Privacy Notice - DWF Liquid Markets
1. Introduction
We hold your privacy in high regard and are dedicated to safeguarding your personal information. This Privacy Notice pertains to the handling of personal data by DWF Liquid Markets ("we", "us", "our") in relation to the utilisation of any of our products, or services (collectively referred to as the "Services"), visiting or using our websites ("Site").
Please be aware that our Services and Site are not intended for individuals under the age of 18, and we do not intentionally gather information about minors.
2. Scope
This Privacy Notice pertains to our handling of your Personal Information as a data controller. This includes situations such as when you access or use our Sites or Services, or when you contact us in any way. We collect various types of information from our users, customers, and business contacts, including Personal Information that can identify you as an individual, such as your name, address, and online identifiers. Please refer to the "Personal Information We Collect" section for more details.
However, this Privacy Notice does not cover the processing of Personal Information that our Customers, acting as data controllers, share with us as their service provider. For instance, this applies to Personal Information that our Customers possess about their own customers, which they may share or make accessible to us via our Services. In these cases, we will only process your Personal Information as a data processor on behalf of our Customers. Please contact the data controller directly or visit their website to learn more about how they handle your Personal Information.
Personal Data:
Personal data or personal information refers to any information that relates to an identified or identifiable living individual. This broad definition includes the specific pieces of personal data described below. However, it does not include data that cannot be used to identify an individual, such as a company registration number.
A "data subject" is an individual who can be identified, directly or indirectly, by personal data. This is typically done by reference to an identifier such as a name, identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual.
Different pieces of information that, when combined, can lead to the identification of a particular person also constitute personal data. However, data where the identity has been removed (anonymous data) is not considered personal data.
For more information, please refer to the link provided (note that this is a third-party website).
Categories of Personal Data:
Depending on whether and how you use our Services, or Site, we will collect, use, store, and transfer different types of personal data about you, which we have grouped into categories as follows:
Category of personal data
Examples of specific pieces of personal data
Identity Data
first name,
maiden name,
last name,
username or similar identifier,
title,
date of birth and gender,
biometric information, including a visual image of your face,
national identity cards,
passports, driving licences or other forms of identification documents.
Social Identity Data
your group/company data,
information on referrals related to you,
political background,
close connections,
behavioural data,
risk assessment,
compliance assessment.
Contact Data
residence details,
billing address,
delivery address,
home address,
work address,
email address and telephone numbers,
proof of address documentation.
Financial Data
bank account,
payment card details,
virtual currency accounts,
stored value accounts,
amounts associated with accounts,
external account details,
source of funds and related documentation.
Transactional Data
details about transactions to and from you,
other details of any transactions you enter into using the Services or Site.
Investment Data
information about your:
investment objectives,
investment experience,
prior investments.
Technical Data
internet connectivity data,
internet protocol (IP) address,
operator and carrier data,
login data,
browser type and version,
device type, category and model,
time zone setting and location data,
language data,
browser plug-in types and versions,
operating system and platform,
diagnostics data such as crash logs and any other data we collect for the purposes of measuring technical diagnostics, and
other information stored on or available regarding the devices you allow us access to when you visit the Site, or use the Services.
Profile Data
your username and password,
your identification number as our user,
information on whether you have DWF Liquid Market account and the email associated with your accounts,
requests by you for products or services,
your interests, preferences and feedback,
other information generated by you when you communicate with us, for example when you address a request to our customer support.
Usage Data
information about how you use the Site, the Services, and other offerings made available by us, including:
interaction type and time,
event time, name and source.
Marketing and Communications Data
your preferences in receiving marketing from us or third parties,
your communication preferences,
your survey responses.
As mentioned in the Identity Data section above, we will collect a visual image of your face, which, along with our subcontractors, will be used to verify your identity during onboarding. This data is considered a special category of personal data.
Refusal to Provide Personal Data:
If we are required by law or under a contract to collect personal data from you, and you refuse to provide such data when requested, we may not be able to perform the contract we have with you or are trying to enter into with you, such as providing you with our Services. In such cases, we may have to cancel any product or service you receive from us, but we will inform you if this becomes necessary.
