This privacy policy applies to the processing activities of GHF (as defined below). As part of our day-to-day business we need to collect personal information from our customers and potential customers to ensure that we can meet their needs and provide them with information about our services. Your privacy is important to us and it is our policy to respect the confidentiality of information and the privacy of individuals.
This policy outlines how we manage your personal information supplied to us by you or a third party in connection with our provision of services to you or which we collect from your use of our services and/or website(s). It also details your rights in respect of our processing of your personal information. Our privacy policy will be reviewed from time to time to take account of new obligations and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment.
Any personal information we hold will be governed by our most current privacy notice.
The three regulated entities within the GHF Group are:
(together “GHF”).
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.
If you are an actual or potential customer, we may collect the following types of information about you:
We obtain this information in a number of ways through your use of our services or other dealings with us including through any of the GHF websites, the customer on-boarding process, marketing sign up forms, subscribing to news updates and from information provided in the course of ongoing customer service correspondence. We may also obtain personal information about you through your use of our websites or through the use of cookies on our websites and, in particular by recording which pages you look at on our websites.
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.
As part of using your personal information for the purposes set out above, we may disclose your information to:
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 all relevant data protection laws and this privacy notice.
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.
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 disciplinary 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.
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:
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.
We may use personal information for the following purposes:
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 have the right to ask us to provide you with a copy of any personal data that we hold. You may make a data subject access request (“DSAR”) to us via one of the methods described below in the How to Contact Us section. The standard time for our response is one month from receipt of the DSAR unless the case proves to be complex or you make multiple requests, in which case this may be extended by a further two months. Should this prove to be the case, we will notify you within the month and explain why it may take longer.
Initially we will confirm whether we process your personal data. If we do, we shall provide a copy of that personal data and any relevant supplementary information, such as the purposes of processing, recipients of the data and any rights you have to manage your data held by us.
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.
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 Data Privacy Framework (UK Extension)or any other equivalent applicable arrangements.
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.
A cookie is a small piece of text stored on your computer or device when you visit a website. We use cookies on our websites to provide you with a more relevant and effective experience, including presenting web pages according to your needs or preferences. For further information about cookies and how we use cookies, 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.
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.
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.
If you have any questions about this privacy notice or want to exercise your rights, please contact us by:
