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PRIVACY POLICY

BCP Technologies Ltd (BCP Markets) Private Policy

Introduction

BCP Technologies Ltd’s (“BCP Markets”) Data Policy (“Policy”) outlines the processes and approaches in relation to the collection, usage and processing of information and data, for the purposes of building, supporting and enhancing its platform and features. To provide these services, we are required to process such information about you.

Please read our terms of service thoroughly. By registering an account through our application or website, using any of our services, the BCP Markets App or our website, you agree to be legally bound by our terms of service and all the terms incorporated by reference.

Definition and Scope
The Data We May Collect
How is your Personal Data collected?
How we use your Personal Data
Disclosure of your Personal Data
International Transfer
Data Security
Data Retention
Your Legal Rights
Generally

1. Definition and Scope

Purpose of this Policy

Our Policy aims to give you information on how we collect and process your personal data through our website www.bcpmarkets.co.uk (“our website”) and our iOS and Android mobile applications (“BCP Markets App”). This includes any data you use to provide, submit or upload through the Site and the BCP Markets App website when you purchase our Services, sign up to our mailing list or take part in a competition or other promotion that we hold or manage.

Our Services are not intended for children and we do not knowingly collect data from them.

This Policy is to be read together with any other data policy, privacy or fair usage data processing policy that we may provide on any specific occasions when we collect or processing personal data about you.

This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

Data Controller

BCP Technologies Limited is the data controller and responsible for your personal data.

If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact Details

BCP Technologies Ltd

Email Address: info[at]bcpmarkets.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office the UK supervisory authority for data protection issues (http://ww.ico.org.uk). We would, however, appreciate the opportunity to address your concerns before so please contact us in the first instance.

Changes to the Policy and your Duty to Inform us of changes.

The Policy may be reviewed and altered from time to time. This version was last updated on 24th August 2022.

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with Us.

Scope

This Policy applies to you during the course and provision of our services, including through our Website and App.

Third Party links

Our Site and App may include links to third-party websites, plug-ins and apps. Clicking on these links or enabling these 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 conduct or privacy statements. When you leave our site via a link to a third-party website, app or platform, you should review its privacy policy.

2. The Data We May Collect

“Personal data” and/or “personal information” means any information about an individual from which that person can be identified. This does not include data where the identity has been anonymised or removed.

We may collect, use, store and transmit different types of personal data about you which we have been categories together under the following:

Identity Data includes first name, last name, username or a similar identifier, title, date of birth and gender.
Contact Data includes billing address, email address and telephone numbers.
Financial Data includes bank accounts’ and payment cards’ details.
Transaction Data includes details about payments to and from you and other details concerning the good and services you may have purchased or acquired from us.
Technical Data includes Internet Protocol (“IP”) addresses, your login and usage data, browser type and version details, time zone setting and geolocation data, browser plug-in types and versions, operating system and platforms, and other technologies on the devices you use may have, contain or use to access this website.
Profile Data includes your username and password, your purchases or orders, your interests, preferences, settings, feedback and survey responses.
Usage Data includes information about how you use our website, App and Services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may 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 may 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 and App 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 transformed data as personal data which will be used in accordance with this Policy.

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.

If you fail to provide your Personal Data collected.

Where we need to collect personal data by law, or under the terms of a contract we have with your, and you fail to provide that data when requested, We may be unable to perform the contract that we have or are trying into with you. We may have to cancel our provision of the Services to you.

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 information: Identity, contact and financial data by filling in forms, scanning documentation (IDs, Passport, Driving License) through the App or by corresponding with us through methods of communication (such as by the post, email). This includes personal data you provide when you:

Apply for the Services;
Exceed a top-up limit;
Create an account on our Site and App;
Subscribe, use or purchase to our Goods and Service and publications;
Request marketing information to be sent to you;
Enter a competition, promotion or survey; or
Give us feedback or contact us.
Automated technologies or interactions. As you interact with our Site and App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if You visit other websites employing our cookies.
Third parties or data retrieved from publicly available sources. We may receive or collect personal data about You from various third-parties.
Technical Data from the following parties:

(a) analytics providers (such as Google which may store data outside of the EU)

(b) advertising networks located inside or outside the EU

Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.
Identity and Contact Data from data brokers or aggregators based inside or outside the EU.
Identity and Contact Data from publicly available sources, such as Companies House and the Electoral Register based inside or outside the EU.

