Who we are

TransFICC Limited ('we' or 'us') are a 'controller' for the purposes of the UK GDPR regime comprised of the Retained Regulation (EU) 2016/679 ('UK GDPR’) and the Data Protection Act 2018 and any subsequent UK data protection legislation and we are responsible for, and control the processing of, your personal information.

Who does this privacy apply to?

This privacy policy applies to visitors of this website and any individuals whose personal information we process during the course of business, which includes:

• Our prospective customers and recipients of our marketing communications;
• Our customers (contacts);
• Our suppliers, service providers, agents, and subcontractors; and
• Applicants for job vacancies.

This policy does not apply to individuals who create an account with us to use our One API for eTrading on behalf of their employer/principal. We process that data on behalf of the employer/principal and such individuals should refer to their employer/principal (who is the ‘controller’) for details on how their data is processed.

If you are unsure how this policy applies to you, please contact us (see ‘How to contact us’ below) and we will be happy to help.

What information do we collect and process?

Personal information provided by you

During the course of accessing our website, using our products and services, job applicant process, contacting us, providing services to us, or otherwise dealing with us, you may provide us with a range of personal data which we will use in the course of our business. This personal information may include:

• Your name or another unique identifier;
• Your address;
• Your contact details (which may include your landline telephone number, mobile number, and/or email address);
• Payment or other financial details (e.g. payment card information, bank information);
• Professional information (e.g. job title and/or type, professional qualifications, industry); and
• Other related information.

Information we collect automatically

Our website and services may collect certain information about you automatically (such as your IP address, geographical location, browser type and version, operating system, referral source, length of visit and number of page views).

Personal information provided by third parties

Occasionally we may receive information about you from other sources (such as our suppliers, customers, recruitment agencies and your referees (in the case of job applicants) or group companies), which we will add to the information we already hold about you in order to help us operate our business effectively.

Personal information about other individuals

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

• transfer the personal data and give consent on his/her behalf to the processing of his/her personal data;
• receive on his/her behalf any data protection notices;
• give consent to the transfer of his/her personal data abroad; and
• give consent to the processing of his/her sensitive personal data (if applicable)

How do we use your data and our legal basis for processing your data

We may process your data for a variety of reasons, including because:

• we are legally obliged to e.g. to confirm your identity;
• the processing is necessary for the performance of the contract with you to provide our services or to enter into an employment contract with you; or
• it is in our legitimate business interests to do so.

In some instances, we will rely on your consent to process personal data and where we do this, it will be flagged to you at the time.

Our main processing activities for personal data, and the legal basis on which we perform those activities are:

Prospective customers / marketing recipients:

We rarely use personal data to market our services but where we do, we will process your personal data in order to contact you in relation to our products and services and keep a record of our communications (e.g. sales telephone calls, quotations and offers).

Our legal basis for doing so is:

• consent, which you will have given when you provided the personal data to us or one of our suppliers. You can withdraw this consent at any time by following the instructions in our communications or by contacting us; or
• our legitimate interests, which allows us to market our products and services to individuals provided there is a business case for doing so and our interests do not override the rights of the individuals in question. If you wish to object to direct marketing, you may do so by contacting us.

Customer:

We will process your personal data in order to provide our products/services to you and to provide you with information and updates regarding the same. Our legal basis for doing so is that the processing is necessary for the performance of a contract. We will also keep a record of your data and use it for related purposes, including corporate account management, customer support, and audit purposes, on the basis that we have a legitimate interest in doing so.

We may also contact you in relation to our products and services. Our legal basis for doing so will be the same as for prospective customers, as set out above.

Suppliers, service providers etc.:

We will process your personal data in order to receive goods and/or services from you and to manage our relationship, including making payments to you, dealing with accounts issues, placing orders etc. Our legal basis for doing so is that the processing is necessary for the performance of a contract.

Applicants for job vacancies:

We will process your personal data for the purposes of considering your application or CV, your interview with us and the selection process in order to recruit staff for our business. Our legal basis for doing so will primarily be that it is necessary for our legitimate interests, which will allow us to consider and evaluate applicants for the vacancies. If successful, we may need to process your personal data for the purposes of entering into an employment or consultancy contract with you.

Other processing activities

Monitoring and recording communications

We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of training, fraud prevention, and/or quality assurance. We may also retain copies of communications and details provided to us by you, for example support requests, account queries, complaints, for internal account management and auditing purposes. This is done on the basis of legitimate interests.

Credit checking

We may do a credit check on you:

• so that we can make credit decisions about you and your business; and
• to prevent and detect fraud and money laundering.

Our search will be recorded on the files of the credit reference agency.

We may also disclose information about how you conduct your account to credit reference agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked.

Other credit businesses may use your information to:

• make credit decisions about you and the people with whom you are financially associated
• trace debtors, and
• prevent and detect fraud and money laundering.

If you provide false or inaccurate information to us and we suspect fraud, we will record this.

Storage of your information and who your information might be shared with

We process your personal data on servers based inside and outside the UK/EEA. For further details of where we store your personal data specifically, please contact us.

We may disclose your personal data to:

• other companies within our group to the extent that there is a legitimate interest in doing so to support our business aims;
• our agents and service providers, to the extent that they require access to the data in order to provide goods/services to us, in which case they will be bound by a contract requiring them to process personal data in accordance with the requirements prescribed by data protection law;
• law enforcement agencies in connection with any investigation to help prevent unlawful activity; and
• a third party purchaser if we sell our business, in which case, customer and user information will be a transferred asset.

Keeping your data secure

We will use technical and organisational measures to safeguard your personal data, for example:

• we store your personal data on secure servers; and
• we are certified to ISO 27001. These standards helps us manage your information and keep it safe and secure.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see ‘How to contact us’ below).

What can I do to keep my data safe?

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Transfers of your data out of the EEA

We may need to transfer your personal data outside the European Economic Area (for example to our hosting suppliers). We will only do this if appropriate safeguards are place in accordance with data protection legislation. Any transfer of your data will be subject to a contract that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

How long do we keep your personal information?

We keep your personal information for as long as we need to for the purposes for which it was collected or (if longer) for any period for which we are required to keep personal information to comply with our legal and regulatory requirements.

What rights do you have?

You are responsible for ensuring that information you provide to us is accurate, complete and up-to-date. You can review and change your information by contacting us.

You have a number of rights in relation to your personal data, these include the right to:

• find out how we process your data;
• request that your personal data is corrected if you believe it is incorrect or inaccurate;
• obtain restriction on our, or object to, processing of your personal data;
• if we are relying on consent, you can withdraw your consent to our processing of your personal data (including any direct marketing);
• obtain a copy of the personal data we process concerning you. We will take steps to verify your identity before responding to your request. Once we have verified your identity we will respond as soon as possible and in any event within one month.
• lodge a complaint with the UK supervisory body, the Information Commissioner’s Office (the ICO) here https://ico.org.uk/. If you have a concern or complaint about the way we handle your data, we ask that you contact us in the first instance to allow us to investigate and resolve the matter as appropriate.

• if we are relying on legitimate interests for direct marketing, you can object to receiving such direct marketing;

If you would like to exercise any of your rights or find out more, please contact us.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time, and if we do so we will highlight any changes to these pages. If you continue to access or use our services after notified changes have come into effect, you will have agreed to the revised policy.

How to contact us

Please contact us if you have any questions about this privacy policy or the information we hold about you.

If you wish to contact us, please send an email to emailing [email protected]

Cookies

We use cookies on this website. A cookie is a text file sent by a web server to a web browser, and stored by the browser. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
We may send a cookie, which may be stored by your browser on your computer's hard drive. We may use the information we obtain from the cookie in the administration of this website, to improve the website's usability and for marketing purposes. We may also use that information to recognise your computer when you visit our website, and/or to personalise our website for you.

Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookies by clicking 'Tools', 'Internet Options', 'Privacy', and selecting 'Block all cookies' using the sliding selector.) This will, however, have a negative impact upon the usability of many websites.

We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google's privacy policy is available at: http://www.google.com/privacypolicy.html.