1. Introduction

Your privacy is very important to us. We are committed to protecting and respecting your personal data. This Privacy Policy describes what types of personal data we collect about you when you choose to use our services, how we will use your personal data, when and with whom we share it and how we will keep it safe. It also details your rights in respect of our processing of your personal information and how you may exercise them. Please take the time to read and understand this policy.

Trade Online Group is authorised and regulated by the Financial Conduct authority with firm reference number 711715.
We may make changes to this Notice from time to time and it is important that you check this Notice for any updates. Any personal information we hold will be governed by the current privacy notice at the given time. If we make changes we consider to be important, we will communicate them to you.

Please note that this notice is addressed to customers and potential customers. If you are an Trade Online Group employee, a contractor to Trade Online Group or a third-party service provider, your personal information will be used in connection with your 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 ‘Trade Online Group’ in this privacy notice is a reference to each group company within the Trade Online 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 customers and potential customers as the context requires unless otherwise stated.

By accessing our websites, including using any of the communication channels to contact us, we consider that you have read and understood the terms of this notice and how we process any information you disclose to us including personal data prior to becoming a client. Once you open an account with us you agree that this notice, including any amendments, will govern how we collect, store, use, share and in any other form process your personal data and your rights during our business relationship and after its termination.

We may collect your personal information from third parties, including, for example, business partners, analytics providers, search information providers, credit reference agencies and third-party marketing companies or through publicly available sources.

Subject to applicable laws, we will monitor and record your calls, emails, text messages, app and digital communications, social media messages and other communications in relation to your dealings with us. We will do this for regulatory compliance, crime prevention and detection purposes, to protect the security of our communications systems and procedures, for quality control and staff training, and so we can provide you with a record of what’s been said when you require one. We will also monitor activities on your account where necessary for these reasons and this is justified by our legitimate interests or our legal obligations.

2. Why we collect your information

Trade Online Group collects your personal information in order to provide you with our products and services, to establish and manage your account and to comply with the law. By collecting your information, Trade Online Group is able to monitor and improve the services we offer to our existing and potential clients.

3. What Information Do We Collect and How??

We collect and use your personal data to the extent necessary for our activities and to provide high-quality individualized products and services.

Your “personal data” means any information about you that you have given to us, or third parties, in connection with a service or product offered whether through use of this web site, by phone, in person or in writing.

The data we use about you may either be directly provided by you or be obtained from other third-party sources to verify or enrich our databases.

The types of personal data that we may collect from you, includes:

  • identification information (e.g. name, ID card and passport numbers, nationality, place and date of birth, gender, photograph, IP address);
  • contact information (e.g. postal address and e-mail address, phone number);
  • employment information (e.g. employment, employer’s name);
  • banking, financial and transactional data (e.g. bank account details, credit card number, money transfers);
  • information related to your digital activities (e.g. IP address, browsing activity, geolocation etc.)
  • The full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to navigate away from the page, and any phone number used to call our customer service number
  • databases made available either through various third parties like business partners, business affiliates or authorised sub-contractors, marketing and advertising agencies and search information providers etc.

We may also use cookies or similar technologies to collect website usage information. More detailed information on the cookies and their use can be found under our Cookie Policy published on our website.

3.1 Joint applicants

You should only give us personal information about someone else (such as a joint applicant) with their permission. Where information is provided by you about someone else, or someone discloses information about you, it may be added to any personal information that is already held by us and it will be used in the ways described in this privacy notice. Sometimes, when you open a joint account or product, this may mean that your personal information will be shared with the other applicant. For example, transactions made by you will be seen by your joint account holder and vice versa.

4. Whom we share information
4.1 Sharing Information With Our Affiliates

We may share personal information described above with our affiliates for business purposes, such as, but not limited to, servicing customer accounts and informing customers about new products and services, or to aid in the trading activity of the company, its affiliates, or employees, and as permitted by applicable law. Our affiliates may include companies controlled or owned by us as well as companies that have an ownership interest in our company. The information we share with affiliates may include any of the information described above, such as your name, address, trading and account information. Our affiliates maintain the privacy of your information to the same extent Trade Online Group does in accordance with this Policy

4.2 Sharing Information With Third Parties

Trade Online Group does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with Trade Online Group, including those that provide professional, legal, or accounting advice to Trade Online Group. Non-affiliated companies that assist Trade Online Group in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that Trade Online Group dictates. Trade Online Group may aggregate data on an anonymous basis about its clients' trades and disclose such data to third parties.

We may also disclose your personal information to third parties to fulfill your instructions or pursuant to your expressed consent. We want you to know that Trade Online Group will not sell your personal information.

4.3 Legal Disclosure

Under limited circumstances, Trade Online Group may disclose your personal information to third parties as permitted by, or to comply with, applicable laws. For example, we may disclose personal information to cooperate with law enforcement agencies to comply with subpoenas or other official requests, and as necessary to protect our rights or property. Except as described in this privacy policy, we will not use your personal information for any other purpose, unless we describe how such information will be used at the time you disclose it to us or we obtain your permission.

4.4 Direct Marketing

Trade Online Group intends to use your personal information (other than sensitive information) for direct marketing investment products and services and we require your consent for that purpose. By applying for and/or opening a live or demo Trade Online Group account, you acknowledge and agree that your consent is voluntarily provided to us. If you do not wish to use your data for use in direct marketing as described in this policy, you may exercise your right to opt-out by notifying us in writing or by selecting/clicking the unsubscribe or opt-out link in the marketing emails we send you.

In regard to sensitive information, Trade Online Group will obtain the consent of the client before using or disclosing sensitive information for the purposes of direct marketing.

