1.2. NPLM respects your privacy and is committed to protecting your personal Data. This Policy will inform You as to how We look after your personal Data when You contact us, when You do business with us, or when You otherwise engage with us, or We engage with you, including visiting the Website, or making enquiries of us or when We market our goods and services to You and tell You about your privacy rights and how the law protects You.
2. Definitions and Interpretation
In this Policy, the following definitions are used:
|Data:||means, collectively, all information that You submit to NPLM by means of the Website, or any other means. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;|
|Cookies:||means a small text file placed on your computer by the Website when You visit certain parts of the Website and/or when You use certain features of the Website.|
|Data Protection Laws:||means any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national or international implementing laws, regulations and secondary legislation;|
|GDPR:||means the General Data Protection Regulation (EU) 2016/679;|
|UK and EU Cookie Law:||means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;|
|Website:||means the website that You are currently using, http://www.nplmarkets.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions; and|
|You:||means any third party that accesses the Website and is not either (i) employed by NPLM and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to NPLM and accessing the Website in connection with the provision of such services.|
3. Important information and who We are
3.1. Purpose of this Policy
(a) This Policy aims to give You information on how NPLM collects and processes your personal Data when You interact with us, or when We interact with You.
(a) It is important that You read this Policy together with any other Policy or fair processing notice We may provide on specific occasions when We are collecting or processing personal Data about You so that You are fully aware of how and why We are using your Data. This Policy supplements the other notices and is not intended to override them.
(b) This Policy was issued on 05 March 2019.
3.2. Children and minors
NPLM does not knowingly collect or solicit Personal Data from children and minors. Anyone under the age of eighteen (18) will not be knowingly allowed to register for any service on the Website or to purchase any products or service on the Website.
3.3. Data Controller
(a) For purposes of the applicable Data Protection Laws, NPLM is the “Data Controller”. This means that NPLM determines the purposes for which, and the manner in which, your Data is processed, and undertakes to abide by and act in accordance with all relevant Data Protection Laws in such capacity.
(b) We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below:
|Full name of legal entity:||NPLMARKETS LIMITED|
|Name or title of data privacy manager:||Data Protection Officer|
|Postal address:||107-111 Fleet Street, London, Greater London, EC4A 2AB United Kingdom|
|Telephone number||+44 (0) 20 3984 6288|
(c) You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK 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 ICO so please contact us in the first instance.
3.4. Third-party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those 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 privacy statements. When You leave the Website, We encourage You to read the Policy of every website You visit.
4. The Data We collect about You
4.1. 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). We may collect, use, store and transfer different kinds of personal Data about You which We have grouped together follows:
(a) Identity Data includes first name, last name, customer code or identifier, title, date of birth and gender.
(b) Contact Data includes billing address, delivery address, email address and telephone numbers.
(c) Usage Data includes information about how You use the Website, products and services.
(d) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
4.2. We also collect, use and share Aggregated Data such as statistical or demographic Data for any purpose. Aggregated Data may 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 or perhaps buying a certain type of product. 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 Policy.
4.3. 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.
2. How is your personal Data collected?
We use different methods to collect Data from and about You including through:
2.1. Direct interactions. You may give us your Identity and contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal Data You provide when you:
(a) apply for our products or services;
(b) express an interest in our products or services;
(c) create an account with us;
(d) subscribe to any of our services or publications;
(e) request marketing to be sent to you;
(f) complete a survey; or
(g) give us some feedback.
2.2. Third parties or publicly available sources. We may receive personal Data about You from various third parties and public sources as set out below:
(a) Contact Data from providers of technical, payment and delivery services.
(b) Identity and Contact Data from Data brokers or aggregators including business directories.
(c) KYC Data from credit agencies such as processor, paid databases, and other third party providers of analagous services.
(d) Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
3. How We use your personal Data
3.1. We will only use your personal Data when the law allows us to. Most commonly, We will use your personal Data in the following circumstances:
(a) Where We need to perform or manage the contract We are about to enter into or have entered into with You.
(b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
(c) Where We need to comply with a legal or regulatory obligation.
3.2. Generally We do not rely on consent as a legal basis for processing your personal Data other than in relation to sending third party direct marketing communications to You via email or text message or where You are an individual customer and We wish to send You marketing materials. You have the right to withdraw consent to marketing at any time by contacting us.
4. Your consent
4.1. By submitting your information on the Website you consent to the use of that information as set out in this Policy. If we change our Policy, we will post the changes on this page or on the Website, and may place notices on other pages of the Website, so that you may be aware of the Personal Information we collect and how we use it at all times.
