1. IMPORTANT INFORMATION AND WHO WE ARE

Hanseatic Capital Management Ltd and all its affiliates (hereinafter referred to as “HCM”, “we” or “us”) are committed to maintaining the privacy of every current, former and prospective customer. We recognize that you entrust important personal information to us, and we wish to assure you that we take seriously our responsibilities in protecting and safeguarding this information. This Privacy & Cookie Policy (“Policy”) describes in detail how we deal with information that we collect on this website (the “Site”).
This Policy may be updated at any time. Please ensure that you regularly read the latest version of this page. The first paragraph of the Policy tells you when the last update was made.

Controller

This Privacy notice is issued by HCM and Contact details can be found in https://hanseatic-cm.com/contact-us/.

CONTACT DETAILS

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our internal GDPR team at [email protected].

You have the right to make a complaint at any time to the concerned supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy notice under regular review. This version was last updated on 31.07.2018. We will inform you when we update our policy with a link to view historical versions.

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.

2. THE DATA WE COLLECT ABOUT YOU

Information We Collect

We may collect information about you when you use this Site or when you apply for or use other services offered by HCM in the following ways:

• If you register to use the password-protected portions of our site, we will ask you to provide us with certain information about yourself. This information may include your name, company name, title, address, country of residence, e-mail address, telephone number, account number, assets, income and financial situation. We use such information about you to verify your identity and eligibility to receive certain products or services, to provide information to you about products and services that we believe may be of interest to you, to record your interest in products and services that we offer, and to respond to your requests for information. We may also use cookies or web bugs on such portions of our Site to collect Usage Information, and to facilitate your movement within the Site (e.g. remembering passwords during a session).
• We may also collect personal information about you from applications, forms or questionnaires you may complete or agreements you enter into with us or in the course of your establishing or maintaining a customer relationship with us, including information about your credit history or financial situation, and your transactions with us or others who provide services to us.

If you decline to provide us with the personal information we require then we may not be able to make investment products available to you or to provide other services to you.

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 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.

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.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

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

• Direct interactions. You may give us your name, company name, title, address, country of residence, e-mail address, telephone number, account number, assets, income and financial situation by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our services;
  • When you register with us.
  • Give us feedback or contact us.
• 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, add-in and other similar technologies.
• Third parties or publicly available sources. We will receive Technical Data from analytics providers such as Google based outside the EU.

Security of Data Transfers

Please note that data transferred via a public network, such as the internet or an email service, may be viewed by others. Information transmitted via the internet (such as online forms) and content received online may under certain circumstances be transmitted via third-party networks. HCM cannot guarantee the confidentiality of messages or documents transmitted via such open networks or networks from third parties.

If you disclose personal information via an open network or a third-party network, you should be aware that your data may be lost or that third parties may be able to gain access to this information and consequently gather and make use of the data without your consent. In particular, while individual data packets are often encrypted, the names of the sender and recipient are not. A third party could therefore be able to draw conclusions about existing bank accounts or business relationships or ones that are subsequently established. Even if both the sender and recipient are located in the same country, data may also be transmitted regularly and without controls via such networks to other countries, including to countries that do not afford the same level of data protection as your country of domicile. We accept no responsibility for the security of your data during transmission via the internet and cannot be held liable for any direct or indirect losses. We ask that you use alternative methods of communication if you deem this to be necessary or appropriate for security reasons.

Data you provide in online forms can be communicated to commissioned third-party companies for order processing and be processed by such companies.

Protection, Processing and Use of Personal Data

We use your personal information to enhance the quality of the products or services we wish to provide to our customers or in connection with your investments with or through us and to maintain contact details for those with whom we deal. We restrict access to personal information about you to those employees or other parties who need to know that information to provide products or services to you or in connection with your investments with or through us. We maintain physical, electronic and procedural safeguards to guard your personal information, including firewalls, individual passwords and encryption and authentication technology. We do not use for purposes other than as set out above, or disclose to any third party any personal information about our customers or former customers, except with such customer’s consent or as otherwise permitted or required by law. We may also disclose this information to firms that perform services on our behalf to the extent permitted by applicable law. These service providers are required to treat the information confidentially and use it only for the purpose for which it is provided. Certain jurisdictions may have more stringent privacy requirements that will prevent disclosure of your personal information to any other person or entity, including affiliates.
We will retain your personal information in accordance with applicable data protection laws for so long as it is needed 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.

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 unauthorized 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.

THIRD-PARTY MARKETING

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

CHANGE OF PURPOSE

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.

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.

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.

Cookie policy

All websites of HCM and its affiliates (hereinafter referred to as “HCM”, “we” or “us”) use cookies for statistical purposes and to improve user experience and online advertising campaigns. One of the cookies we use is essential for parts of the site to operate and has already been set. This site does not work without cookies. By using this website, you agree to the use of cookies for this purpose.

What is a cookie?

Cookies are small files which are stored on your computer to keep track of your visit to the website and your preferences; as you move between pages, and sometimes to save settings between visits. Cookies help the builders of websites gather statistics about how often people visit certain areas of the site, and help in tailoring websites to be more useful and user-friendly.

For more information on cookies, please visit the UK Information Commissioner’s Office website (www.ico.gov.uk) for a thorough and detailed description of the purpose and usage of cookies, and information on how to control and delete cookies from your browser.

How are cookies used in this website?

The cookies we store on HCM websites are used to:

• • track the number, and type of visits to the website, and its pages, in order for us to determine which parts of the site are working well, and which need improvement,
  • gather statistics on the number of users and their usage patterns,
  • improve the speed and performance of the website pages.
    • The table below explains the cookies we use and why:

Analytics tools for the website
This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies” to help us analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google. To find out more about Google Analytics, Google’s privacy policy and opting out of its cookies please visit: https://tools.google.com/dlpage/gaoptout.

Deleting Cookies

You may opt-out of cookies (and the use of this website) at any time, by deleting the cookies that were set by the site. This can be done via the settings of your internet browser, and deleting all cookies. To find how to manage and delete cookies, please visit the Information Commissioner’s Office website (www.ico.gov.uk).

Links

This Site may contain hyperlinks to other websites that are not operated or monitored by HCM. These other websites are not subject to this Policy and we are not responsible for their content or for the policy they apply to the treatment of personal data. We recommend that you read the policy used by these websites and check how these websites protect your personal data and whether they are trustworthy.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

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:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact us at [email protected]

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 could refuse to comply with your request in these circumstances.

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.

TIME LIMIT TO RESPOND

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.