3. How We Collect Your Data:
We use various methods to collect information from and about you, including the following:
Direct Interactions:
You may directly provide us with your Identity Data, Social Identity Data, Contact Data, Financial Data, Profile Data, and Marketing and Communications Data when you interact with us. This can be done by filling in forms, providing a visual image of yourself via the Service, emailing us, or engaging with us in any other way. This includes personal data you provide when you:
visit our Site;
apply for our Services;
create an account;
make use of any of our Services;
request marketing materials to be sent to you, such as by subscribing to our newsletters;
enter a competition, promotion, or survey, including through social media channels;
give us feedback or contact us.
Automated Technologies or Interactions:
When you interact with us via Website, you agree to permit us to use cookies to track each of your actions and collect and keep all the information that you leave on this Website. We will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We will also collect Transactional Data, Investment Data, and Usage Data. We may also receive Technical Data and Marketing and Communications Data about you if you visit other websites that employ our cookies.
1.1 When you visit our Website, we use cookies to monitor our performance and evaluate the effectiveness of our online advertising. Cookies are small data files that are sent to your browser and stored on your computer's hard drive. Cookies are only sent to your computer's hard drive when you use your computer to access our Website.
1.2 Cookies are typically used to record the browsing habits and preferences of visitors on our Website. The information collected by cookies is aggregated and non-identifiable statistical data that does not involve personal information.
1.3 Cookies allow the Website or service provider system to recognize your browser and collect and recall information, but cannot be used to obtain data from your hard drive, email address, or personal information. Most browsers are configured to accept cookies. You can opt to configure your browser to reject cookies or to alert you when cookies are being sent. However, disabling cookies in your browser may prevent you from accessing some features of our Website.
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Third Parties or Publicly Available Sources:
We also obtain information about you, including Social Identity Data, from third parties or publicly available sources. These sources may include:
fraud and crime prevention agencies;
a customer referring you;
public blockchains;
publicly available information on the internet (websites, articles, etc.).
4. How we use your data
We will use the Personal Information we collect from you and our customers and their users for various purposes, as described below:
Personal Information collected from you:
To administer our Sites, events and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
To improve our Sites to ensure that content is presented in the most effective manner for you and your computer;
To analyse customers' use of the Sites for trend monitoring, marketing, remarketing, and advertising purposes;
For purposes made clear to you at the time you submit your information, such as fulfilling your contact request, or providing information you have requested about our Services;
To keep our Sites safe and secure.
In doing so, we will rely on our legitimate interests to provide and improve our Sites for our visitors. If you provide your consent to receive marketing communications, we will rely on your consent for the processing of your Personal Information for marketing purposes.
Personal Information collected from our customers and their users:
To set up a user account;
To provide, operate, and maintain the Services;
To process and complete transactions, and send related information, including transaction confirmations and invoices;
To manage our customers' use of the Services, respond to inquiries and comments, and provide customer service and support;
To send technical alerts, updates, security notifications, and administrative communications;
To investigate and prevent fraudulent activities, unauthorised access to the Services, and other illegal activities.
Our processing of your information will generally be undertaken in accordance with our performance or entry into a contract with you or your employer, including terms of use applicable to your use of the Site or Services. We may also use the information you send to us via our Sites and/or Services to communicate with you via email and other means regarding products, services, offers, promotions, and events we think may be of interest to you, if this is in accordance with your marketing preferences. However, you will always be able to opt-out of such communications at any time.
Purpose for Using Your Personal Information:
We collect Personal Information for various purposes, including communicating with you, marketing and promotional activities, and providing and improving our services. The legal basis for collecting and using your Personal Information depends on the specific context in which we collect it.
We will generally collect your Personal Information with your consent, when we need it to perform a contract with you, or when the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may have a legal obligation to collect your Personal Information or may need the information to protect your vital interests or those of another person.
If we request your Personal Information to comply with a legal requirement or to perform a contract with you, we will inform you of this and advise whether the provision of your Personal Information is mandatory or not, as well as the potential consequences if you do not provide your Personal Information.
Likewise, if we collect and use your Personal Information based on our legitimate interests (or those of a third party), we will explain to you at the relevant time what those legitimate interests are.
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
Detailed Information on the Processing of Your Personal Data
Third Parties that share your Personal Data with us include:
Service providers. For example, we may use analytics service providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
Social networks connected to the services. If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your Account with us.
Advertising partners. We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.
Other third parties, such as providers of business contact information, who provide us with publicly available information on You, such as mailing addresses, job titles, email addresses, phone numbers, Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles for purposes of targeting advertising. We may combine this information with Personal Data provided by You, for targeting advertising purposes. This helps us analyze our records and identify new Customers.
