Effective 25 May 2018
This policy (together with our user terms and conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, through our Website or App will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our Website or using our App, you are accepting and consenting to the practices described in this policy. We are committed to the protection and privacy of any shared personal information by meeting the aims and objectives of the principles of the GDPR.
What is personal data?
We collect information about you in a range of forms, including personal data. As used in this Policy, “Personal Data” is as defined in the GDPR, this includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.
We may collect and process the following data about you:
Information you give Us.
- You may give Us information about you by filling in forms on Our sites or by corresponding with Us by phone, e-mail or otherwise. This includes information you provide when you register to use Our sites, subscribe to Our services, place an order or transact on Our sites or report a problem with Our sites. The information you give Us may include your name, address, e-mail address and phone number, financial and credit information.
- You may give Us information relating beneficiaries, shareholders, trustees and directors to enable us to deliver Our services. This may be through filling in forms on Our sites or by corresponding with Us by phone, e-mail or otherwise. You must obtain appropriate consent before disclosing such information to Us. The information you give Us may include their name, address, e-mail address and phone number, financial and credit information.
Information We collect about you.
With each visit to Our sites We may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from Our sites (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call Our customer service number.
Information We receive from other sources.
- We may receive information about you if you use any other websites We operate or other services We provide. This data may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. Where this is the case We will ensure this will be in full compliance of the Regulation.
A cookie is a very small text file placed on your computer, that allows Us to distinguish you from other users of Our sites. These cookies help Us to provide you with a good experience when you browse Our sites. We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of Our sites. They include, for example, cookies that enable you to log into secure areas of Our sites.
- Analytical/performance cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around Our sites when they are using them. This helps Us to improve the way Our sites work, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to Our sites. This enables Us to personalise Our content for you, by remembering your preferences (for example, your choice of language or region).
You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of Our sites.
How We use your information
Information you give to Us. – We will use this information:
- to carry out Our obligations arising from any contracts entered into between you and Us and to provide you with the information, products and services that you request from Us;
- to provide you with information about other products and services We offer;
- where you are an existing customer, we will only contact you with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you.
- where you are a new customer, we will contact you only if you have consented to this. If you do not want Us to use your data in this way, please tick the relevant box situated on the form on which We collect your data.
- You may withdraw this consent at any time by using the links provided at the bottom of marketing emails from Us, or by contacting Our DPO.to provide you with information about other products and services We offer;
- to notify you about changes to Our service;
- to respond to any enquiry you have made through Our sites, or via phone, e-mail or otherwise.
- to comply with legal obligations, we are subject to as a data controller and regulated business
- where required to protect your vital interests or that of another natural person
- where performing tasks carried out in the public interest or in the exercise of official authority invested in Us
Information We collect about you. – We will use this information:
- to administer Our sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve Our sites to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of Our services, when you choose to do so;
- as part of Our efforts to keep Our sites safe and secure;
- to measure or understand the effectiveness of advertising We serve to you and others, and to deliver relevant advertising to you;
Information We receive from other sources. – We will use this information:
We may combine this information with information you give to Us and information We collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information We receive).
Information We disclose about you
We will not share any of your personal data with any third parties for any purpose subject to the following exception.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
Where this is necessary, we are required to comply with all aspects of the Regulation. The following are the types of organisations We may share some of your personal information with:
- Business partners, suppliers and sub-contractors for the performance of any contract We enter into with them or you.
- Analytics and search engine providers that assist Us in the improvement and optimisation of Our sites.
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of Us entering into a contract with you. We may disclose your personal information to third parties:
- In the event that We sell or buy any business or assets, in which case We may disclose your personal information to the prospective seller or buyer of such business or assets.
- If Concorde Currency Capital Limited or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
Where We store your personal information.
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). It may also be processed by staff operating outside the EEA who work for Us or for one of Our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. When these transfers are needed, they will be done in full compliance of the Regulation.
All your personal information will be afforded a high level of protection wherever it is processed and no matter whether it is held by Us, or Our contractors or agents.
All information you provide to Us is stored under Our control. Any payment transactions will be encrypted. Where We have given you (or where you have chosen) a password which enables you to access certain parts of Our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect your personal information, we cannot guarantee the security of your data transmitted to Our site; any transmission is at your own risk. Once We have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Should you have concerns about a method of data transmission, we will take reasonable steps to provide an alternative method.
You may contact Our Data Protection Officer, [email protected], to exercise your rights. When exercising your rights, we will always inform you of any lawful reason that may require Us to continue processing your data.
You have the right to request from Us information about whether we process your personal information, and ask questions about how We collect, store and process that information.
You have the right to access free information about the personal information We hold about you, whether this is transferred to a third country or international organisation and the associated safeguards.
You have the right to receive any personal data We hold about you in a commonly used and machine-readable format.
Where information We hold is not accurate or is incomplete, you have the right to request We correct such information and We will do so without undue delay.
You have the right to request that We delete any data We process about you, where there the processing is no longer necessary.
Where you have previously provided consent for Our processing of your data, you have the right to remove that consent and for Us to stop processing your data specific to that consent. You also have the right to object to Our processing of your data.
Our site may, from time to time, contain links to and from the websites of Our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
Retaining your Data
The period for which We will retain your data is dependent upon any statutory retention periods We are required to adhere to as a regulated organisation. After the expiration of that period, personal data shall be securely deleted, if it is no longer required for the fulfilment of any contract, initiation of a contract or in relation to other legal proceedings.