Commodities Trading Corporation Limited (CTC) respects the personal information of people that it collects (such as title, name, telephone number, date of birth address) and complies with the General Data Protection Regulation (EU 679/2016) (GDPR) and UK GDPR, and the Data Protection Act 2018 (Data Protection Laws).
We ask that you read this privacy notice carefully as it contains important information on:
- who we are;
- how and why we collect, store, use and share personal information,
- your rights;
- on how to contact us and supervisory authorities in the event you have a complaint.
1. Who we are
Commodities Trading Corporation Ltd (CTC) a company registered in England and Wales with company number 09827671 who registered offices are at Rex House, 4th floor, 4-12 Regent Street, London, SW1Y 4PE (“CTC” and “We”) collects, uses and is responsible for certain personal information about you.
When we do so we are regulated by Data Protection Laws which apply across the European Union and the United Kingdom and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
2. The personal information we collect and use
a) Information collected by us:
In the course of providing our marketing services we collect the following personal information:
1. Information you provide to us when you contact us to request our services.
2. Information obtained through the use of emails and cookies to identify you when you contact us about our services.
3. Information collected through publicly available sources such as social media platforms (Facebook, LinkedIn and any others) for the purposes of our B2B marketing activities.
4. The types of information we collect includes but is not limited to the following:
i) name, address, email address and telephone contact numbers;
ii) Details of visits made to our website including, but not limited to,
iii) the volume of traffic received;
iv) the Internet protocol (IP) address used to connect your computer to the Internet;
v) your login information, browser type and version,
vi) time zone setting;
vii) browser plug-in types, versions, operating system and platform; and
viii) information about your visit, including the full Uniform Resource Locators (URL) and the resources accessed by you.
b) We use personal information to:
- To provide our services to you.
- Where you have given explicit consent we may use your personal information to send you information about products or services that may be of interest to you.
- For business related purposes.
c) Who we share your personal information with
We will only share personal information with law enforcement or other public authorities and regulators if required by applicable law. We are under a duty to disclose or share your personal data in order to comply with any legal, governmental or regulatory obligation. For example, we are under legal and regulatory duties to share data with the Financial Conduct Authority or similar regulatory bodies.
d) Whether information has to be provided by you, and if so why.
You will be required to provide your name, address, email address and telephone number. If you choose not to provide this information to us, we may not be able to provide our services to you.
e) How long your personal information will be kept
We will hold your personal data in accordance with applicable laws and for as long as we need your data to provide services. Where we do not require your data we will delete it.
f) Reasons we can collect and use your personal information
We rely on a combination of legal bases to collect, use, process and store your personal data. These include consent which we collect at the point of entering a contract with you), legitimate interests and contract performance.
3. Transfer of your information out of the EEA
We do not transfer your personal information out of the European Economic Area (EEA).
4. Your rights
Under the GDPR you have a number of important rights. In summary, those include rights to:
a) Fair processing of information and transparency over how we use your personal information.
b) Access to your personal information. Please provide enough information to identify yourself correctly; you may make such a request by emailing us at email@example.com.
c) Require us to correct any mistakes in your information which we hold. You can request us to rectify and correct any personal data that we are processing about you which is incorrect by contacting us at firstname.lastname@example.org. We will update your personal details and keep your data accurate.
d) Require the erasure of personal information concerning you in certain situations.
Again you can request us to erase any personal data that we are processing about you by contacting us at email@example.com.
e) Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to a third party in certain situations. You can request us to do this by contacting us at firstname.lastname@example.org.
f) Object at any time to processing of personal information concerning you for direct marketing. Again you can object by contacting us at email@example.com.
g) Object in certain other situations to our continued processing of your personal information by contacting us at firstname.lastname@example.org.
h) Otherwise restrict our processing of your personal information in certain circumstances by contacting us at email@example.com.
Please note that some of these rights apply in specific circumstances and are qualified by exemptions in data protection legislation. We will advise you if we are relying on any such exemptions when we respond to you.
If you would like to exercise any of those rights, please email, call or write to us at the email above or at the address given below in “how to contact us”.
5. Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach in 72 hours where we are legally required to do so.
You should also note that whilst we will use all our efforts to protect your privacy and data, we cannot ensure or warrant the security of any information you transmit to us over the internet because no method of transmission over the internet or method of electronic storage can be guaranteed to be absolutely secure.
6. How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
Data Protection Laws also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the United Kingdom is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
7. How to contact us
Please contact us if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us please send an email to firstname.lastname@example.org.
Version 2. Last updated 31st May 2018.