Your rights under applicable Law
Privacy Rights for EEA, United Kingdom and Switzerland Users:
If you are a resident of the EEA, United Kingdom, or Switzerland, you have certain data protection rights. You can exercise these rights by emailing liquidmarkets@dwf-labs.com. Your rights include:
The right to access, correct, update, or request deletion of your Personal Information;
The right to object to the processing of your Personal Information by asking us to restrict processing of your Personal Information or request portability of your Personal Information; and
The right to withdraw your consent at any time if we collected and processed your Personal Information with your consent.
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
If Personal Information pertaining to you has been submitted to the Service by or on behalf of a DWF Liquid Markets customer, and you wish to exercise any data protection rights you may have in respect of that data under applicable law, please inquire with the relevant DWF Liquid Markets customer directly. If you wish to make your request directly to us, please provide the name of the DWF Liquid Markets customer who submitted your data to our Service, and we will refer your request to that customer and support them as needed in responding to your request within a reasonable timeframe.
If we transfer your information outside of your country, we will take steps to ensure that appropriate security measures are taken to protect your privacy rights as outlined in this notice. These measures may include, for example, relying on an adequacy decision, or entering into standard contractual clauses approved for use in your jurisdiction.
5. Disclosures of Your Data:
We share your personal data with our third-party service providers, agents, subcontractors, and other associated organisations, our group companies, and affiliates (as described below) to complete tasks and provide the Services and use of the App to you on our behalf. When using third-party service providers, they are required to respect the security of your personal data and to treat it in accordance with the law. We may pass your personal data to the following entities:
Companies and organisations that assist us in processing, verifying, or refunding transactions/orders you make and in providing any of the Services that you have requested.
Identity verification agencies to undertake required verification checks.
Fraud or crime prevention agencies to help fight against crimes including fraud, money laundering, and terrorist financing.
Anyone to whom we lawfully transfer or may transfer our rights and duties under the relevant terms and conditions governing the use of any of the Services.
Any third party because of any restructure, sale, or acquisition of our group or any affiliates, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us.
Regulatory and law enforcement authorities, whether they are outside or inside of the EEA, where the law allows or requires us to do so.
We ensure that all third-party service providers are bound by strict contractual obligations to keep your personal data confidential and to use it only for the purposes for which we have disclosed it to them. We will not sell, distribute, or lease your personal data to third parties unless we have your permission or are required by law to do so.
6. International Transfers
We may share your personal data within our group, which may involve transferring your personal data outside the EEA, United Kingdom, or Switzerland. Additionally, some of our external third parties are based outside the EEA, United Kingdom, or Switzerland, so their processing of your personal data may involve a transfer of data outside the EEA, United Kingdom, or Switzerland.
Whenever we transfer your personal data out of the EEA, United Kingdom, or Switzerland, we ensure that a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
The country to which we transfer your personal data has been deemed to provide an adequate level of protection for personal data by the European Commission, the UK Parliament or the Swiss Parliament.
A specific contract approved by the European Commission, the UK Parliament or the Swiss Parliament that provides safeguards for the processing of personal data, also known as Standard Contractual Clauses.
Please contact us if you want further information on the specific mechanism we use when transferring your personal data out of the EEA, United Kingdom, or Switzerland.
7. Data Security
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, damaged, or accessed in an unauthorised or unlawful way, altered, or disclosed while being transmitted over the internet. We limit access to your personal data to those employees, agents, contractors, and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
Depending on the nature of the risks presented by the proposed processing of your personal data, we have implemented the following appropriate security measures:
Organisational measures, such as staff training and policy development.
Technical measures, such as physical protection of data, pseudonymization, and encryption.
Securing ongoing availability, integrity, and accessibility, such as ensuring appropriate backups of personal data are held.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any relevant regulator of a breach where we are legally required to do so.
8. Data Retention
We determine the appropriate retention period for personal data by considering 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, as well as the applicable legal, regulatory, tax, accounting, or other requirements.
We usually consider the following factors when determining how long we need to retain your personal data:
In the event of a complaint.
If we reasonably believe there is a prospect of litigation in respect of our relationship with you or if we consider that we need to keep information to defend possible future legal claims.
To comply with any applicable legal and/or regulatory requirements with respect to certain types of personal data.
If information is needed for audit purposes and other similar reasons.
In accordance with relevant industry standards or guidelines.
In accordance with our legitimate business need to prevent abuse of the promotions that we launch.