4. How we use your Personal Data

Under the General Data Protection Regulation (2016/679), BCP Technologies Limited has the “data controller” and you are the “data subject”. We will only use your personal data when the law allows us to. We will ordinarily use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override these interests.
Where we need to comply with a legal obligation.

We generally rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to Your via email or text message. You have the right to withdraw consent to receiving marketing communications at any time by contacting us.

Purposes for which we will use your personal data

General Data Protection Regulation (2016/679) states that data controllers are only able to use personal information if there is a proper reason to do so. This includes sharing your data with third-parties.

We have set out, in a table, the ways that we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

To register you as new customer

(a) Contact

To buy with any amount of £

(a) Contact

(b) Identity

To extend the buying limit above £500

(a) Contact

(b) Identity

Performance of a contract with you

To extend the buying limit above £1,000 per month period

(a) Contact

(b) Identity

(d) Source of funds

Marketing

We will provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Please contact us to access your personal data and amend or withdraw your consent if you no longer with to receive these marketing communications.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (i.e. marketing).

You will receive marketing communications from Us if You have requested information from Us or purchased services from Us and You have opted in to receiving that marketing.

Third-party Marketing

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

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us to change your marketing preferences, by clicking the opt-out links on any marketing communication sent to you by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of purchase of Our Services or other transactions, which may need to be retained for a period of not less than 6 years in order for us to comply with legal and regulatory obligations (the FCA is regulating the Sector since January 2020).

You can set your browser to refuse some or all cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies completely, please note that some parts of our website and/or Services and App may become inaccessible or not function properly.

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 the original reason is compatible with the original purpose. If you wish to obtain 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.

In order to comply with legal or regulatory obligations, requirements and rulings, we may process Your personal data without your knowledge or consent.

5. Disclosures of your Personal Data

We may share Your personal data (except your Identification documents) with the parties set out below for the purposes set out in the table above.

Internal Third-Parties
External Third-Parties
Third-parties to whom we may choose to sell, transfer or merge parts of Our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

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.

6. International Transfers

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, We may transfer data to them if they are part of the Privacy Shield programme which requires them to provide similar protection to personal data shared between the European Union and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when we transfer your personal data outside the EEA.

7. Data Security

Data Security is very important to us, and we have in place suitable electronic, physical and managerial security procedures in place to safeguard and secure your personal data. These procedures allow us to protect, to the furthest extent, your collected data via our website and App from being accidentally lost, used or accessed in an unauthorised way, or from being altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third- parties on a who have a business “need to know” basis. They will only process your personal data in accordance to on our instructions and they are subject to a strict duty of confidentiality.

We also have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of any such breach = where we are legally required to do so. If password access is required for the App or on certain parts of the website, you are

responsible for keeping this password confidential. You must not share your password with anyone else, nor store it in an insecure location.

We will do our best to protect your Personal Data, but transmission of information over the Internet may not be secure and can be intercepted, and is done so at your own risk. We are unable to cannot ensure absolute the security of your Data transmitted to the website or through the App.

8. Data Retention

How long will you use my data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, 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 stemming from unauthorised 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.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.

In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

[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].

If you wish to exercise any of the rights set out above, please contact our data privacy manager at info@bcpmarkets.co.uk

No fees charged for Standard Access Requested

You will generally not be required 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(s) in such circumstances.

What we may require in orders to Process such a request

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 an unrelated or unauthorised person. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Frame for Responding

We will generally respond to all legitimate requests within one month. I Occasionally, it may take us longer than one month if your request is particularly complex, you have failed to provide the requested supplemental documentation (used for verifying your identity) or if you have made a number of requests. In cases of such delay, we will notify you and keep you updated.

10. Generally

Your rights under this Policy may not be transferred to any other person. We may transfer our rights under this Policy where we believe your rights will not be affected.

Changes to the Policy

This Policy may be changed or altered as we may deem necessary from time to time or as may be required by law. The most current version will be posted on our website and you are deemed to have accepted the terms of the privacy policy on your first use or on subsequent accesses.

11. Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We will endeavour We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data in connecting with our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how We assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

Service providers:
Professional advisors (acting as processors or joint controllers) including but is not limited to lawyers, bankers, auditors and insurers, who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances, and,
Other third-parties such as but is not limited to Market Researchers and Fraud prevention agencies.

Your Legal Rights

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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.