This Policy is a legally binding agreement between you (“User”, “you” or “your”) and Limehouse Markets (Global) Limited (doing business as “Invaxa”, “we”, “us” or “our”). If you are entering into this agreement on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this agreement, you must not accept this agreement and may not access and use the Services. By accessing and using the Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
Automatic collection of information
When you open the Website or use the Mobile Application, our servers automatically record information that your browser or device sends. This data may include information such as your device’s IP address and location, browser and device name and version, operating system type and version, language preferences, the webpage you were visiting before you came to the Services, pages of the Services that you visit, the time spent on those pages, the information you search for on the Services, access times and dates, and other statistics.
Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Services. This statistical information is not otherwise aggregated in such a way that would identify any particular User of the system.
Collection of personal information
You can access and use the Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered on the Services, you may be asked to provide certain Personal Information (for example, your name and e-mail address).
We receive and store any information you knowingly provide to us when you create an account, make a purchase, or fill any forms on the Services. When required, this information may include the following:
- Account details (such as full name, username, unique user ID, password, etc.)
- Contact information (such as email address, phone number, fax etc.)
- Basic personal information (such as gender, age, place of birth, citizenship, country of residence, etc.)
- Proof of residence (such as residential address and supporting documentation etc.)
- Proof of identity (such as a copy of a government ID, passport or driver’s license)
- Payment and other financial information (such as credit card details, bank details, tax ID, information about your income and wealth, source of funds etc.)
- Authentication data (e.g., signature)
- Geolocation data of your device (such as latitude and longitude)
- Trading performance, knowledge and experience
- Trading account balances, trading activity, your inquiries and our responses
- Information on whether you or close members of your family hold a prominent public function (PEPs)
- Certain features on the mobile device (such as contacts, calendar, gallery, etc.)
- In case of a legal entity the corporate documentation (such as statutory/incorporation documents and all the relevant documentation for related individuals)
- Information about other individuals (such as your family members, friends, etc.)
- Periodically and subject to the characteristics of each client, we may also require provision of other information to improve the services performed and satisfy the regulatory requirements
- Any other materials you willingly submit to us (such as articles, images, feedback, etc.)
We obtain this information in several ways through your use of our Services, including through any of our websites, apps, the account registration applications, our demo registration forms, webinar registration forms, subscribing to news updates and from information provided in the course of ongoing customer service communications. We may also collect this information about you from third parties such as through publicly available sources. We also keep records of your trading behaviour, including records regarding the following:
- products you trade with us and their performance
- historical data about the trades and investments you have made including the amount invested
- your preference for certain types of products and services
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 business relationship with you. These recordings will be our sole property and will constitute evidence of the communications between us. Such communications 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 may record your image.
You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features on the Services. Users who are uncertain about what information is mandatory are welcome to contact us at [email protected].
Personal Information is kept in personnel files or within our Human Resources systems. We have a separate employee non-disclosure agreement for employees, which will be provided to you upon being recruited. The following types of data may be held by us, as appropriate, on relevant individuals:
- name, address, phone numbers, date of birth, email address, gender, marital status, etc.
- CVs, academic certificates and other information gathered during recruitment
- references from former employers
- National Insurance numbers
- Criminal conviction data
- job title, job descriptions and pay grades
- conduct issues such as letters of concern and disciplinary proceedings
- internal performance information
- medical or health history/information
- tax identification information
- terms and conditions of employment
- training details
We may further ask for other Personal Information as we may consider necessary for the purposes of recruitment. If you are unsuccessful in obtaining employment, we will seek your consent to retaining your data in case other suitable job vacancies arise in the Company for which we think you may wish to apply. You are free to withhold your consent to this and there will be no consequences for withholding consent.
We do not knowingly collect any Personal Information from minors under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website or Services. If you have reason to believe that a minor under the age of 18 has provided Personal Information to us through the Website or Services, please contact us to request that we delete that minor’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Services without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.
Use and processing of collected information
We act as a data controller and a data processor when handling Personal Information unless we have entered into a data processing agreement with you, in which case you would be the data controller and we would be the data processor.
Our role may also differ depending on the specific situation involving Personal Information. We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Services. In such instances, we are a data controller because we determine the purposes and means of the processing of Personal Information.
We act in the capacity of a data processor in situations when you submit Personal Information through the Services. We do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller.