Please note that under certain conditions, you can ask us to delete your data. We will honour your deletion request ONLY if the condition(s) is met.
In adherence with the European Union's laws on Combating Money Laundering and Terrorist Financing, we are required to retain your personal data for a period of five years after the termination of our business relationship, in accordance with the applicable directives. This retention period may be extended further in specific instances as provided for by relevant legislation. Equivalent requirements under the anti-money laundering laws of the United Kingdom and Switzerland mandate the retention of personal data for five years and ten years respectively after termination of the business relationship.
9. Your Legal Rights
As a data subject, you have certain legal rights in relation to your personal data. The rights available to you depend on the reason for processing your personal data. If you wish to exercise any of the rights listed below, please contact us.
You have the right to:
Request access to your personal data, which enables you to obtain confirmation of whether we are processing your personal data, to receive a copy of the personal data we hold about you, and information regarding how your personal data is being used by us.
Request rectification of your personal data by asking us to rectify information you think is inaccurate and to complete information you think is incomplete, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data by asking us to delete or remove personal data we hold about you. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you.
Object to the 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
Require that decisions be reconsidered if they are made solely by automated means, without human involvement. We use automated tools to make sure that you are eligible to be our customer, taking into account our interests and legal obligations. If these automated tools indicate that you do not meet our acceptance criteria, we will not onboard you as our customer.
Request restriction of processing your personal data, which enables you to ask us to suspend the processing of your personal data if you want us to establish the data accuracy; where our use of the data is unlawful, but you do not want us to erase it; 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 if 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, and we will provide to you, or a third party you have chosen (where technically feasible), 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, but we will advise you if this is the case at the time you withdraw your consent.
Complain to the IDPC, ICO, DPC, or any relevant authority about any perceived violation and to seek compensation for damages in the courts.
10. 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 manifestly unfounded or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
11. Period for Replying to a Legitimate Request
The statutory period under GDPR for us to reply to a legitimate request is one month. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.
Please note that we may request that you provide some details necessary to verify your identity when you request to exercise a legal right regarding your personal data.
12. Miscellaneous:
Change of Business Ownership and Control:
We may choose to buy or sell assets and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Moreover, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be one of the assets transferred to or acquired by a third party.
Apart from the instances listed above, Personal Information will only be disclosed or transferred to third parties when required by law, or to exercise, establish or defend our legal rights.
Under 18:
We do not knowingly collect or solicit Personal Information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us with Personal Information, please contact us at liquidmarkets@dwf-labs.com.
Storage:
We will store your Personal Information as long as is reasonably necessary to fulfil the purposes for which it was collected (including, but not limited to, for the purpose of meeting any legal, accounting, or other reporting requirements or obligations). When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
Do Not Track:
Some internet browsers, like Internet Explorer, Firefox, and Safari, include the ability to transmit "Do Not Track" or "DNT" signals. Since uniform signals have not been adopted, we do not currently process or respond to "Do Not Track" or "DNT" signals.
Marketing Communications:
You can opt-out of receiving certain promotional or marketing communications from us at any time by using the unsubscribe link in the email communications we send or by contacting us at liquidmarkets@dwf-labs.com with the word "UNSUBSCRIBE" in the subject field of the email. If you have an account for our Services, we will still send you non-promotional communications.
Links to Other Websites:
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes to this Privacy Policy:
We reserve the right to modify the Privacy Notice at any time and without prior notice. Any modifications to the Privacy Notice will be communicated by updating and publishing the effective date of the new version on this Website and highlighting the changes made. Although we may issue a notice to inform you of the modifications made to the Privacy Notice, we are not obligated to do so.
You are responsible for regularly reviewing the Privacy Notice and its modifications. If you do not agree to the modifications, you must immediately cease accessing this Website. Your continued use of this Website following the publication of an updated Privacy Notice indicates your agreement to the modifications and your willingness to comply with the updated Privacy Notice.
13. Communication with Us
If you have any requests or comments, please send an email to liquidmarkets@dwf-labs.com. This is the only valid and official email address that we use to communicate with you. We will not be held responsible for any failure to use effective contact information or any act or omission arising from the use of invalid contact information.
We only post announcements and information on this Website based on valid and effective contact information. We shall not be liable for any loss arising from your reliance on information obtained through means other than the above-mentioned contact information.
If you have any questions or concerns about our Privacy Notice, please feel free to contact us at any time.
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