Any personal information we hold will be governed by our most current privacy notice.
WHO ARE WE?
The three entities within the GHF Group are:
- G. H. Financials Ltd of 4th Floor, 29 Ludgate Hill, London, EC4M 7JR (registration number 02775278) and who is registered with the Information Commissioner under No. Z5369625)
- G. H. Financials, LLC, 311 South Wacker Drive, Suite 1550 ,Chicago, IL 60606 USA
- G. H. Financials (Hong Kong) Limited, Suite 2007, 20th Floor, The Center, 99 Queen's Road Central, Hong Kong,
GHF provides global clearing services in exchange traded futures and options markets and is the data controller of your personal information in relation to those services.
Please note that if you are a GHF employee, a contractor to GHF or a third party service provider, your personal information will be used in connection with your employment contract, your contractual relationship or in accordance with our separate policies which are available by contacting us. Any reference to ‘us’, ‘our’, ‘we’ or ‘GHF’ in this privacy notice is a reference to each group company within the GHF Group as the context requires unless otherwise stated. Similarly, any reference to ‘you’, ‘your’, ‘yours’ or ‘yourself’ in this privacy notice is a reference to any of our customers and potential customers as the context requires unless otherwise stated.
WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?
If you are an actual or potential customer, we may collect the following types of information about you:
- name, address and contact details
- date of birth and gender
- in certain cases, information about your income and wealth including details about your assets and liabilities, account balances, trading statements, tax and financial statements
- profession and employment details
- location data
- any other similar information.
We may ask for other personal information voluntarily from time to time (for example, through market research or surveys). If you choose not to provide the information we need to fulfil your request for a specific product or service, we may not be able to provide you with the requested product or service. We may record any communications, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our relationship with you. These recordings will be our sole property and will constitute evidence of the communications between us. Such telephone conversations may be recorded without the use of a warning tone or any other further notice. Further, if you visit any of our offices or premises, we may have CCTV which will record your image.
WHO MAY WE DISCLOSE PERSONAL INFORMATION TO?
As part of using your personal information for the purposes set out above, we may disclose your information to:
- other companies within the GHF Group who provide financial and other back office services
- service providers and specialist advisers who have been contracted to provide us with administrative, IT, financial, regulatory, compliance, insurance, research or other services
- marketing partners for joint events, initiatives and promotions including but not limited to Exchange Groups, ISVs, Market Data vendors, etc.
- credit providers, courts, tribunals and applicable regulatory authorities as agreed or authorised by law or our agreement with you
- anyone authorised by you.
Generally, we require that organisations outside the GHF Group who handle or obtain personal information acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with the all relevant data protection laws and this privacy notice.
HOW DO WE OBTAIN YOUR CONSENT?
Where our use of your personal information requires your consent, such consent will be provided in accordance with the applicable term and conditions of use on our website(s) or any other contract we may have entered into with you or as set out in our communication with you from time to time. If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time by contacting us using the contact details set out in this privacy notice.
MANAGEMENT OF PERSONAL INFORMATION
We always take appropriate technical and organisational measures to ensure that your information is secure. In particular, we train our employees who handle personal information to respect the confidentiality of customer information and the privacy of individuals. We regard breaches of your privacy very seriously and will impose appropriate penalties, including dismissal where necessary. Our Compliance team ensures that our management of personal information is in accordance with this privacy notice and the applicable legislation.
HOW DO WE STORE PERSONAL INFORMATION AND FOR HOW LONG?
Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, by mail, over the internet or any other electronic medium. We hold personal information in a combination of secure computer storage facilities and paper-based files and other records, and take steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. When we consider that personal information is no longer needed, we will remove any details that will identify you or we will securely destroy the records. However, we may need to maintain records for a significant period of time. For example, we are subject to certain anti-money laundering laws which require us to retain:
- a copy of the documents we used to comply with our customer due diligence obligations; and
- supporting evidence and records of transactions with you and your relationship with us, for a period of five years after our business relationship with you has ended.
If we hold any personal information in the form of a deed, we will hold this deed in its complete form for a period of 12 years after our business relationship with you has ended. If we hold any personal information in the form of a recorded communication, by telephone, electronic, in person or otherwise, this information will be held in line with local regulatory requirements which will either be 5 years or 10 years after our business relationship with you has ended. Where you have opted out of receiving marketing communications we may hold your details on our suppression list so that we know you do not want to receive these communications but we will not send you marketing communications.
HOW DO WE USE THE PERSONAL INFORMATION?
We may use personal information for the following purposes:
- To verify your identity and establish and manage your account
As part of providing services, or information about our services, to you, we will need to verify your identify to set you up as a customer and we will need to use those details in order to effectively manage your account with us to ensure that you are getting the best possible service from us. This may include third parties carrying out credit or identity or checks on our behalf. It is not only in our legitimate interest to do so but the use of your personal information in this way is necessary for us to know who you are as we have a legal obligation to comply with certain Know Your Customer regulatory obligations.
