Great Eastern FX Co. Ltd. (“Great Eastern FX”, “us”, “we” or “our”) respects your privacy and is committed to protecting the personal data you provide to us. This privacy notice will let you know how we collect, process and manage your personal data which we have received through your use of our www.greateasternfx.com website (the Website), our social media pages; and any of the Services (the Services) accessible through the Website or through other channels organised by us regarding the promotion and sale of Great Eastern FX products and services. The privacy notice will also notify you of your privacy rights in relation to the personal data and how the law protects you.
Please note that we may amend this policy from time to time and any updated policy will be posted on our website and, where appropriate, notified to you by email. Please continue to review this policy whenever accessing our site.
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.
You have the right to make a complaint at any time to the Information Commissioner’s Office in the United Kingdom, the British 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 Information Commissioner’s Office, and invite you to contact us in the first instance.
THE DATA WE COLLECT ABOUT YOU
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).
The type of information we collect from you will depend upon the type of interaction you have with us.
Broadly speaking, the types of personal data that we collect may include:
a)If you are a customer of Great Eastern FX: your first and last name, email address, postal address, telephone number and the details of the transactions which you conduct using the Services.
b)If you are a job applicant, employee or contractor: your full name, contact details (including address, phone number and email address), identification details, job title, employment history and education details, names and contact details of referees, next of kin details, national insurance number or other information if required by law.
c)Personal data that you provide by completing forms on the Website, including if you sign up to receive our newsletter, search for a product, place an order on the Website, request any information, or enter into any competition or promotion.
d)If you register or create an account with us, your log-in and password details.
e)Information contained in messages when you post on our social media pages.
f)Information contained in communications you send to us, for example when you report a problem or to submit queries, concerns or comments regarding the Website or its content.
g)Data from surveys that we may, from time to time, run on the Website for research purposes, if you choose to respond to, or participate in, them.
You are under no obligation to provide any such data. However, if you choose to withhold requested information, you may not be able to access all of the Website’s contents and services.
Our website is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.
All direct payment gateways offered by Wix.com and used by our website adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including when you:
a)Create a Great Eastern FX customer account.
b)Place an order via the Website or use the Services.
c)Provide content and other information when you use the Services or post on our social media accounts.
d)Visit our Website and any other webpage that we own and manage.
e)Provide information in your account or manage/change your account information.
f)Contact us by phone, email, post or via the Website.
g)Subscribe to receive our newsletter or promotional materials or sign up to a mailing list; and/or participate in surveys, or competitions or other promotional activities.
Great Eastern FX may also collect personal data relating to you from third parties. This may include (but is not limited to) the collection of personal data relating to you from:
a)Our distributors, dealers and other partners.
b)Someone you duly authorise to act on your behalf.
c)Recruiters we have retained and from referees you have provided in support of a job application.
HOW WE USE YOUR PERSONAL DATA
We will never sell your data, will keep your details secure, and will never share them with third parties for marketing purposes without your express consent.
Most commonly, we will use your personal data in the following circumstances:
a)Where we need to perform a contract, we are about to enter into or have entered into with you, or to provide a service which you have requested.
b)Where we need to comply with a legal or regulatory obligation.
c)To provide you with our newsletters, where you have subscribed to receive our newsletters (please see section 9 below).
d)To provide you with information about other products we offer that are similar to those that you have already purchased or enquired about, where you have consented to be contacted for such purposes.
e)To ensure that content from this Website is presented in the most effective manner for you and for your computer.
f)To administer this Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
g)To allow you to participate in interactive features of our Services, when you choose to do so.
h)To liaise with distributors and other partners in connection with your use of the Services.
i)To deal with enquiries or complaints.
j)As part of our efforts to keep this Website safe and secure.
k)To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
l)To conduct our internal business and management processes, for example accounting or auditing purposes.
m)For any other purposes that you would reasonably expect.
We may combine this data with personal data you give to us and personal data we collect that relates to you. We may use this personal data and the combined data for the purposes set out above (depending on the type of data we receive).
