LAST UPDATED: 25/07/2023
Etrading Software Ltd (we, us, our or ETS), the owner and operator of www.etradingsoftware.com (Website), is committed to protecting and respecting your privacy.
We collect personal information from you in the following ways:
Personal information you give to us:
When you order services and/or solutions from us, contact us or enquire about our services and/or solutions and interact with and post comments on our Website, we may collect personal information about you, including:
Personal information we collect about you:
We may automatically collect information about your use of the Website, such as the number and duration of visits to the Website and details of which particular pages have been visited. We will anonymise this information so that it is not attributable to you (Anonymised Information).
We may also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform as well as cookie information (Technical Information). Please see our Cookies Policy for further information.
We use any collected Technical Information and Anonymised Information to analyse how the Website is functioning and how it is used by users, for insight purposes and to help us maintain and improve the Website on an ongoing basis.
In relation to your personal information that we process as a controller, data protection law requires us to have a valid reason to process it for each of the different purposes for which we use that information. The law refers to each reason as a ‘lawful basis’. The purposes for which we use your personal information and the lawful basis on which we rely to process it for each purpose is as follows:
Where you have provided CONSENT
We may use and process your personal information where you have consented for us to do so for the following purposes:
You may withdraw your consent for us to use your information in any of these ways at any time. Please see paragraph 10 (Your Rights) for further details.
Where necessary to comply with our LEGAL OBLIGATIONS
We will use your personal information to comply with our legal obligations:
Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:
Processing necessary for us to promote our business and measure the reach and effectiveness of our campaigns
Processing necessary for us to respond to changing market conditions and the needs of our customers
Processing necessary for us to provide our services to your employer
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
Processing necessary for us to publish meaningful content on the Website for our users
Where necessary for us to carry out PRE-CONTRACT STEPS you have requested or for the performance of our CONTRACT
We will use your personal information where this is necessary for us to perform our contract with you or to carry out any pre-contract steps you’ve asked us to so that you can enter into that contract, for the following purposes:
We may disclose your information to our third party service providers, agents and subcontractors (Suppliers) for the purposes set out above. Our Suppliers can be categorised as follows:
Recipient / relationship to us
Industry sector (& sub-sector)
Advertising, PR, digital and creative agencies
Media (Advertising & PR)
Cloud software system providers, including database, email and document management providers
IT (Cloud Services)
Facilities and technology service providers including scanning and data destruction providers
IT (Data Management)
Insurers and insurance brokers
Insurance (Underwriting & Broking)
Legal, security and other professional advisers and consultants
Professional Services (Legal & Accounting)
National competent authority
Market and customer research providers
Media (Market Research)
Social media platforms
Media (Social Media)
Website and data analytics platform providers
IT (Data Analytics)
Website and app developers
IT (Software Development)
Website hosting services providers
When sending your information to third parties, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
When we share your personal information with any third parties that are controllers of that information, they may disclose or transfer it to other organisations in accordance with their data protection policies. This does not affect any of your data subject rights as detailed below. In particular, where you ask us to rectify, erase or restrict the processing of your information, we take reasonable steps to pass this request on to any such third parties with whom we have shared your personal information.
We may disclose your personal information to other third parties as follows:
All information you provide to us may be transferred to countries outside the UK. By way of example, this may happen where any of our servers or those of our third-party service providers are from time to time located in a country outside of the UK. These countries may not have similar data protection laws to the UK and so may not protect the use of your personal information to the same standard.
If you use our services whilst you are outside the UK, your information may be transferred outside those territories in order to receive those services.
If we collect your personal information, the length of time for which we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 6 years after the date it is no longer needed by us for any of the purposes listed under paragraph 3 (How and why we use your personal information) above. The only exceptions to this are where:
We employ security measures to protect the personal information you provide to us, to prevent access by unauthorised persons and unlawful processing, accidental loss, destruction and damage.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do everything possible to protect your personal information, we cannot guarantee the security of any personal information during its transmission to us online. You accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we are at fault.
In addition, if you linked to the Website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 1 calendar month from either:
You have the following rights, some of which may only apply in certain circumstances:
To have your information corrected if it is inaccurate and to have incomplete personal information completed
To object to processing of your personal information
To withdraw your consent to processing your personal information
To restrict processing of your personal information
You may ask us to restrict the processing of your personal information in the following situations:
· where you believe it is unlawful for us to do so; or
· you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.
In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
To have your personal information erased
To request access to your personal information and how we process it
To electronically move, copy or destroy your personal information in a standard, machine-readable form
Where we rely on your consent as the lawful basis for processing your personal information or need to process it in connection with a contract in place directly with you, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Rights relating to automated decision making, including profiling
To complain to a data protection regulator
You have the right to complain to a data protection regulation (which in the UK is the Information Commissioner’s Office (ICO)) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.
If you wish to write to us, please write to Etrading Software Ltd, 107 Cheapside, London, EC2V 6DN, United Kingdom
Our email address for data protection queries is firstname.lastname@example.org alternatively you can contact us via the Website.
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