- To provide you with products and services, or information about our products and services, and to review your ongoing needs
Once you open an account with us, or subscribe to our website or webinar, we will need to use your personal information to perform our services and comply with our obligations to you. It is also in our legitimate interests to ensure that we are providing the most appropriate products and services so we may periodically review your needs to ensure that you are getting the benefit of the best possible products and services from us.
- To help us improve our products and services, including customer services, and develop and market new products and services
We may from time to time use personal information provided by you through your use of the services and/or through customer surveys to help us improve our products and services. It is in our legitimate interests for us to use your personal information in this way to ensure that we provide you with the best products and services we can and to continue to be a market leader in our industry.
- To investigate or settle enquiries or disputes
We may need to use personal information collected from you to investigate issues and/or settle disputes with you as it is in our legitimate interests to ensure that issues and/or disputes get investigated and resolved as quickly and efficiently as possible.
- To comply with applicable law, court order, other judicial process, or the requirements of any applicable regulatory authorities
We may need to use your personal information to comply with applicable law, court order or other judicial process, or the requirements of any applicable regulatory authority. We do this not only to comply with our legal obligations but because it may also be in our legitimate interest to do so.
- Data analysis
Our web pages and e-mails may contain web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence. Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. However where your personal information is not in an anonymised form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market.
- Marketing by us
- Internal business purposes and record keeping
We may need to process your personal information for internal business and record keeping purposes. Such processing is in our own legitimate interests and is required in order to comply with our legal obligations. This may include any communications that we have with you in relation to the services we provide to you and our relationship with you. We will also keep records to ensure that you comply with your obligations under any contract you have entered into with us.
- Corporate restructuring
If we undergo a corporate restructure or part or all of our business is acquired by a third party, we may need to use your personal information in association with that restructure or acquisition. Such use may involve disclosing your details as part of a due diligence exercise. It is our legitimate interest to use your information in this way provided we comply with any legal obligation we have to you.
If you enter any of our premises we may record your image on our CCTV for security reasons. We may also take your details to keep a record of who has entered our premises on any given day. It is in our legitimate interest to do this to maintain a safe and secure working environment.
THE PERSONAL INFORMATION WE HOLD ABOUT YOU
The information about any rights that might be available to you in relation to the personal information we hold about you is set out below.
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
You can ask us to delete or remove your personal information in certain circumstances such as where we no longer need it or you withdraw your consent (where applicable) provided that we have no legal obligation to retain that data. Such request will be subject to any retention limits we are required to comply with in accordance with applicable laws and regulations and subject to section 'How do we store personal information and for how long'.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It will not stop us from storing your personal information though. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
Under the General Data Protection Regulation (679/2016), you have the right, in certain circumstances, to obtain personal information you have provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.
You can ask us to stop processing your personal information, and we will do so, except if we can demonstrate compelling legal grounds for the processing.
TRANSFERS OUTSIDE OF THE EUROPEAN ECONOMIC AREA
We may transfer your personal information outside the European Economic Area to other GHF Group companies as well as processors who are engaged on our behalf (‘Transferees’). To the extent we transfer your information outside the European Economic Area, we will ensure that the transfer is lawful and that there are appropriate security arrangements.
In order to transfer personal information to third parties in territories that do not have a finding of adequacy by the applicable authority and regulations, we enter into agreements with the Transferees ensuring appropriate and suitable safeguards based on standard contractual terms which are consistent with those adopted by the European Commission. Where we make transfers to Transferees in the US, we may in some cases rely on applicable standard contractual clauses, binding corporate rules, the EU-US Privacy Shield or any other equivalent applicable arrangements.
THE PERSONAL INFORMATION WE HOLD ABOUT YOU
For further information about any rights that might be available to you in relation to the personal information we hold about you, please refer to our website.
We are constantly striving to improve functionality on this site through technology changes. This may mean a change to the way in which personal information is collected or used. The impact of any technology changes which may affect your privacy will be notified in this privacy notice at the time of the change.
LINKS TO THIRD PARTY WEBSITES
Our websites or our apps may have links to external third party websites. Please note, however, that third party websites are not covered by this privacy notice and those sites are not subject to our privacy standards and procedures. Please check with each third party as to their privacy practices and procedures.
WHAT IF YOU HAVE A COMPLAINT?
If you have a concern about any aspect of our privacy practices, you can make a complaint. This will be acted upon promptly. To make a complaint, please contact us via one of the methods set below. If you are not satisfied with our response to your complaint, you have the right to lodge a complaint with our supervisory authority, the Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
HOW TO CONTACT US
If you have any questions about this privacy notice or want to exercise your rights, please contact us by: