Privacy | Reactive Markets

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Privacy Policy

Scope

Your privacy is important to us, and this Privacy Notice explains how we collect and use your personal data.

This Privacy Notice applies to all personal data collected or processed by Reactive Markets Limited, Reactive Markets Technologies Limited, Reactive Markets LLC and Reactive Markets Technologies LLC (together, “Reactive Markets”), including that of individuals at clients or potential clients of ours and users of our websites and our services in respect of whom we hold personal data. This Privacy Notice is part of every agreement or terms we have in place with you. If there is a difference between this Privacy Notice and any agreement or terms, this Privacy Notice takes priority.

This Privacy Notice sets out how Reactive Markets complies with applicable laws relating to privacy, data protection and information security, including but not limited to:

the UK General Data Protection Regulation UK Data Protection Act 2018 and to the extent it handles the personal data of EU persons the EU General Data Protection Regulation;
the applicable US federal and state laws and regulations, including the Gramm-Leach- Bliley Act, the California Consumer Privacy Act (as amended by the California Privacy Rights Act), state data breach notification laws, and any binding regulatory guidance,

together referred to as “Applicable Data Protection Rules”.

“Personal data” is any information relating to an identified or identifiable natural person.

Processing includes but is not limited to collecting, storing and using personal data. Reactive Markets is predominantly a data controller for the purposes of Applicable Data Protection Rules but may also process personal data. We are responsible under Applicable Data Protection Rules for how we collect, use, store and protect personal data about you.

Data collection

We may collect, use, and store personal data in respect of clients and investors (actual or proposed) and third parties or contractors providing services to Reactive Markets.

Almost all of the personal data we collect is collected when you interact directly with us, for example when you communicate with or through us in relation to our services. There may be other circumstances in which we receive your personal data, such as from third parties in accordance with their terms and conditions and privacy policies.

The types of personal data we collect depend on the services you have with us, and your use of our website and Switchboard.

Processing your personal data

We will only collect and process your personal data when Applicable Data Protection Rules allow us to, for example in the following circumstances:

where we have your consent to do so;
where we need to comply with legal and regulatory obligations;
for our legitimate business purposes as permitted by law, including in providing services to you (or your employer or a company related to you or those of a third party) or assessing your suitability for a role;
for the purposes communicated to you at the time of collection or in your agreement(s) with us and in this Privacy Notice;
where we need to perform a contract which we have entered into with you;
to verify your identity, authenticate you and investigate your personal background, as permitted by law;
to assess your eligibility for our services;
to communicate features and other information about our services;
to help us understand the interests of our current and prospective clients and to improve our products and services;
to ensure we can act on your instructions (e.g. keeping records of communications including conversations);
to manage risks and operations;
to prevent and detect fraud and suppress financial abuse;
to establish, exercise or defend legal claims or proceedings; and
to protect client and employee safety, and to protect against theft and property damage in and around physical premises.

Your rights

We uphold your rights in relation to your personal data in accordance with and subject to our legal obligations under Applicable Data Protection Rules and other applicable laws, i.e.:

your right to be informed;
your right of access;
your right to rectification of inaccurate personal data;
your right to erasure;
your right to restrict processing;
your right to data portability;
your right to object; and
your rights in relation to automated decision making and profiling.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us at privacy@reactivemarkets.com in the first instance.

Data security

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 and on whom we have performed the necessary due diligence. They will only process your personal data on our instructions and they are subject to a duty of confidentiality in respect of your personal data.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of such a breach where we are legally required to do so.

Data retention

We will only retain your personal data for as long as necessary in compliance with Applicable Data Protection Rules (including retention periods specified) to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements. Details of retention periods for different aspects of your personal data are available in our data retention policy which you can request from us by contacting us.

International transfer

If we transfer your personal data out of the UK or European Economic Area ( EEA), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data under Applicable Data Protection Rules;
where we use certain service providers, we may use specific contracts approved under Applicable Data Protection Rules which give personal data the same protection it has in the UK/Europe;
where we use providers based in the US, we may transfer personal data to them if they are part of the EU-US Data Privacy Framework or UK-US Data Bridge (as defined under Applicable Data Protection Rules, and as updated from time to time), which requires them to provide similar protection to personal data shared between UK/Europe and the US, or if they are otherwise subject to contractual provisions that require them to provide such similar protection.

Links to other sites

The Reactive Markets website/s may contain links to websites operated and maintained by third parties over which we have no control. Privacy policies on such linked websites may be different from our Privacy Notice. You access such linked websites at your own risk. We encourage you to review the privacy policy of any such linked website you visit to understand that website’s collection, storage and use of your information.