data controller for the Advanced Markets Group. In addition, the below lists the primary operating entities within the Advanced Markets Group which are also registered as a data controller in the listed jurisdictions as required. In respect of any instruction with the Advanced Markets Group, the primary data controller will be the entity with which you have contacted or contracted for services.
13. No Fee Usually Required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
14. What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
15. Time Limit To Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
16. Changes To The Privacy Notice And Your Duty To Inform Us Of Changes
We will inform you in advance if we make substantial changes to this privacy notice by email if you are registered with us or on the Website.