Privacy Policy

This privacy policy applies to the processing activities of TTG (as defined below).

As part of our day-to-day business we need to collect personal information from our professional traders and potential professional traders to ensure that we can meet their needs and provide them with information about our services. Your privacy is important to us and it is our policy to respect the confidentiality of information and the privacy of individuals.

This policy outlines how we manage your personal information supplied to us by you or a third party in connection with our provision of services to you or which we collect from your use of our services and/or website(s). It also details your rights in respect of our processing of your personal information. Our privacy policy will be reviewed from time to time to take account of new obligations and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment.

Any personal information we hold will be governed by our most current privacy notice.

WHO ARE WE?

The two primary entities within the TTG Group are:

• TTG Capital Limited of Second Floor, 30 Old Broad Street, London, EC2N 1HT  (registration number 10575233) and who is registered with the Financial Conduct Authority (FCA) with reference number: 780342 and registered with Information Commissioner under No. ZA463290); and

·       Tower Trading Group Limited, of Second Floor, 30 Old Broad Street, London, EC2N 1HT  (registration number 06733944) and registered with Information Commissioner under No. ZA211437), (together “TTG”).

TTG provides global infrastructure and clearing related services in exchange traded futures and options markets and is the data controller of your personal information in relation to those services.

Please note that if you are a TTG professional trader, employee, a contractor to TTG or a third party service provider, your personal information will be used in connection with your trading agreement, employment contract, your contractual relationship or in accordance with our separate policies which are available by contacting us. Any reference to ‘us’, ‘our’, ‘we’ or ‘TTG’ in this privacy notice is a reference to each group company within the TTG Group as the context requires unless otherwise stated. Similarly, any reference to ‘you’, ‘your’, ‘yours’ or ‘yourself’ in this privacy notice is a reference to any of our professional traders  and potential professional traders  as the context requires unless otherwise stated.

WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?

If you are an actual professional trader or potential professional trader, we may collect the following types of information about you (and related information about any personal service company that you use):

• name, address and contact details
• date of birth and gender
• in certain cases, information about your income and wealth including details about your assets and liabilities, account balances, trading statements, tax and financial statements
• profession and employment details
• location data
• any other similar information.

We obtain this information in a number of ways through your use of our services or other dealings with us including through the TTG website, the trader services and compliance on-boarding process, marketing sign up forms, subscribing to news updates and from information provided in the course of ongoing professional trader service correspondence. We may also obtain personal information about you through your use of our websites or through the use of cookies on our websites and, in particular by recording which pages you look at on our websites.

We may ask for other personal information voluntarily from time to time (for example, through market research or surveys). If you choose not to provide the information we need to fulfil your request for a specific product or service, we may not be able to provide you with the requested product or service. We may record any communications, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our relationship with you. These recordings will be our sole property and will constitute evidence of the communications between us. Such telephone conversations may be recorded without the use of a warning tone or any other further notice. Further, if you visit any of our offices or premises, we may have CCTV which will record your image.

WHO MAY WE DISCLOSE PERSONAL INFORMATION TO?

As part of using your personal information for the purposes set out above, we may disclose your information to:

• other companies within the TTG Group who provide compliance, risk, financial and other back office services
• service providers and specialist advisers who have been contracted to provide us with administrative, IT, financial, regulatory, compliance, insurance, research or other services
• marketing partners for joint events, initiatives and promotions including but not limited to Exchange Groups, ISVs, Market Data vendors, etc.
• credit providers, courts, tribunals and applicable regulatory authorities as agreed or authorised by law or our agreement with you
• anyone authorised by you.

Generally, we require that organisations outside the TTG Group who handle or obtain personal information acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with all relevant data protection laws and this privacy notice.

HOW DO WE OBTAIN YOUR CONSENT?

Where our use of your personal information requires your consent, such consent will be provided in accordance with the applicable term and conditions of use on our website or any other contract we may have entered into with you or as set out in our communication with you from time to time. If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time by contacting us using the contact details set out in this privacy notice.

