YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, age, nationality, photographs, gender, job title, Tax ID number, passport number, driver’s license details, national identity card details, photograph identification cards, and/or visa information.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.
- Transaction Data includes details about payments to and from you and other details of Services you have purchased from us, such as the name of the recipient, your name, the amount, and/or timestamp.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Interface and Services.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information provided to our support team, public social networking posts, authentication data, security questions, user ID, click-stream data and other data collected via cookies and similar technologies.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our Services;
- create an account on our Interface or Services;
- subscribe to our Services or publications;
- request marketing material or content to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Automated technologies/interactions and third party sources. We may automatically collect your personal information as you interact with our Interface (such as browsing actions, patterns, hardware model, device ID, operating system version, web-browser software and your Internet Protocol address/MAC address/device identifier). We may also receive your personal data from various third parties and public sources as required or permitted by applicable law (such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms).
PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA
We will only use your personal data within the limits allowed by law. Most commonly, with reference to the types of legal basis specifically outlined in the GDPR, we will use your personal data where:
- we need to perform the contract we are about to enter into or have entered into with you;
- it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
- we need to comply with a legal obligation.
Please see the below Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
We have set out below, in table format, a description of the ways we plan on using your personal data, and on what basis we do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of personal data||Lawful basis for processing, including basis of legitimate interest|
|To register you as a new user||Performance of a contract with you|
To deliver the Services including:
To deliver the Services including:
|To enable you to partake in a prize draw, competition or complete a survey|
|To administer and protect our business, this Interface and the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|
|To deliver relevant Interface and Services content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Necessary for our legitimate interests (to study how customers use our Services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Interface, Services, marketing, customer relationships and experiences||Necessary for our legitimate interests (to define types of users for our Services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To identify or verify you in order to comply with applicable laws such as anti-money laundering and terrorist financing laws|
|To make suggestions and recommendations to you about Services that may be of interest to you||Necessary for our legitimate interests (to develop our Services and grow our business)|
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you with respect to the Interface or the provision of the Services. Based on your communication preferences, we may send you marketing communications to inform you about our events or our partner events; to deliver targeted marketing and advertising; and to provide you with promotional offers based on your communication preferences.
INFORMATION SHARED WITH THIRD PARTIES
From time to time we may request your permission to allow us to share your personal data with third parties. We will only share your personal data with third parties who have a legitimate purpose for accessing it, particularly:
- We share your personal data with third party identity verification services in order to perform obligations under AML Laws, Anti-Bribery Laws, Sanctions Laws, CTF Laws, and other Applicable Laws;
- We share your personal data with service providers who provide consultancy, banking, legal, insurance and accounting services under contract and who help with parts of our business operations;
- We share your personal data with financial institutions with which we partner to process payments you have authorised;
- We share your personal data with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our user agreement or any other applicable policies.
You may opt out of having your personal data shared with third parties, or allowing us to use your personal data for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorisation. If you choose to do so, certain features of our Interface or Services may not be available to you.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Your personal data may be transferred, stored, and processed in any country in which we operate.
Data Subjects of the European Economic Area (“EEA”) Only:
Where we transfer your personal data outside of the EEA, this is done either on the basis that it is necessary for the performance of the contract between you and BTSE, or that the transfer is subject to the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and Decision 2010/87/EU as appropriate or, in the event that the transfer is to a US entity, we may transfer personal data if the transferee is part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
- Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe.
- Content that you post on our Interface such as support desk comments, photographs, videos, blog posts, and other content may be kept indefinitely after you close your account for audit and crime prevention purposes.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data, which include the right to:
- request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it;
- request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
- request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons (for example, for complying with the requirements of retaining certain personal data for a specific period of time under the Applicable Laws) which will be notified to you, if applicable, at the time of your request;
- object to 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s 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.
- 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. We will provide to you, or a third party you have chosen, 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 Services to you. We will advise you if this is the case at the time you withdraw your consent.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
You have the right to make a complaint at any time to the Information and Data Protection Tribunal (“Tribunal”). We would, however, appreciate the chance to deal with your matter internally before approaching the Tribunal.