Effective 14th February 2014
SecureTrading Financial Services Ltd (“We“, “Secure Trading Financial Services“) is committed to protecting and respecting your privacy.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is SecureTrading Financial Services Ltd of Ewropa Business Centre, Triq Dun Karm, Birkirkara, BKR 9034, Malta.
INFORMATION WE MAY COLLECT FROM YOU
We (or our agents or sub-contractors acting our behalf) 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 the Website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use the Website, subscribe to any of our services, request further information via the Website and/or when you report a problem with the Website. The information you give us may include your name, job title, postal address, e-mail address, phone number, company details including bank details.
Information we collect about you. With regard to each of your visits to the Website 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 the Website (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 of the other websites we operate or the other services we provide. 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.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
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, or to permit our agents or sub-contractors to provide you, with information about other goods and services we offer that are similar to those that you have already purchased or enquired about – if you do not want us to use your data in this way, please tick the relevant box situated on the form on where we collect your data;
- to provide you, or to permit our agents or sub-contractors to provide you, with information about any of our goods or services which we feel may interest you – if you do not want us to use your data in this way, please tick the relevant box situated on the form on where we collect your data;
- to provide you, or permit our agents or sub-contractors to provide you, with information about any third party goods or services which we feel may interest you – if you do not want us to use your data in this way, please tick the relevant box situated on the form on where we collect your data;
- (or our agents or sub-contractors will use this information) for the purpose of supplying your details to third parties so that you can be contacted directly by those same third parties regarding their goods and services – if you do not want us to use your data in this way, or to pass your details on to third parties for this purpose, please tick the relevant box situated on the form on where we collect your data;
- to send (or for our agents or sub-contractors to send) you promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided;
- to contact (or for our agents or sub-contractors to contact) you for market research purposes;
- to notify (or for our agents or sub-contractors to notify) you about changes to our service; and
- to ensure that content from the Website is presented in the most effective manner for you and for your computer.
Information we collect about you. We will use this information:
- for internal record keeping;
- for research;
- to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve the Website and our products and services 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 service, when you choose to do so;
- as part of our efforts to keep the Website safe and secure;
- to make suggestions and recommendations to you and other users of the Website about goods or services that may interest you or them (subject to your preferences where possible);
- providing you with information about specially selected third party products and services (if you consent to receive such information when supplying your data to us);
- notifying you of any changes to our products and services;
- providing you with password reminders or to notify you that a particular service has been suspended for maintenance; and
- processing and dealing with any complaints or enquiries made by you.
Information we receive from other sources. 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).
DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, or any services that we provide to you.
- Analytics and search engine providers that assist us in the improvement and optimisation of the Website.
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 data to the prospective seller or buyer of such business or assets.
- If Secure Trading Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- With your express consent.
- We may also share anonymised, aggregated data, such as access statistics, with third parties such as business partners. This will not involve the identification of individuals.
WHERE WE STORE YOUR PERSONAL DATA
The data that you provide us is sent via a secure link (HTTPS) and sensitive data stored is encrypted using standard encryption technology in computer servers with limited access and in controlled facilities. We store your personal information for at least for the duration of any customer relationship we have with you, or as otherwise required by law (normally up to a maximum of 7 years for legal and tax reasons).
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. We will never contact you and ask for your password.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; 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.
All our employees and data processors, who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of your personal data.
The Website 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 data to these websites.
We may use the information we collect to contact you by post, telephone and/or electronic means.
You have the right to ask us not to process your personal data for marketing purposes either at initial registration or later through updates. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at [email protected]
If you would prefer to no longer receive marketing-related messages from us, or if you would prefer that we not share personal data about you with any of our business partners, you may opt-out of receiving messages from us or from our future sharing of information about you by following the “unsubscribe” instructions in the latest such message you have received. We will endeavour to comply with your request as soon as reasonably practicable. Please keep in mind that if you opt-out of receiving promotional messages from this Website, we will continue to send you transactional messages and important account-related information regarding this Website or services offered through this Website. We also will continue to honour your requests regarding promotional communications from any other websites within our group of companies for which you have subscribed.
Please note that if you opt-out as described above, we will not be able to remove personal data about you from the databases of any business partners with which we have already shared personal data about you (i.e., to which we have already provided personal data about you as of the date that we implement your opt-out request). If you wish to cease receiving marketing-related messages from such business partners or any artists, please contact such business partners directly or utilize any opt-out mechanisms set out in their respective privacy policies or marketing-related messages.
ACCESS TO INFORMATION
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
We are not responsible nor will be liable to you in any way for events beyond our direct control. Because of the complex and constantly changing nature of our technology and business, we cannot guarantee nor do we represent that our performance will be error free, and to the maximum extent permitted by law we will not be liable for any direct, indirect, incidental, consequential or punitive damages or other loss suffered by you and relating to the use or release of your personal data.
- Email: [email protected]
- Phone: +44 (0)203 764 5050
- Post: Data Protection Officer, SecureTrading Financial Services Ltd, Ewropa Business Centre, Triq Dun Karm, Birkirkara, BKR 9034
If you are not satisfied with our response to your concern you may wish to contact the Information and Data Protection Commissioner. Contact details can be found on the IDPC website at https://idpc.gov.mt/en/Pages/contact/complaints.aspx