House of Borse Limited (“HOB” or “we”) appreciates your visit to this web site ("HOB Website") and your interest in our services and products. Your privacy is important to us and we want you to feel comfortable visiting our site. We take care to protect your personal data collected, processed and used during visits to the HOB Website.
By accessing the HOB Website, you accept this Privacy Statement ("Statement").
If you do not agree to this Statement, do not proceed to further web pages of the HOB Website.
This Statement may be updated from time to time. We therefore ask you to consult it on a regular basis. The last line of this Statement below indicates when the Statement was last updated.
Who we are?
HOB is an online brokerage of investment derivatives offered on a Matched Principal Basis. For more information about HOB, please see the “About House of Borse” section of our website.
What is the purpose and the scope of this Statement?
HOB are committed to safeguarding the personal information that we collect from individuals who use the HOB Website. Accordingly, HOB has developed this Statement to describe how and what type of data will be collected from users of the HOB Website, and the purposes for which HOB may collect, share or disclose the data. HOB also outlines reasonable precautions which are taken to keep your data secure.
This Statement applies to any information obtained by HOB through your use of the HOB Website. It is not applicable to any Internet websites controlled by third parties not affiliated with HOB that the HOB Website may link to ("Third Party Sites"). Please review the privacy statements of Third Party Sites as HOB is not responsible for and has no influence on the content or the privacy practices of Third Party Sites.
The terms of this Statement are subject to any additional terms of disclaimers or other contractual terms you have entered into with HOB such as client privacy statements or notices, and any applicable mandatory laws and regulations.
What information do we collect from you?
The personal information that we may collect about you broadly falls into the following categories:
INFORMATION THAT YOU PROVIDE VOLUNTARILY
You may give us your identity, contact and financial data etc. by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes personal information you provide when you:
- Apply for our products or services
- Create an account on our website
- Subscribe to our or related third party service or publications
- Request marketing to be sent to you
- Enter a competition, promotion or survey
- Give us some feedback
In addition to above, certain parts of our website may ask you to provide personal information voluntarily (for example, we may ask you to provide your contact details in order to register an account with us, to subscribe to marketing communications from us, and/or to submit enquiries to us). The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
INFORMATION THAT WE COLLECT AUTOMATICALLY
When you visit our website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area (EEA), this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (for example, country or city-level location) and other technical information. We may also collect information about how your device has interacted with our website, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our website, where they come from, and what content on our website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our website to our visitors.
INFORMATION THAT WE OBTAIN FROM THIRD PARTY OR PUBLICLY AVAILABLE SOURCES
From time to time, we may receive personal information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
We use the information we receive from these third parties to enhance the services we provide to you, such as providing curated content that is relevant to services we provide you or topics you are interested in.
Lawful basis for processing personal information
Our lawful basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where 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 also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect vital interests.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the lawful basis on which we collect and use your personal information, please contact us.
Serving you as a client
Type of Data: Identity, contact details, transactional, financial, contractual
- setting up and providing access to you trading account
- delivering our products and services
- facilitating withdrawals, deposits, transfers
- responding to your queries via chart, email and phone
Lawful basis: performance of a contract with you
Administering our operations and business
Type of Data: Transactional, financial, contractual, technical, usage date
- managing risk exposure and financial position
- stress testing our systems and controls
- reviewing an improving our processes
- collect and recover money owed to us
- test new products
Lawful basis: performance of a contact with you, legal obligation, complying with rules and guidance from regulators, to be innovative and develop new products
Managing risk, financial crime prevention, responding to regulatory requirements and legal claims
Type of Data: Transactional, financial and identity
- To detect, investigate, report and seek to prevent financial crime
- To manage risk for us and our customers
- To be compliant with applicable laws and regulations
- To respond to complaints and seek to resolve them
- Submitting information to regulators for investigatory purposes
Lawful basis: public interest, legal obligation, complying with rules and guidance from regulators, prevent fraud, money laundering and financial crime
Type of Data: Contact, consents, technical, behavioural and communication
- Develop and carry out marketing activities
- Guidance about products
Lawful basis: Learn and understand what our clients’ needs are, to be innovative and develop new products and explore new segments
How do we collect and store information from you?
HOB uses tracking technology such as cookies or tags to gather information as outlined above (see sections: "What information do we collect from and the lawful basis for processing personal information?") to understand how visitors use the HOB Website.
Tracking technology helps us manage and improve the usability of the HOB Website, for example by detecting whether there has been any contact between your computer and us in the past and to identify the most popular sections of the HOB Website.
