Our Commitment to You
ITI Capital Limited and its affiliated companies (“Company” or "We") are dedicated to providing users with the highest level of transparency and control over the use of their data. In order for us to provide you with our services we are required to collect and process certain personal information about you and your activity.
Grounds for data collection
Processing of your Personal Data (meaning any information which may potentially allow your identification with reasonable means) is necessary for the performance of our contractual obligations towards you and providing you with our services and the operation of our website (hereinafter the Services and Website), to protect our legitimate interests and for compliance with legal and regulatory obligations to which we are subject.
How we receive data about you
We receive your Personal Data from various sources:
1. Registration data
- When you voluntarily provide us with your personal details in order to create an account or register to our Services (for example, your name and email address);
2. When you communicate with us
- For example when you send us an email, we collect the Personal Data you provided us with.
3. Technical data
4. Third party data
- We also collect information about you from third party sources such as suppliers that help us prevent money laundering and fraud, marketing agencies, identity verification services and analytics providers. The categories of information that we collect about you from other sources are:
- where permissible under applicable law, personal details (e.g. name, date of birth);
- contact details (e.g. phone number, email address, postal address or mobile number); and
- employer name.
Please note that we may be required by law to collect and use certain personal information about you. And we may need to collect and use personal information to enter into or fulfil a contract with you. Failure to provide this information may prevent or delay the fulfilment of our obligations in these circumstances.
Type of data we collect
- Registration data: your name, address, your email address and payment details.
- When using our Services: our webserver will collect your IP-address and UID.
- Information from third parties: in order to provide our Service, we may receive Personal Data from our business partners. This may include Personal Data such as your contact details (name, phone, email) as well as details pertaining to your company, your job, your activities and publications.
2. Non-Personal Data - We also collect data about the use of our Service and the characteristics and activities of users, in order to operate it and improve it. We may collect the following non-Personal Data:
3. Technical data - This category includes data such as website visits, the browser you are using and its display settings, your operating system, device type, session start/stop time, time zone, network connection type (e.g., Wi-Fi, cellular), cookie data and your general location (city and country).
4. Data from third parties - This category includes data we receive from our business partners. This may include pseudonymous advertiser identifiers that some Advertisers or other third-party ad platforms choose to share with us. This data is also used to enhance data points about a unique browser or device.
If we combine Personal Data with non-Personal Data, the combined data will be treated as Personal Data. Further Personal Data will only be stored and processed if you voluntarily provide it to us, e.g. through a contact form.
When you visit or access our Services we use (and authorize 3rd parties to use) pixels, cookies, events and other technologies. Those allow us to automatically collect data about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Websites performance, perform analytics and customize your experience on it. In addition, we may merge data we have with data collected through these tracking technologies with data we may obtain from other sources and, as a result, such data may become Personal Data.
Managing your cookie settings and opting out of 3rd party cookies
There are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively.
Turning off cookies via your web browser
Most web browsers will provide you with some general data about cookies, enable you to see what cookies are stored on your device, allow you to delete them all or on an individual basis, and enable you to block or allow cookies for all websites or individually selected websites. If you want to delete cookies that are already on your device, you can do this by deleting your browser history or visit www.aboutcookies.org. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of some or all cookies. However, in a few cases, you may find that you are not able to access parts of our website. You can also normally turn off third party cookies separately. Please note that the settings offered by a browser or device often only apply to that particular browser or device.
How we use the data we collect
1. Provision of service - For the provision and improvement of our Services, including for support and to respond to your queries.
2. Service announcements - We will use your Personal Data to communicate with you and to keep you informed of our latest updates to our Services and offer you service offers.
3. Marketing and advertising purposes - We may use your Personal Data in the following ways: we may send you promotional material concerning our Services, or our partners' services, which we believe might interest you; we may also display certain adverts on our site, which we believe will be relevant for you. Furthermore, by subscribing to our newsletter you will receive tips and announcements straight to your email account. We make our best efforts to make sure you see only relevant ads and receive relevant communications from us, including but not limited to, by building an automated profile based on your Personal Data. You may however choose not to receive our promotional or marketing emails (all or any part thereof) by clicking on the unsubscribe link in the emails that you receive from us. Please note that even if you unsubscribe from our newsletter, we may continue to send you service-related updates and notifications or reply to your queries and feedback you provide us. You may also object to the use of your Personal Data for advertising purposes by disabling your cookies, as described in the tracking technologies section above.
5. Analytics, surveys and research - From time to time, we may conduct surveys or test features, and analyze the data we have to develop, evaluate and improve these features, all in order to improve our Services and think of new and exciting features for our users.