4.2. You agree that You do not object to us contacting You for any of the purposes of processing your services or orders, statistical or survey purposes to improve this Website and its services to You, provision of website content and advertisements to You, administration of this Website and where You consent, to notify You of services, products or special offers that may be of interest to You. You consent to such contact whether by telephone, e-mail or in writing and you confirm that You do not and will not consider any of the above as being a breach of any of your rights under any applicable Data Protection Laws.
5. Purposes for which We will use your personal Data
5.1. We have set out below, in a table format, a description of all the ways 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.
5.2. 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
5.3. Data may be used by us for the following reasons:
(a) transmission by email of marketing materials that may be of interest to you;
(b) Registration for upcoming events ;
(c) Registration for our products
in each case, in accordance with this Policy.
5.4. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances, as set out below.
5.5. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:
(a) soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
(b) for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
(c) if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time, as set out below.
5.6. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
5.7. Promotional offers from us
You will receive marketing communications from us if You have requested information from us or purchased goods or services from us and, in each case, You have not opted out of receiving that marketing. We may also contact You if You are a business and You have not asked us not to contact you, and We believe You may be interested in our goods and services.
5.8. Third-party marketing
We will get your express opt-in consent before We share your personal Data with any other company or person.
5.9. Opting out
(a) You can ask us or third parties to stop sending You marketing messages at any time by contacting us at any time.
(b) Where You opt out of receiving these marketing messages, this will not apply to personal Data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
5.10. Change of purpose
(a) 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.
(b) 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.
(c) 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.
6.2. All Cookies used by the Website are used in accordance with current UK and EU Cookie Law.
6.3. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling NPLM to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
6.4. The Website may place the following Cookies:
|Type of Cookie||Purpose|
|Strictly necessary Cookies||These are Cookies that are required for the operation of the Website. They include, for example, Cookies that enable you to log into secure areas of the Website, use a shopping cart or make use of e-billing services.|
|Analytical/performance Cookies||They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily.|
|Functionality Cookies||These are used to recognise you when you return to the Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).|
|Targeting Cookies||These Cookies record your visit to the Website, the pages you have visited and the links you have followed. We will use this information to make the Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.|
6.5. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
6.6. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
6.7. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
6.8. For more information generally on Cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete Cookies from your computer.
10. Disclosures of your personal Data
10.1. We may have to share your personal Data with third parties. These include
(a) Third party providers of Data and other services to us, such as credit agencies, and third party archival, cloud and backup providers.
(b) Third party providers of professional services, such as accountants, bankers, insurers and lawyers.
(c) HM Revenue and Customs, and other regulatory authorities.
10.2. 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.
11. Data security
11.1. We have put in place appropriate security measures to prevent your personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, We limit access to your personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal Data on our instructions and they are subject to a duty of confidentiality.
11.2. We have put in place procedures to deal with any suspected personal Data breach and will notify You and any applicable regulator of a breach where We are legally required to do so.
12. Data retention
How long will You use my personal Data for?
12.1. We will only retain your personal Data for as long as necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
12.2. 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 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 requirements.
12.3. By law We have to keep basic information about our customers (including Contact, Identity and KYC Data) for six years after they cease being customers for tax and accounting purposes.
12.4. In some circumstances You can ask us to delete your Data: see [Request erasure] below for further information.
12.5. In some circumstances We may anonymise 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.
13.1. 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.
13.2. 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.
14. Your Legal Rights
14.1. You have the right to:
(a) Be informed of how your personal Data is being utilised by us, as set out in this Policy.
(b) 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.
(c) 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.
(d) 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.
(e) 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.
(f) 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.
(g) 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.
(h) 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.
14.2. No fee usually required
(a) You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
(b) It is important that the Data We hold about You is accurate and current. Please keep us informed if your Data changes during the period for which We hold it.
15.1. You may not transfer any of your rights under this Policy to any other person. We may transfer our rights under this Policy where We reasonably believe your rights will not be affected.
15.2. If any court or competent authority finds that any provision of this Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Policy will not be affected.
15.3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
15.4. This Policy will be governed by and interpreted according to the law of England and Wales. All disputes arising under this Policy will be subject to the exclusive jurisdiction of the English and Welsh courts.
16. Changes to this Policy
16.1. NPLM reserves the right to change this Policy as We may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and You are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations.
16.2. You may contact NPLM by email at firstname.lastname@example.org .