Privacy Policy

Please read this Privacy Policy (hereinafter referred to as this Policy) carefully before using this website (www.gtngroup.com/europe).

The protection of privacy and the safeguarding of your personal information, including Personal Data, is our highest priority. We respect your privacy rights and are strongly committed to protecting your privacy. In this Policy, “we”, “us” and “our” means GTN Europe Financial Services Limited [GTNE] and “you”, “your”, “the user” means the individual or an authorised representative of a legal entity who accesses or uses this Site from anywhere in the world. In the course of providing financial Products and Services, we collect and maintain certain Personal Data when you use our Site, in order to enter into a transaction or open an account with us.

This Policy explains how we collect and protect your Personal Data. We ensure that any Personal Data obtained from you is not used or disclosed unless we have a lawful basis for such processing. By opening an account or by using our Site, you acknowledge the collection, use, and the disclosure of Personal Data by us in accordance with this Policy and other agreements (if any) you have entered with GTNE.

Definitions

Affiliate means a legal entity that controls, is controlled by, or is under common control with another legal entity, but only while that control relationship exists. To “control” means the direct or indirect ownership or power to control more than 50% of the issued shares or other securities of an entity or of the voting rights attached to the issued shares or other securities of such entity; or the power to control, directly or indirectly, the appointment of more than 50% of any board of directors or governing body of such entity.

Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Data Subject means an identified or identifiable natural person to whom Personal Data relates.

Personal Data means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Products means the financial products made available to you by GTNE and/ or its Affiliates.

Services means the services made available to you through our Site.

Collection of personal data

We collect your Personal Data through our Site when you log in to the Site. You may also provide Personal Data to us when you subscribe to any Products or Services or when you fill in account opening applications (whether written or electronic) or when we conduct Know Your Client (‘KYC’) and Customer Due Diligence checks upon you or when you provide Personal Data in any other form.

Personal Data we collect may include information required to communicate with you and would generally consist of the following information:

  • Your name,
  • Mailing address,
  • Telephone number,
  • E-mail address
  • Identification information (passport, identity card or other form of Identification information),
  • Demographic information,
  • Birth date,
  • Education,
  • Occupation,
  • Work Experience,
  • Information about your intended transactions with us and other related information,
  • Information about transactions you enter into through our Site in order to assess your trading experience,
  • Your approximate annual income and approximate net worth to assess your financial position and suitability for entering into transactions with us,
  • Bank details or details of your investments with other financial services providers

Purpose of collecting personal data

We may use the information collected from you for the following purposes:

  • To establish and verify your identity and contact information,
  • To establish and set up your trading account,
  • Issue an account number and a secure password,
  • To monitor your account activity and contact you with account information,
  • To personalise and continually improve the Services,
  • To customise your browsing experience and inform you about additional Products, Services or promotions that may be of interest to you.

How long we keep your Personal Data

We will retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements under UK law and the UK GDPR.

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 under UK law and the UK GDPR.

We may also retain your Personal Data after the closure of the account or if your application is declined or abandoned for as long as we require in order to comply with legal and regulatory requirements and for our legitimate business purposes, in accordance with UK law and the UK GDPR. We will ordinarily retain your information for six (6) years to comply with financial regulations or longer if required by UK law.

Disclosure of Personal Data

We may share your Personal Data with our Affiliates and third parties for the purposes of providing you with Products and Services. For example, we may share your Personal Data in order to process transactions for your account, execute your trades on an exchange, and manage and administer your account, or we may share your Personal Data with any of our service providers as required by them enabling them to provide their services to you. Furthermore, these service providers may only use your Personal Data in accordance with our instructions.

Our Affiliates will deal with your Personal Data in the same way as described in this privacy statement. GTNE may disclose the information to GTNE’s agents, counterparties such as bankers, custodians, broker-dealers, exchanges, and sub- contractors as necessary in order to provide the Services to you.