6. Protecting our interests - We may use your Personal Data when it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our services and protect the rights and property of the Company, its users and/or partners.
7. Compliance with legal and regulatory requirements - We may use your Personal Data to investigate legal and regulatory violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.
With whom we share your Personal Data
1. Internal concerned parties - We share your data with companies in our group, as well as our employees, in order to provide you with our services.
3. Compliance with laws and law enforcement entities - We cooperate with government and law enforcement officials in order to comply with our reporting, legal and/or regulatory requirements. For example, we may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
Some of the processing we conduct will involve making decisions about you based on automated processing of your Personal Data. For example, we may conduct profiling activities to select personalized offers or recommendations for you based on your use of the Services or browsing history. If you are in the EU, where these decisions are based solely on our automated processing of your Personal Data (e.g., not subject to human review), these types of decisions will not have legal or similar effects on you, but you can still contact us for further information and to object to this use of your personal information.
Under EU privacy law, we must have a legal basis to process Personal Data. In most cases the legal bases for our processing, under EU law, will be one of the following:
1. To fulfil our contractual obligations to you, for example to provide the Services or to ensure that invoices are paid correctly;
2. To comply with our legal and/or regulatory obligations, for example obtaining proof of your identity to enable us to meet our anti-money laundering obligations; and/or
3. To meet our legitimate interests, for example to: understand how you use the Services and to enable us to use this knowledge to improve our products and services and to develop new ones; to communicate with you about the products and services that you use or we offer; maintain our accounts and records; to assess patterns of use; and to plan and evaluate our marketing and business development programs. When we process Personal Data to meet our legitimate interests, we put in place, when needed, safeguards designed to protect your privacy interests, freedoms, and rights under applicable laws.
5. We may anonymize your Personal Data and use it for other purposes. For example, we may prepare aggregated reports about how users interact with the Services for research.
For additional terms applicable to users in the EEA, please click here. Please note some data recipients may be located outside the EEA. In such cases we will transfer data of EEA Users only to such countries as approved by the European Commission as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.
How we protect your data
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn’t publicly available. We limit access of your data only to those employees or partners on a need to know basis, in order to enable the carrying out of the agreement between us.
While we seek to protect your data to ensure that it is kept confidential, we cannot absolutely guarantee its security. You should also be aware that there is always some risk involved in transmitting data over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the service, and you do so at your own risk.
We will retain your Personal Data for a 7 year period in order for us to meet our legal obligations, resolve disputes, and enforce our policies, with, for example, any personal data relevant to our anti-money laundering obligations to be held for a period of at least five years in order for us to comply with our record keeping obligations under the Money Laundering Regulations 2017. Retention periods will be determined taking into account the type of data that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused data at the earliest reasonable time. Under applicable regulations, we will keep records containing client Personal Data, trading data, account opening documents, communications and anything else as required by applicable laws and regulations.
We have put in place certain safeguards to help prevent unauthorized access and maintain data security with respect to your Personal Data. Despite these protections, however, we cannot guarantee that your data will be 100% secure. You should take measures to protect your Personal Data.
Your online access to your Personal Data may be protected with a password you select. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). You have an obligation to keep your user ID, password and personal information secure. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. As part of maintaining this obligation we recommend you do the following:
1. Keep your user ID and password confidential;
2. Utilize a unique password and change it frequently;
3. Make sure others are not watching you enter your user ID and/or password on your keyboard when using protected elements of the Services; and
4. Do not leave your computer unattended while logged onto protected elements of the Services. After you finished accessing your information, exit the protected area.
If you have a concern about our privacy practices or where you believe your data has been processed in a way that does not comply with GDPR, you can make a complaint which will be acted on promptly. To make a complaint, please contact us on the details provided below.
If you are not satisfied with our response, you have the right to submit a complaint to our supervisory authority, the Information Commissioner’s Office (ICO). You can contact them on their helpline on 0303 123 1113 or alternatively you could visit their website at https://ico.org.uk/ to find out more.
To contact us?
If you wish to exercise any of the aforementioned rights, or receive more information, please contact us using the details provided below:
Head of Compliance
ITI Capital Limited
Level 33 Tower 42,
25 Old Broad Street,
London EC2N 1HQ.
Tel: + 44 (0) 207-562-8000
We understand the importance of protecting children’s privacy, especially in an online environment. The Site and Services are not designed for or directed at children under the age of 18 years old (Minors). We do not knowingly collect Personal Data from Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data, he or she should contact us using the details provided above.