In order to make the Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:
- Create and manage user accounts
- Fulfill and manage orders
- Deliver products or services
- Improve products and services
- Send administrative information
- Send marketing and promotional communications
- Send product and service updates
- Respond to inquiries and offer support
- Request user feedback
- Improve user experience
- Post customer testimonials
- Deliver targeted advertising
- Administer prize draws and competitions
- Enforce terms and conditions and policies
- Protect from abuse and malicious users
- Respond to legal requests and prevent harm
- Run and operate the Services
Processing your Personal Information depends on how you interact with the Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. We may also combine or aggregate some of your Personal Information in order to better serve you and to improve and update our Services.
Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
In case of Services requiring payment, you may need to provide your credit card details or other payment account information, which will be used solely for processing payments. We use third-party payment processors (“Payment Processors”) to assist us in processing your payment information securely.
Payment Processors adhere to the latest security standards as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. Sensitive and private data exchange happens over an SSL secured communication channel and is encrypted and protected with digital signatures, and the Services are also in compliance with strict vulnerability standards in order to create as secure of an environment as possible for Users. We will share payment data with the Payment Processors only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds.
Please note that the Payment Processors may collect some Personal Information from you, which allows them to process your payments and handle all the steps in the payment process through their systems, including data collection and data processing. Where necessary, your financial information will be stored in encrypted form on secure servers of our Payment Processors. The Payment Processors’ use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies.
We may also ask you to permit us to collect data about you from third-party providers to verify your identity, do a credit check and prevent fraud or assess risk. This helps us ensure that you are using our Services legally, that you are eligible for the Services you want to use, and to protect your data and our Services from fraudsters who may put you and your money at risk.
You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described below.
Disclosure of information
Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your information with our partners, affiliates, contracted companies, and service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. We will not share any information with unaffiliated third parties.
Service Providers are not authorised to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorise them to use or disclose any of the provided information for their own marketing or other purposes. We will share and disclose your information only with the following categories of Service Providers:
- Advertising networks
- Partnership and Affiliate programs
- Cloud computing services
- Communication and collaboration services
- Data analytics services
- Data storage services
- Financial services
- Government agencies
- Order fulfillment services
- Payment processors
- Performance monitoring services
- Product engineering and design services
- Sales and marketing services
- User authentication services
- Website hosting service providers
We may also disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and your Personal Information will likely be among the assets transferred.
Retention of information
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, as long as your user account remains active, to enforce our agreements, resolve disputes, and unless a longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
Our Services use “cookies” to help personalise your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. If you choose to decline cookies, you may not be able to fully experience the features of the Services. Click here to learn more about cookies and how they work.
Do Not Track signals
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information.
We may permit certain third-party companies to help us tailor advertising that we think may be of interest to Users and to collect and use other data about User activities on the Services. These companies may deliver ads that might place cookies and otherwise track User behaviour.
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilising a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.
All e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.
We offer push notifications to which you may also voluntarily subscribe at any time. To make sure push notifications reach the correct devices, we use a third-party push notifications provider who relies on a device token unique to your device which is issued by the operating system of your device. While it is possible to access a list of device tokens, they will not reveal your identity, your unique device ID, or your contact information to us or our third-party push notifications provider. We will maintain the information sent via e-mail in accordance with applicable laws and regulations. If, at any time, you wish to stop receiving push notifications, simply adjust your device settings accordingly.
Partner and Affiliate links
We may engage in partner and/or affiliate marketing and have partner and/or affiliate links present on the Services for the purpose of being able to offer you related or additional products and services. If you click on a partner and/or affiliate link, a cookie will be placed on your browser to track any sales for purposes of commissions.
Link to other resources
The Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Services and to read the privacy statements of each and every resource that may collect Personal Information.
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorised access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
As the security of Personal Information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.
In the event we become aware that the security of the Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When we do, we will send you an email.
Changes and amendments
We reserve the right to modify this Policy or its terms related to the Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorised to access or use the Services.
We may disclose your Personal Information as required by rules and regulations and when we believe that disclosure is necessary to protect our rights and/or to comply with any proceedings, court order, legal process served or pursuant to governmental, intergovernmental, or other regulatory bodies. We will not be liable for misuse or loss of Personal Information or otherwise on Website or Service that we do not have access to or control over. We will not be liable for unlawful or unauthorised use of your Personal Information due to misuse or misplacement of your passwords, negligent or malicious intervention and/or otherwise by you or due to your acts or omissions or a person authorised by you (whether that authorisation is permitted by the terms of our legal relationship with you or not).
Contacting us / Opt-out
If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below. If you do not want us to use your Personal Information, you must inform us by sending an email using the details below. If you decide to do so, we may not be able to continue to provide the Services requested by you and we will have no liability to you in this respect.
Contact email: [email protected]
We will attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.
This document was last updated on March 30, 2022