Privacy Notice and Cookie Policy

Globe Derivative Trading Limited (trading as ‘Globe’) is committed to protecting your privacy, providing clear information about how your personal data is processed and complying with data protection law when dealing with your personal data. This Privacy Notice and Cookie Policy sets out how we collect and use your personal data and how we use cookies. Please read this Privacy Notice and Cookie Policy carefully.

1. INTRODUCTION

About us

In this Privacy Notice and Cookie Policy references to “we” or “us” or “Globe” are to Globe Derivative Trading Limited, a company registered in the Republic of Seychelles (company number 212550). For the purposes of data protection law, we act as the ‘data controller’ in respect of the personal data that we process. If you have any questions about how we collect, store or use your information, or you would like to update the information we hold about you, you may contact us by emailing [email protected]

About this Privacy Notice and Cookie Policy

This Privacy Notice and Cookie Policy tells you what personal data we collect, why we need it, how we use it and what protections are in place to keep your personal data secure. It applies to all visitors to our website in addition to our prospective and existing customers and third party suppliers. It should be read in conjunction with any other privacy notices and information that we provide to you on how we use your personal data. We may change our Privacy Notice and Cookie Policy from time to time. Any changes we may make to this policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. We therefore encourage you to review our Privacy Notice and Cookie Policy when you visit the website from time to time to stay informed of how we are using your personal data. 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. We encourage you to read the privacy policy of every website you visit.

2. HOW DO WE COLLECT PERSONAL DATA?

Information provided to us by you

Personal data is provided to us by you:

• When you enter information into our website, e.g. when you register to use our website, when you enter details into our online enquiry form and when you report a problem with our site; and
• When you contact us.

Information collected automatically by us

Personal data is collected by us automatically, when you visit our website – details of this are set out in section 3.

Information provided to us by third parties

Personal data is provided to us by third parties – details of this are set out in section 3.

3. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS?

Information provided to us by you

Personal data provided to us by you may include, as applicable:

• Your name and e-mail address

Information collected automatically by us

Personal data collected by us automatically, when you visit our website, may include:

• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time);
• Products and services 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; and
• 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.

Information provided to us by third parties

We work closely with third parties (including, for example, analytics providers) and may receive information about you from them.

4. WHAT DO WE USE YOUR PERSONAL DATA FOR?

Information you give to us

We will use this information:

• To enable you to create an account with us and to use our products and services; and
• To notify you about changes to our products and services.

In these circumstances, the legal basis for processing the data is our legitimate interest in operating our business. We will also use this information to comply with our legal obligations, e.g. where we are obliged to disclose information under orders from courts and regulators. In such circumstances, our legal basis for processing the personal data will be compliance with a legal obligation.

In addition, we will use the information that you provide to us:

• To provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about; and
• To notify you of special offers or to carry out market research.

In these circumstances, the legal basis for processing the data is our legitimate interests. We have a legitimate interest in keeping you informed about our products and services that may be of interest to you. Please note that when we send you marketing communications, there are separate laws that we adhere to, in addition to data protection laws. If you do not want us to use your data in this way, please tick the relevant box situated on the form on which we collect your data (i.e. the registration form). You may opt out of receiving marketing communications from us at any time by contacting us at [[email protected]], and each marketing communication that we send provides a straightforward means of opting out.

Information collected automatically by us

We will use this information:

• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• To allow you to participate in interactive features of our service, when you choose to do so; As part of our efforts to keep our site safe and secure;
• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• To ensure that content from our site is presented in the most effective manner for you and for your computer; and
• To make suggestions and recommendations to you and other users of our site about products or services that may interest you or them.

In these circumstances, the legal basis for processing the data is our legitimate interest in administering and improving our website and its features, and keeping our website secure.

Information provided to us by third parties

We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

What happens if I do not provide my personal data?

Where we need to collect personal data by law and you fail to provide that data when requested, we may not be able to provide you with, or have to cancel a product or service.

5. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

Your personal information

We may share your personal information with the following third parties, where relevant:

• Our group companies;
• Our staff, agents and contractors;
• Our professional advisors;
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; and
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may also share your information with third parties such as regulatory authorities, or where we are under a legal obligation to disclose your information (for example where we are required to share information in accordance with legislation, to prevent fraud and other criminal offences, or because of a court order). We may disclose your information in order to enforce our legal rights or to protect our legal rights or those of a third party.

In addition to the above, we may disclose your personal data to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and/or
• if Globe Derivative Trading Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

6. HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE?

We have security measures in place to restrict access to personal data, to guard against unauthorised or unlawful processing of personal information and against damage to, accidental loss or destruction of, your personal information.

The security measures applied include storing your personal information on secure servers, encrypting transfers of personal data to or from our servers, and only granting access to your personal information where necessary. 

7. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We keep your personal information only for as long as is reasonably necessary for the purposes for which we process your personal information. These purposes are listed at section 4 of this Privacy Notice and Cookie Policy.

8. INTERNATIONAL TRANSFERS

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.

9. YOUR RIGHTS

You have certain rights under data protection legislation in relation to the personal information that we hold about you. These rights apply only in particular circumstances and are subject to certain exemptions such as public interest (for example the prevention of crime).

They include:

• The right to access your personal information;
• The right to rectification of your personal information;
• The right to erasure of your personal data;
• The right to restrict or object to the processing of your personal data;
• The right to object to the use of your data for direct marketing purposes;
• The right to data portability;
• Where the justification for processing is based on your consent, the right to withdraw such consent at any time; and
• The right to complain to the Information Commissioner’s Office about the use of your personal data.

If you would like to contact us about your rights, please see the contact details in section 1.

10. COOKIE POLICY

About cookies

Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. The cookies may transmit information via your browser with a purpose of authenticating or identifying the computer (via e.g. the IP address) or the user. Cookies may contain information such as registration data and user preferences. See https://www.allaboutcookies.org for further information on cookies.

How we use cookies

Our site uses cookies to distinguish you from other users of our site. Our cookies help us to:

• Make our site work as you would expect;
• Remember your settings during and between visits;
• Improve the speed/security of our site;
• Allow you to share pages with social networks like Facebook;
• Continuously improve our site for you; and
• Make our marketing more efficient.

Google Analytics

These cookies help us analyze how users use the Site. The information generated by the cookies about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers owned by Google. Google will use this information for the purpose of evaluating use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. The collected data is not tied to any single individual, no individual profiles are created, and Google will not associate your IP address with any other data held by Google. Further use of your information shall be in accordance with the privacy policies and procedures of Google in effect from time to time.

How can I turn cookies off?

You may refuse to accept cookies from our site at any time by activating the setting on your browser which allows you to refuse cookies. Please note that by disabling or blocking any or all cookies, some features of our site may not operate as intended and you may not have access to features or personalisation available on our site.