Privacy Policy

This Privacy Policy is current as of the effective date set forth above. We reserve the right to change this Privacy Policy from time to time. Changes and modifications to this Privacy Policy will be effective immediately upon posting of the changes and modifications to this website, except where prohibited by law. You should therefore periodically visit this page to review the current Privacy Policy. If we change this Privacy Policy, we will notify you of the changes by updating the effective date at the top of this policy and, if required by applicable laws, provide by other means, such as email or notice within this website. Where the changes will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will, as required by applicable laws, provide you with notice in advance. If at any time you choose not to accept the terms of this Privacy Policy, you should not use this website.

 

1. Introduction

1.1  Virtual Auction Global Markets Limited (referred to as the “VAGM”, “we”, “us” and “our”) respects your privacy and is committed to protecting your personal data. This privacy policy informs you about how we look after your personal data, provides information about your privacy rights and explains how the law protects you.

1.2  We are the data controller responsible for your personal data. We will appoint a data protection officer (the “DPO”) who will be responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at any time using the details set out below.

  • Full name of legal entity: Virtual Auction Global Markets Limited
  • Email address: privacy@vagm.com
  • Postal address: 6 New Street Square, London EC4A 3DJ
  • Telephone number: +44 (0) 208 369 5445

2. About this privacy policy

2.1  This privacy policy aims to give you information on how we collect and processes your personal data through your use of this website and any personal data you may provide to us at any time.

2.2  This website is not intended for children under 16 years of age and we do not knowingly collect data relating to children.

2.3  It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 personal data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

3. Changes to this privacy policy and your duty to inform us of changes

3.1  We keep our privacy policy under regular review. 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.

4. Third-party links

4.1  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 policy of every website you visit.

5. The data we collect about you

5.1  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).

5.2  We may collect, use, store and transfer different categories of personal data about you, which we have grouped together as follows:

5.2.1  Identity data includes first name, marital status, last name, personal title, job title, national identification number (such as passport number or identity card number where applicable), date of birth, nationality, gender and user name and password used to access any system or service provided by VAGM or VAGM group companies;

5.2.2  Contact data includes postal address, email address and telephone numbers;

5.2.3  Financial and tax data includes payment card details;

5.2.4  Technical data includes internet protocol (IP) address, 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 any system or service provided by VAGM or VAGM group companies;

5.2.5  Usage data includes data about how you use our website, products and services; and

5.2.6  Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

5.3  We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

5.4  We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

6. If you fail to provide personal data

6.1  Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our services but we will notify you if this is the case at the time.

7. How we collect your personal data

7.1  We use different methods to collect personal data from and about you including through:

7.1.1  Direct interactions. You may provide your identity, contact or financial data by filling in forms or by corresponding with us via our website, phone, email or otherwise. This includes personal data you provide when you:

  • Meet with us in person;
  • Access our multilateral trading facility (“MTF”);
  • Place orders via the MTF;
  • Execute transactions via the MTF;
  • Contact us about the MTF;
  • Subscribe to our newsletter;
  • Request marketing to be sent to you;
  • Contact us via our website; or
  • Give us feedback or report a problem with our website.

7.1.2  Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookies policy for further details.

7.1.3  Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below

  • Technical data from the following parties that are based both inside and outside of the European Economic Area (the “EEA”):(a) Analytics providers;
    (b) Advertising networks; and
    (c) Search information providers;
  • Identity and contact data from the following providers that are based both inside and outside the EEA:
    (a) VAGM affiliates, VAGM group companies or other VAGM clients or referrers;
    (b) Regulatory and screening providers who help us to achieve our compliance obligations; and
    (c) Publicly available sources such as Companies House, the Electoral Register and equivalent organisations in countries other than the United Kingdom.

8. How we use your personal data

8.1  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:

8.1.1  Where we need to perform the contract, we are about to enter into or have entered into with you;

8.1.2  Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests); or

8.1.3  Where we need to comply with legal or regulatory obligations.

8.2  Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us as described below.

9. Purposes for which we will use your personal data

9.1  We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

9.2  Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To:

(a) register you as a new trader;

(b) keep records of your trading activities, which we are legally obliged to record; and

(c) conduct know your client and other compliance checks to fulfil our legal compliance obligations.

 

(a) identity;

(b) financial;

(c) transaction; and

(d) contact.

(a) Performance of a contract with you.

(b) Necessary to comply with our legal obligations.

To process and deliver your trading activities including:

(a) setting up and administering your account with us;

(b) provide you with our products and services;

(c) assist you to use such products and services, including providing any operational assistance and support, training you on our systems and notifying you of any product changes and system maintenance periods;

(d) manage payments, fees and charges; and

(e) collect and recover money owed to us.

 

(a) identity;

(b) contact;

(c) financial;

(d) transaction; and

(e) marketing and communications.

(a) Performance of a contract with you.

(b) Necessary for our legitimate interests (to process and deliver our products and services).

To manage our relationship with you which will include:

(a) notifying you about changes to our terms or privacy policy; and

(b) asking you to leave a review or take a survey.

 

(a) identity;

(b) contact;

(c) profile; and

(d) marketing and communications.

 

(a) Performance of a contract with you.

(b) Necessary to comply with a legal obligation.

(c) Necessary for our legitimate interests (to keep our records updated).

 

 

 

To enable you to partake in a prize draw, competition or complete a survey.