We will anonymise personal data relating to you and consolidate such data. We may provide our distributors and other partners with aggregated anonymised data about the users of this Website and the Services, for example behavioural data.
DISCLOSURES OF YOUR PERSONAL DATA
1. OUR DEALERS, SERVICE PROVIDERS AND SUB-CONTRACTORS
In order to process any requests you make regarding Great Eastern FX products and services, to host you at an Great Eastern FX event, or to provide you with customer support, we may need to share your personal data with some of our service partners, suppliers and sub-contractors including members of our authorised dealer network who are best placed to assist you and parties who manage particular Great Eastern FX events. We will only allow such parties to handle your personal data when we have confirmed that they apply appropriate data protection and security controls and we have in place with them contractual obligations relating to data protection and security which include a requirement that they may only use your data to provide services to us and to you, and for no other purposes.
2. OTHER THIRD PARTIES
Apart from the above parties, we will not disclose your personal data to any third party without your express consent, except that we may make such a disclosure to governmental bodies, regulators, law enforcement agencies, courts/tribunals and legal advisers or insurers where we are required to do so in order to: comply with our legal obligations; exercise and/enforce our legal rights; prevent, detect, investigate crime or prosecute offenders; or in order to protect our employees and customers. In each case any such disclosure will comply with the relevant laws. 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.
WHERE DO WE STORE PERSONAL DATA?
The personal data that we collect from you may be transferred to, and stored at, locations 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. These staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
By submitting your personal data, you accept that personal data relating to you may be transferred, stored or processed in this way. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
HOW DO WE PROTECTION PERSONAL DATA?
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect personal data relating to you, we cannot guarantee the security of such data transmitted to the Website; any transmission is at your own risk. Once we have received personal data relating to you, we use strict procedures and security features to try to prevent unauthorised access.
All information you provide to Great Eastern FX is stored on secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted industry-standard encryption technologies when transferring or receiving personal data, such as SSL technology. The safety and security of your information and any personal data relating to you also depends on you. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Website and/or the Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Great Eastern FX takes steps to destroy or de-identify personal data when the information is no longer required for any purpose for which it may be used or disclosed by us and we are no longer required by law to retain the information.
This Website operates an email newsletter program, used to inform subscribers about products and services supplied by Great Eastern FX. Users can subscribe through an online automated process should they wish to do so but do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user.
Subscriptions are managed in compliance with the Privacy and Electronic Communications Regulations 2003. Subscribers are given the opportunity to unsubscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscribe system is unavailable, clear instructions on how to unsubscribe will by detailed instead
Email marketing campaigns published by us may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include: the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity.
This information is used to refine future email campaigns and supply the subscriber with more relevant content based around their activity.
SOCIAL MEDIA PLATFORMS
Communication, engagement and actions taken through external social media platforms that we participate on are subject to the terms and conditions as well as the privacy policies of those social media platforms.
You are advised to use social media platforms wisely and communicate/participate on them with due care and caution with regard to your personal data. We will never ask for personal or sensitive data through social media platforms and we encourage users wishing to discuss sensitive details to contact the relevant platform provider through primary communication channels such as by telephone or email.
This Website may use social sharing buttons which help share web content directly from our web pages to the social media platform in question. Where you use such social sharing buttons you do so at your own discretion – you should note that the social media platform may track and save your request to share a web page respectively through your social media platform account. Please note these social media platforms have their own privacy policies, and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these social media platforms.
LINKS TO THIRD PARTY WEBSITES
Our site may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
LEGAL RIGHTS FOR CUSTOMERS & PROSPECTS BASED IN THE EUROPEAN UNION
1. WHAT ARE THESE?
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
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.
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.
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 information 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.
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 information which override your rights and freedoms.
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.
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.
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.
2. NO FEE USUALLY REQUIRED
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.
3. WHAT WE MAY NEED FROM YOU
We may need to request specific information 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.
4. TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may 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.