MANAGEMENT OF PERSONAL INFORMATION

We always take appropriate technical and organisational measures to ensure that your information is secure. In particular, we train our employees who handle personal information to respect the confidentiality of professional trader information and the privacy of individuals. We regard breaches of your privacy very seriously and will impose appropriate penalties, including dismissal where necessary. Our Compliance team ensures that our management of personal information is in accordance with this privacy notice and the applicable legislation.

HOW DO WE STORE PERSONAL INFORMATION AND FOR HOW LONG?

Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, by mail, over the internet or any other electronic medium. We hold personal information in a combination of secure computer storage facilities and paper-based files and other records, and take steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. When we consider that personal information is no longer needed, we will remove any details that will identify you or we will securely destroy the records. However, we may need to maintain records for a significant period of time. For example, we are subject to certain anti-money laundering laws which require us to retain:

• a copy of the documents we used to comply with our professional trader due diligence obligations; and
• supporting evidence and records of transactions with you and your relationship with us, for a period of five years after our business relationship with you has ended.

If we hold any personal information in the form of a deed, we will hold this deed in its complete form for a period of 12 years after our business relationship with you has ended. If we hold any personal information in the form of a recorded communication, by telephone, electronic, in person or otherwise, this information will be held in line with local regulatory requirements which will either be 5 years or 10 years after our business relationship with you has ended. Where you have opted out of receiving marketing communications we may hold your details on our suppression list so that we know you do not want to receive these communications but we will not send you marketing communications.

HOW DO WE USE THE PERSONAL INFORMATION?

We may use personal information for the following purposes:

1. To verify your identity and establish and manage your account
   As part of providing services, or information about our services, to you, we will need to verify your identify to set you up as a professional trader and we will need to use those details in order to effectively manage your account with us to ensure that you are getting the best possible service from us.  This may include third parties carrying out credit or identity checks on our behalf.  It is not only in our legitimate interest to do so but the use of your personal information in this way is necessary for us to know who you are as we have a legal obligation to comply with certain Know Your Customer regulatory obligations (noting that in the case of TTG we do not have customers as that term is defined by the FCA and generally by UK legislation, but our legal and regulatory obligations require us to carry out the same identification checks on our professional traders and any potential professional trader).
2. To provide you with products and services, or information about our products and services, and to review your ongoing needs

Once you open an account with us, or subscribe to our website or webinar, we will need to use your personal information to perform our services and comply with our obligations to you. It is also in our legitimate interests to ensure that we are providing the most appropriate products and services so we may periodically review your needs to ensure that you are getting the benefit of the best possible products and services from us.

3. To help us improve our products and services, including professional trader services, and develop and market new products and services
   We may from time to time use personal information provided by you through your use of the services and/or through professional trader surveys to help us improve our products and services.  It is in our legitimate interests for us to use your personal information in this way to ensure that we provide you with the best products and services we can and to continue to be a market leader in our industry.
4. To investigate or settle enquiries or disputes
   We may need to use personal information collected from you to investigate issues and/or settle disputes with you as it is in our legitimate interests to ensure that issues and/or disputes get investigated and resolved as quickly and efficiently as possible.
5. To comply with applicable law, court order, other judicial process, or the requirements of any applicable regulatory authorities
   We may need to use your personal information to comply with applicable law, court order or other judicial process, or the requirements of any applicable regulatory authority.  We do this not only to comply with our legal obligations but because it may also be in our legitimate interest to do so.
6. Data analysis
   Our web pages and e-mails may contain web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence. Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. However where your personal information is not in an anonymised form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market.
7. Marketing by us
   We may use your personal information to send you marketing communications by email or phone or other agreed forms (including social media campaigns) to ensure that you are always kept up to date with our latest products and services. Where we send you marketing communications we will either do so as it is in our legitimate interest or with your consent.
8. Internal business purposes and record keeping
   We may need to process your personal information for internal business and record keeping purposes. Such processing is in our own legitimate interests and is required in order to comply with our legal obligations.  This may include any communications that we have with you in relation to the services we provide to you and our relationship with you.   We will also keep records to ensure that you comply with your obligations under any contract you have entered into with us.
9. Corporate restructuring
   If we undergo a corporate restructure or part or all of our business is acquired by a third party, we may need to use your personal information in association with that restructure or acquisition.  Such use may involve disclosing your details as part of a due diligence exercise. It is our legitimate interest to use your information in this way provided we comply with any legal obligation we have to you.
10. Security
    If you enter any of our premises we may record your image on our CCTV for security reasons.  We may also take your details to keep a record of who has entered our premises on any given day.  It is in our legitimate interest to do this to maintain a safe and secure working environment.