When you save your cookie settings, they should also apply to your future visits to the HOB Website. However, for technical reasons beyond HOB’s control, this cannot be guaranteed. For example, if you reset your browser, delete your cookies or access the HOB website from another browser or device your cookie settings may be lost. To comply with applicable laws and regulations, in some countries you may be asked to confirm your cookie settings when you first visit the HOB Website. If you are in a country where you are automatically required to set your cookie settings, you may be asked to set them again on a future visit.
In many cases you can also control tracking technologies using your browser. Please ensure that your browser setting reflects whether you wish to be warned about and/or accept tracking technologies (such as cookies) where possible. The specific capabilities of your browser and instructions on how to use them can usually be found in the manual or help file of your browser.
Refusing, disabling or deactivating of tracking technologies may result in a reduced availability of the services provided by the HOB Website or parts of the HOB Website may no longer function correctly.
To whom do we disclose your information collected from the HOB Website?
We may disclose your personal information to the following categories of recipients:
- To our affiliates, agents, third party service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our website), or who otherwise process personal information for purposes that are described in this Statement or notified to you when we collect your personal information.
- To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
- To a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Statement.
- To any other person with your consent to the disclosure.
Our affiliates, agents and third-party service providers who have access to personal data obtained through the HOB Website are obliged to respect privacy.
When transferring personal data internationally we make sure that we comply with applicable laws and regulations, for example, by entering into agreements which will ensure that the recipients of your information maintain an adequate level of data protection.
What are your rights as a data subject?
At any point whilst HOB is in possession of or processing your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that HOB refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
What information you can request?
- Identity and the contact details of the person or organisation (HOB) that has determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of HOB or a third party such as one of its clients, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (ICO).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What security measures have we implemented to protect your information collected through the HOB Website?
HOB has implemented reasonable technical and organisational security measures to protect and safeguard your personal data collected by HOB via the HOB Website against unauthorized access, misuse, loss or destruction. All data collected is held in the United Kingdom using multiple servers. HOB does not store your personal data outside the EEA.
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. In particular, we:
- Hold personal information in secure facilities and where the information is held electronically, on secure servers.
- Use encrypted transmission links whenever we can
- Use other safeguards such as firewalls, authentication systems (e.g., passwords), and access control mechanisms to control unauthorised access to systems and data.
- Regularly review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
- Restrict access to personal information to our employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations.
How do we treat electronic messages sent to and from HOB?
All electronic messages sent to and from HOB are automatically retained in a distinct journaling system which preserves the evidential weight of the e-mails. They are protected by reasonable technical and organisational measures and may only be accessed in justified cases in line with applicable laws and regulations (e.g. court order, suspicion of criminal conduct, violation of regulatory obligations, material breach of employment contract) to specific persons in defined functions (e.g. Legal, Compliance, Risk). Every step of the process, as well as the search criteria used, are logged in an audit trail. All emails are disposed of after the applicable retention period has expired.
What should you consider when sending data over the Internet?
The Internet is generally not regarded as a secure environment, and information sent via the Internet (such as to or from the HOB Website or via electronic message) may be accessed by unauthorized third parties, potentially leading to disclosures, changes in content or technical failures. Even if both sender and receiver are located in the same country, information sent via the Internet may be transmitted across international borders and be forwarded to a country with a lower data protection level than exists in your country of residence.
Please note that we accept no responsibility or liability for the security of your information whilst in transit over the Internet to HOB. In order to protect your privacy, we would like to remind you that you may choose another means of communication with HOB, where you deem it appropriate.
How long do we hold your personal data?
Your personal information will be retained for as long as it is necessary to carry out the purposes set out in this Statement (unless longer retention is required by law). However, we will not retain any of your personal information beyond this period and the retention of your personal information will be subject to periodic review. We may keep an anonymised form of your personal information, which will no longer refer to you without time limits, to the extent that we have a legitimate and lawful interest in doing so.
How do we deal with information from individuals under the age of 18?
The HOB Website does not seek to collect personal data from individuals under the age of 18. Individuals under the age of 18 should receive permission from their parent or legal guardian before providing any personal data to HOB on the HOB Website.
How can you access or review your personal data?
You may, where permitted by applicable law or regulation:
- check whether we hold your personal data,
- ask us to provide you with a copy of your personal data, or
- require us to correct any of your personal data that is inaccurate.
Should you have a request regarding the processing of your personal data please send a letter to the following address:
Data Protection Officer
House of Borse Limited
33 Cavendish Square
Last update in May 2018.