Where a client would not reasonably expect their personal information to be used for direct marketing, or the information has been collected from a third party, we may use or disclose this personal information for the purposes of direct marketing if the client has consented to the use or disclosure for this purpose (or if it is impracticable to seek this consent), and Trade Online Group has provided a means for opting out of direct marketing and the client has not chosen to opt out. We will include this opt out option/statement in each direct marketing communication.

Clients also have the right to contact us and request not to receive direct marketing communications, and for Trade Online Group not to disclose their personal information to other entities for the purposes of direct marketing, as well as request us to provide the source of the individuals personal information if is practicable or reasonable to do so.

4.5 International Transfer

Subject to certain conditions, we may transfer your personal information to a third party in countries outside the country you are residing for further processing in accordance with the purposes set out in this Privacy Policy. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

5. What rights do you have?

Your rights are as follows in respect of the personal information we hold about you:

  • The right to be informed about processing of your personal data;
  • The right to have your personal data corrected if it’s inaccurate and to have incomplete personal data completed;
  • The right to object to processing of your personal data;
  • The right to restrict processing of your personal data;
  • The right to have your personal data erased (the "right to be forgotten");
  • The right to request access to a copy of your personal data and information about how we process it. Please make all requests for access in writing (see how to contact us for details) and provide us with evidence of your identity;
  • The right to move, copy or transfer your personal data (“data portability”); and
  • Rights in relation to automated decision making including profiling.

Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request.

You can contact us by sending an email to info@tradeonline.org.uk. If you prefer to contact us via phone or by post, please refer to the section "contact us".

We will stop processing your personal data unless the processing is for the establishment, exercise or defence of legal claims or we have a legitimate business purpose or legal grounds for the processing.

6. How we protect your information

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

In particular, we:

  • hold personal information in secure facilities and where the information is held electronically, on secure servers.
  • use encrypted transmission links whenever we can.
  • use other safeguards such as firewalls, authentication systems (e.g., passwords), and access control mechanisms to control unauthorised access to systems and data.
  • regularly review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
  • restrict access to personal information to our employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations.
  • We may discipline or terminate individuals who maliciously acquire information, without being entitled to its access.

Once client information is no longer needed, Trade Online Group will take reasonable steps to destroy or de-identify the information as long as we are not required by Law, or court/tribunal order to retain the information, or other overseas regulatory and government bodies.

We will take seriously and deal promptly with any accidental or unauthorised disclosure of personal information. We follow the relevant scheme for notifiable data breaches where applicable and when handling accidental or unauthorised disclosures of personal information

7. How long we hold your information

We will remove any personal information that will identify you or we will securely destroy the records when we consider that that personal information is no longer required. This could be a period of six years after our business relationship with you has ended.

However, we may need to maintain certain records for a longer period, for example, where we are required to hold your personal information for regulatory or legal purposes, to provide you with the services you have requested or to maintain adequate business records.

8. Changes to this Privacy Statement and Opting Out

In the event we materially changes this Privacy Statement, the revised Privacy Statement will promptly be posted to our website. By opening an account with us, you are deemed to agree to accept posting of a revised Privacy Statement electronically on our website as actual notice to you.

Under certain circumstances, such as with respect to our sharing of your personal information with non-affiliated third parties, you may inform us that you would like to "opt out" by contacting us through the contact information listed on the website. Note that for joint accounts, an-opt out election made by one account owner of a joint account is applicable to all account owners of the joint account. An opt-out election must be made for each separate account you hold at Trade Online Group.

Any dispute over our Privacy Statement is subject to this notice and the Trade Online Group Customer Agreement.

9. Your duty to tell us about changes

It is important that the personal data we hold about you is accurate and current. Clients are required to keep us informed if your personal data changes during your relationship with us by emailing us at info@tradeonline.org.uk

10. Making a query or a complaint

If you want to exercise your rights, please contact us by email at info@tradeonline.org.uk using the registered email address you disclosed to us.

If you are not satisfied with our response to your complaint, you have the right to lodge a complaint with the relevant supervisory authorities. Alternatively, you also have the right to lodge a complaint with the data protection authority of your country of residence.

11. Transfers outside the UK and the EEA

We might transfer data to servers spread out among several safe data centers in the UK and EEA. Our server environment is extremely secure, and only a small number of employees have access. All data will be "at rest" encrypted (in other words, on being stored).

Your information might be processed by personnel working for them outside of the UK and EEA as well as transported to and stored at a location outside of those two regions. We will take all reasonable precautions to ensure that information about you is treated securely and in line with this notice, and we will make sure that appropriate measures are in place before your information is transferred outside the UK and EEA as required by law. We take the necessary steps to protect your data when receivers of your personal information are situated in nations outside the UK and EEA that do not uphold the same standard of data protection as that which is deemed suitable in the UK and the European Union. For instance, when necessary, our affiliates and service providers agree to standard contractual terms that have been endorsed by the European Commission or other regulatory bodies.

We may process payments through other organizations and payment systems if you send payments or messages from outside the UK and EEA or if you are inside the UK and EEA but send payments or messages from outside the UK and EEA. They might need to handle and keep your information in order to comply with their own rules. Please be aware that their standards may not be as high as those in the UK and EEA.

Your information is not completely safe when it is transmitted over the Internet. Despite our best efforts to safeguard your information, we cannot ensure the security of any information you communicate to us; as a result, any transfer is done at your own risk. Once we obtain your information, we will endeavor to prevent unauthorized access by following tight protocols and utilizing security features.

12. Contact us

For issues, inquiries, queries or concerns regarding your data or this privacy statement, you can contact us by submitting a request to info@tradeonline.org.uk