THE PERSONAL INFORMATION WE HOLD ABOUT YOU

The information about any rights that might be available to you in relation to the personal information we hold about you is set out below.

Rectification

If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

Erasure

You can ask us to delete or remove your personal information in certain circumstances such as where we no longer need it or you withdraw your consent (where applicable) provided that we have no legal obligation to retain that data. Such request will be subject to any retention limits we are required to comply with in accordance with applicable laws and regulations and subject to section 'How do we store personal information and for how long'.

Processing restrictions

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It will not stop us from storing your personal information though. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

Data Portability

Under the General Data Protection Regulation (679/2016), you have the right, in certain circumstances, to obtain personal information you have provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.

Objection

You can ask us to stop processing your personal information, and we will do so, except if we can demonstrate compelling legal grounds for the processing.

TRANSFERS OUTSIDE OF THE EUROPEAN ECONOMIC AREA

We may transfer your personal information outside the European Economic Area to other TTG Group companies as well as processors who are engaged on our behalf (‘Transferees’). To the extent we transfer your information outside the European Economic Area, we will ensure that the transfer is lawful and that there are appropriate security arrangements.

In order to transfer personal information to third parties in territories that do not have a finding of adequacy by the applicable authority and regulations, we enter into agreements with the Transferees ensuring appropriate and suitable safeguards based on standard contractual terms which are consistent with those adopted by the European Commission. Where we make transfers to Transferees in the US, we may in some cases rely on applicable standard contractual clauses, binding corporate rules, the EU-US Privacy Shield or any other equivalent applicable arrangements.

THE PERSONAL INFORMATION WE HOLD ABOUT YOU

For further information about any rights that might be available to you in relation to the personal information we hold about you, please refer to our website.

WHAT IS A COOKIE AND HOW DO WE USE COOKIES?

A cookie is a small piece of text stored on your computer or device when you visit a website. We use cookies on our websites to provide you with a more relevant and effective experience, including presenting web pages according to your needs or preferences. For further information about cookies and how we use cookies, please refer to our website.

TECHNOLOGY IMPROVEMENTS

We are constantly striving to improve functionality on this site through technology changes. This may mean a change to the way in which personal information is collected or used. The impact of any technology changes which may affect your privacy will be notified in this privacy notice at the time of the change.

LINKS TO THIRD PARTY WEBSITES

Our websites or our apps may have links to external third party websites. Please note, however, that third party websites are not covered by this privacy notice and those sites are not subject to our privacy standards and procedures. Please check with each third party as to their privacy practices and procedures.

WHAT IF YOU HAVE A COMPLAINT?

If you have a concern about any aspect of our privacy practices, you can make a complaint. This will be acted upon promptly. To make a complaint, please contact us via one of the methods set below. If you are not satisfied with our response to your complaint, you have the right to lodge a complaint with our supervisory authority, the Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

HOW TO CONTACT US

If you have any questions about this privacy notice or want to exercise your rights, please contact us by:

• phone on +44-20-7496-8930;
• email at compliance@ttg-capital.com; or  
• writing to the address provided in the “Who are we?” section of this privacy notice.

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