PLEASE READ THIS POLICY CAREFULLY BEFORE USING ANY SERVICES ON THIS WEBSITE.
1. Protecting your personal data is very important to ETFmatic Limited (“ETFmatic”, “us”, “we” or “our”).
3. This privacy notice aims to give you information on how we collect and process your personal data through your use of our Website (https://etfmatic.com) together with our app(s) and their functionalities, as developed from time to time (“Website”), including any data you may provide through this Website when you sign up to our newsletter, purchase a product or service or take part in a competition.
4. This Website is not intended for children and we do not knowingly collect data relating to children except for the purposes of opening Children’s Custodial Accounts in accordance with the Additional Children’s Custodial Accounts Terms and Conditions available on our Website.
5. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
6. For the purpose of the relevant data protection legislation, the data controller responsible for your personal data is ETFmatic Limited of 80 Coleman Street, London EC2R 5BJ, United Kingdom.
7. We are registered with the Information Commissioner’s Office (“ICO”) under number ZA115987.
8. We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice.
If you have any questions about this privacy notice, including any requests to exercise any of your legal rights, please contact the DPO using the details set out below:
Full name of legal entity: ETFmatic Limited
Name of DPO: Tom Carnell
Email address: DPO@ETFmatic.com
Postal address: 80 Coleman Street, London EC2R 5BJ, United Kingdom.
9. You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us using the details in paragraph 8 above in the first instance.
10. This version was last updated on 25 May 2018 to give effect to the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and historic versions can be obtained by contacting us at support@ETFmatic.com.
11. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
12. This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every third-party website you visit.
13. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
14. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: Identity Data, Contact Data, Financial Data, Transaction Data, Technical Data, Profile Data, Usage Data and Marketing and Communications Data.
15. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
16. There may be times when you give us sensitive information, which may include your racial origin, political opinions, religious beliefs, trade union membership details or biometric data. We will only use this information in strict accordance with the law.
17. We do not collect any information about criminal convictions and offences.
18. Where we need to collect personal data by law, or under the Investment Terms we entered with you and you fail to provide that data when requested, we may not be able to perform the obligations we have. In this case, we may have to terminate your Account but we will notify you if this is the case at the relevant time.
We use different methods to collect data from and about you including through:
22. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
23. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time in the section Notifications > Settings > Marketing in your Account on the Website or by contacting us at support@ETFmatic.com.
24. To provide our services. We use it to:
25. To meet our legal obligations. We use it to:
26. To exercise what we define as our legitimate interests. This is when we use data for a reason which is in your and/or our interest, and which doesn't involve overriding your privacy rights. We use it to:
a. Market features and services generally on the Website.
b. Search for your records using a “soft search” at credit reference agencies when you sign up (this does not impact your credit score).
27. With your permission. We use your personal data to:
a. Market and/or communicate our features and services to you by email. You can always unsubscribe from receiving these if you want to, by email to support@ETFmatic.com and via the section Notifications > Settings > Marketing in your Account on the Website.
28. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
29. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call it marketing).
30. You will receive marketing communications from us if you have opened an Account with us and you have not opted out of receiving that marketing.
31. We will get your express opt-in consent before we share your personal data with any company outside the ETFmatic group of companies for marketing purposes.
32. You can ask us or third-parties to stop sending you marketing messages at any time by logging into your Account on the Website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time at support@ETFmatic.com.
33. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a feature or service request or experience or other transactions.
34. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at support@ETFmatic.com.
35. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
36. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
37. We may have to share your personal data with Internal and External Third Parties when they require it to perform their obligations to us or to support any of our services which you use, including:
a. Account providers and/or payment processors and networks.
b. Credit reference agencies (please refer to the Credit Reference Agency Information Notice for details on how they process personal information).
c. Know Your Customer (KYC), analytical and cyber security service providers.
d. Customer-interface service providers (such as online support interface service providers).
e. Companies we engage to run advertising for us and we ensure that no identifiable personal data is being shared with third-parties for their own direct marketing unless you consented. As with any other consent for marketing you give to us, you can opt out any time.
f. Organisations set up for detection and prevention of terrorism.
g. Any party whom we have your explicit permission to share it with.
h. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
38. We require all third-parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
39. Many of our external third-parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
a. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
b. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
c. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
40. Please contact us at support@ETFmatic.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
41. 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
42. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
43. We will retain your personal data as long as you are using ETFmatic and for 6 years after that to comply with applicable laws and regulations. In specific circumstances, such as cases of anti-money laundering or fraud, we may keep your personal data for longer if we must and/or the law says we are required to.
44. Under certain circumstances, you have rights under data protection laws in relation to your personal data, such as to:
a. Access any personal data that we hold about you and/or to get a copy of it.
b. Request to correct any inaccurate data.
c. Ask us to delete, 'block' or suppress your data, though for legal reasons we might not always be able to do it.
d. Object to us using your personal data for direct marketing and in certain circumstances for legitimate interests, research and statistical reasons.
e. Withdraw any consent you’ve previously given us.
45. To do so, please contact us through the Website or by emailing us at support@ETFmatic.com.
46. 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 clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
47. We try to respond to all legitimate requests within one month.
48. We will post any changes made to our privacy notice on this page on our Website and, we will let you know by email of those changes which are significant.
External Third Parties includes:
a. Service providers acting as processors based inside or outside the EEA who provide IT and system administration services.
b. Professional advisers including lawyers, bankers, auditors and insurers based inside the EEA who provide consultancy, banking, legal, insurance and accounting services.
c. HM Revenue & Customs, regulators and other authorities based in or outside the United Kingdom who require reporting of processing activities in certain circumstances.
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, ID number and nationality.
Internal Third Parties means Other companies in the ETFmatic Group and who are based in the EEA and provide IT and system administration services and undertake leadership reporting.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service or feature and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Marketing and Communications Data includes your preferences in receiving marketing from us and our third-parties and your communication preferences.
Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
Transaction Data includes details about payments to and from you and other details of services you have selected and the Mandate you have given us.
Usage Data includes information about how you use our Website and services such as Uniform Resource Locators (URL) clicked get to, through and from our Website (including date and time), what you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.