 

 

 

(a) identity;

(b) contact;

(c) profile;

(d) usage; and

(e) marketing and communications.

 

 

 

(a) Performance of a contract with you.

(b) Necessary for our legitimate interests (to study how you use our products and services, to develop them and grow our business).

 

To administer and protect our business, our systems and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting of data and system monitoring, which we are required to carry out by law).

 

(a) identity;

(b) contact; and

(c) technical.

 

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).

(b) Necessary to comply with a legal obligation.

 

 

 

To deliver relevant VAGM and VAGM group system, website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

 

 

(a) identity;

(b) contact;

(c) profile;

(d) usage;

(e) marketing and communications; and

(f) technical.

 

 

 

 

Necessary for our legitimate interests (to study how you use our products and services, to develop them, to grow our business and to inform our marketing strategy).

 

To use data analytics to improve, customise and enhance our website, products/services, marketing, your relationship with us and your experiences.

 

(a) technical; and

(b) usage.

 

Necessary for our legitimate interests (to keep our systems and website updated and relevant, to develop our business and to inform our marketing strategy).

 

 

 

 

To make suggestions and recommendations to you about products or services that may be of interest to you.

 

 

 

(a) identity;

(b) contact;

(c) technical;

(d) usage;

(e) profile; and

(f) marketing and communications.

 

 

 

Necessary for our legitimate interests (to develop our products and services and grow our business).

 

10. Marketing

10.1  We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

10.2  We may use your personal 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 of our services may be relevant for you. You will receive marketing communications from us if you have requested information from us or engaged our services previously and have not opted out of receiving such marketing.

10.3  We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

11. Opting out

11.1  You can ask us or a third party to stop sending you marketing messages at any time by contacting us at any time at privacy@vagm.com.

11.2  Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your account on the website.

12. Change of purpose

12.1  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.

12.2  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.

12.3  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.

13. Cookies

13.1  You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see here.

14. Disclosure of your personal data

14.1  We may share your personal data with other companies in the VAGM group.

14.2  To best serve you, we may share your personal data with service providers that provide support services to us. Service providers are third parties who perform services on our behalf. They are contractually restricted from using your data in any manner other than in helping us to provide you with the services available from VAGM. For example, we may use:

14.2.1  Subscription management providers to enable us to communicate any updates or educational materials to you;

14.2.2  Know your client and/or regulatory screening providers who will help us to meet our compliance obligations; and

14.2.3  Customer relationship management software providers to help us provide our services to you.

14.3  We may also disclose your personal data to a third party:

14.3.1  When you ask us to do so;

14.3.2 Where it is required by law or any regulatory obligation; or

14.3.3  In the event that we sell or buy any business assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

14.4  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 specific purposes and in accordance with our instructions and this privacy policy.

15. Countries having access to your personal data

15.1  The servers we use to store and keep your personal data secure are located in the United Kingdom and in countries outside of the EEA. Personal data may also be processed by staff members and third party service providers who are located in countries outside of the EEA.

15.2   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:

15.2.1  Where we transfer your personal data to VAGM group companies located in the United States and outside of the EEA, we do so under an internal intra-group data transfer agreement which incorporates the standard contract clauses and ensures a level of protection acceptable to the European Commission (the “EC”);

15.2.2  The transfer of your personal data is to a country that has been deemed to provide an adequate level of protection for personal data by the EC;

15.2.3  Where we use certain service providers, we may use specific contracts approved by the EC which give personal data the same protection it has in Europe; or

15.2.4  Where we use providers based in the United States, 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.

15.3  Please contact us at privacy@vagm.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

16. Data security

16.1  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.

16.2. 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.

17. Retention of your personal data

17.1  We will only retain your personal data for as long as it is necessary to provide our services or to fulfil the purposes we collected it for. Processing is therefore necessary for the purposes of our legitimate interests, or where we are required to do so by law.

17.2 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

17.3   To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

18. Your rights

18.1  You have the right to:

18.1.1  Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;

18.1.2  Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;

18.1.3  Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;

18.1.4  Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms;

18.1.5  Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;

18.1.6  Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you; and

18.1.7  Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

18.2  To exercise any of the rights as listed above, please contact us at privacy@vagm.com.

18.3  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 or if additional copies of your personal data are requested. Alternatively, we may refuse to comply with your request in these circumstances.

18.4  We may need to request specific data from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

18.5  We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

19. Changes to this privacy policy

19.1  This privacy policy replaces all previous disclosures we may have provided you about our data practices. We reserve the right to change this policy at any time, and to apply any changes to data previously collected, as permitted by law. Any changes we may make to this policy in the future will be posted on our website and will be effective upon posting.

20. Contact details

20.1  If you have any questions about this privacy policy or our privacy practices, or to update us with your data-sharing preferences or to update your personal details, you may contact us using the contact details at the top of this privacy policy.

21. Making a complaint

21.1  We pride ourselves on excellent service, but if you would like to make a complaint about the way we have collected or used your personal data, please contact us at privacy@vagm.com.

21.2  If you are unhappy about the way we have handled your complaint and/or you would like to take the matter further or make a complaint directly to our regulator without contacting us first, you can do so by contacting the Information Commissioner’s Office (“ICO”) by following this link: https://ico.org.uk/concerns/ or telephoning the ICO helpline, which is 0303 123 1113.

 

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