We may be obliged to disclose your Personal Data in certain circumstances for legal or regulatory reasons, including but not limited to instances where we are required to disclose the information in accordance with UK law and regulations, including the UK GDPR.

We may also disclose your Personal Data as necessary to perform credit checks, collect debts, enforce our legal rights or protect our interests and property.

Data Security, Safety of Personal Data

We have taken appropriate technical and organisational measures to ensure the security of any Personal Data that we collect and hold, including limiting the number of people who have physical or network access to our database servers.

A secure https/ communication channel ensures the security of data communications made through our Site. Your Personal Data is protected during transmission by using Secure Sockets Layer (SSL) software, which encrypts Personal Data transmitted to us. Furthermore, a 128-bit key, the most secure form of commercially available encryption, is used to ensure the security of your transactions. We also provide you with a unique username and password to access your account information online. You are responsible for keeping this password confidential.

Transmission of information via the internet is not completely secure. Although, we have implemented systems and processes to protect your Personal Information, no data transmission over the Internet can be guaranteed to be completely secure. Accordingly, transmission of data should be done at your own risk.

We assume no responsibility for loss of whatever nature, howsoever arising and/or resulting from computer viruses, trojans, worms or equivalent or similar items which are beyond our control.

Data Subject rights under UK GDPR

If you are a Data Subject located in the UK, you have the following rights under the UK GDPR:

  • The right to access: You have the right to request copies of your personal data.
  • The right to rectification: You have the right to request that we correct any information you believe is inaccurate or incomplete.
  • The right to erasure: You have the right to request that we erase your personal data under certain circumstances.
  • The right to restrict processing: You have the right to request that we restrict the processing of your personal data under certain circumstances.
  • The right to object to processing: You have the right to object to the processing of your personal data under certain circumstances.
  • The right to data portability: You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain circumstances.
  • The right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time.
  • The right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection issues.

Processing, Storage and transfer of Personal Data

We will take all steps reasonably necessary to ensure your Personal Data is processed in accordance with UK law, including the UK GDPR, and this Policy. By submitting your Personal Data, you agree to such transfer, storing or processing in accordance with this Privacy Policy. You agree that we have the right to transfer the Personal Data and process and store it, including outside the UK, provided that appropriate safeguards are in place in accordance with UK law, including the UK GDPR. GTNE is part of GTN Group, a ISO 27001 certified organisation, and all information security policies are strictly enforced.

Use of cookies

Cookies are small text files sent from the web server to your computer. We use cookies to assist us in securing your trading activities and to enhance the performance of our site. Cookies used by us do not contain any Personal Data nor do they contain account or password information. We do not control or take any responsibility for the use of cookies by third parties on other third-party websites linked to our site.

Calls

We may record and monitor any telephone calls made to us or received by us to maintain our service standards, to check instructions, for compliance purposes and otherwise for your protection and ours.

Links to other websites

Our Site may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other websites.

If the use of the websites of other third parties/service providers is associated with the collecting, processing and use of Personal Data, please refer to the data protection notices of the respective third-party websites.

Modifications

We reserve the right to change this Policy at any time by posting revisions on this site. Such changes will be effective upon posting. We advise you to check our site frequently to review any changes to this Policy.

Contact Point for Data Protection enquiries or exercising Data Subject Rights

If you have any queries about this Privacy Policy or data protection provisions or need to exercise any of your rights, please contact our Data Protection Officer (DPO) via email or phone:

Name of DPO: Mr Mevan Balalle
Email address: dpo@gtngroup.com
Contact Number: +971 50 199 5582

Notification of Personal Data Breaches

We will notify you as soon as practicable in the circumstances when a Personal Data Breach is likely to result in a high risk to your rights and freedoms, as required under UK law and the UK GDPR. We shall promptly communicate with you if there is an immediate risk of damage to you.

Governing Law and Jurisdiction

This Privacy Policy and any matters arising from or in connection with it are governed by and construed in accordance with the laws of England and Wales.

For any disputes arising under this Privacy Policy, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection issues. The courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with this privacy policy.