PRIVACY POLICY

The protection of privacy and the safeguarding personal information is our highest priority.

Please view the following Privacy Policy which clearly explains how Dowie Investments (UK) Limited, a company registered under the laws or England and Wales with registration number 10225325 and registered address 11th Floor, Broadgate Tower, 20 Primrose Street, London, EC2A 2EW, United Kingdom (“the Company”) collects, processes, stores and protects personal data (as the term is defined in the Data Protection Legislation).

While providing introductory services, the Affiliate will be exposed to End Users’ personal information. The Company will be exposed to personal information of the Affiliate and the End Users during the course of the Agreement. Therefore, the Affiliate hereby confirms that while providing services the Affiliate will strictly comply with the standards set out in this Privacy Policy and the Data Protection Legislation. The Affiliate grants the Company its consent to such collection, processing, storage and use of personal information by the Company as explained below. Please be advised that End User information held by the Company will not be disclosed to the Affiliate, unless required by law.

Terms used but not otherwise defined in this Privacy Policy shall have the same meaning as in the Affiliate Agreement (“Agreement”).

The collection of personal information

The information that the Company collects in relation to the Affiliate includes information required to communicate with and identify the Affiliate. All relevant information is provided by the Affiliate. The Company also collects personal information for the purposes of complying with the applicable laws and regulations. This information may be of certain demographic information about the Affiliate individuals, including identification details such as name and surname, address, email address (or other contact details as applicable), date of birth, proof of identification such as passport or Identification card, banking details and other relevant financial information, domiciliation, education, occupation, communication between the Affiliate and the Company.

The Company collects the necessary information required to open accounts, transact and safeguard End Users’ assets and to provide the End User with the services they require. To this end, the Company gathers information from the End Users and may, in certain circumstances, gather information from relevant banks and/or credit agencies, and/or other sources which help the Company profile the End Users’ requirements and preferences in an effort to provide better services. The Company may run similar checks on the Affiliate, in order to assess the business relationship between the party, service fees and to meet its legal constraints in practicing the referral business. Information on the processing of the End User data may be found in the Privacy Policy on the markets.com website.

We may also use such personal information to enforce the terms of the Agreement and/or in the event this becomes necessary for the purposes of any litigation, action or claim in connection with the Agreement.

For further information on how we use your personal data, please contact Privacy@markets.com.

Use of personal information

The Company uses personal information only as required to provide quality service and security to the Affiliate. This information is used to set up the Affiliate’s account with us, helps improve services, customize browsing experience and enables the Company to inform the Affiliate of additional products, services or promotions and the Affiliate hereby agrees to the use of this data for such purposes by the Company, subject to any preferences that the Affiliate may have expressed. The option to opt out will be included in all relevant communications.

In the event that the Affiliate wishes to not receive information of this nature for any reason, it shall contact the Company at the following address: unsubscribe@markets.com.

Affiliates and Partners

The Company may share information with affiliates in instances where such information is reasonably required by such affiliate for the provision of products or services to the Affiliate. The Company may share information with partners, affiliates and alliances in order to offer additional similar products and services that meet the Affiliate’s needs and which are delivered in a manner that is useful and relevant only where the Affiliate has authorized the Company to do so.

Non-affiliated third parties

The Company does not sell, license, lease or otherwise disclose personal information to third parties, except as described in this policy.

The Company reserves the right to disclose personal information to third parties where required by law, regulatory, law enforcement or other government authority. The Company may also disclose information as necessary to credit reporting or collection agencies as reasonably required in order to provide the services to the Affiliate.

To help the Company improve its services, the Company may engage third parties to help carry out certain internal functions such as Fee processing, support service, introductory satisfaction surveys or other data collection activities relevant to the Company’s business. The Company may share information with other Markets.com Entities (as this term is defined in the Affiliate Agreement) and their respective legal, accounting, tax and financial advisors as reasonably required. Use of the shared information is strictly limited to the performance of the above and is not permitted for any other purpose. All third parties with which the Company shares personal information are required to protect such personal information in accordance with all relevant legislation and in a manner similar to the way the Company protects the same. Processing by our associates, any Markets.com Entities, agents or sub-contractors which we engage is carried out in accordance with this Policy and is subject to appropriate agreements and arrangements to ensure data protection and compliance with the relevant Data Protection Legislation. The Company will not share personal information with third parties which it considers will not afford the required level of protection.

Where the Affiliate has been referred to the Company by another Affiliate (“Master Affiliate”), such Master Affiliate may have access to the Affiliate’s information. The Affiliate hereby unambiguously and unequivocally consents to the sharing of information with such Master Affiliate.

The Affiliate acknowledges that in order to provide services to the Company, it may be necessary for information to be transferred outside of the European Economic Area or any other jurisdiction the Company or the Affiliate act in, and the Affiliate consents to such transfer. Such transfers shall be carried out in accordance with the Data Protection Legislation and we shall take measures to provide an appropriate level of data privacy protection.

We may share your personal information with third parties when we believe it is required to do so for legal and regulatory reasons, including but not limited to:
  1. To comply with our legal or regulatory obligations and respond to requests from government agencies, including law enforcement and other public or regulatory authorities, which may include such authorities outside your country of residence; and
  2. In the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); and
  3. To protect our rights, customers, systems, and Platforms.

How long we retain personal data

Once your Agreement with us terminates, we shall keep your Personal Data provided to us, including but not limited to your name, address, email, phone number, verification details, communications etc for a period of five years for compliance with our legal and regulatory obligations. Where we keep personal data for marketing purposes based on consent, we shall retain that data until your consent is withdrawn or ceases to be valid.

However, depending on your country of residence and/or citizenship, there may be different statutes of limitation in force. A “statute of limitations” is a statute prescribing a period of limitation for the bringing of actions or claims of certain kinds, which means that, depending on the jurisdiction, you have the right to bring a claim against the Company in connection with your agreement with the Company only during a certain period of time (the “Limitation Time”). We have a legitimate interest in retaining your personal information in order to enable us to defend ourselves against any such claim that you may have. Accordingly, such personal information shall be retained by us after the date of expiration or termination of the Agreement during the Limitation Time.

Restriction of responsibility

The Company is not responsible for the privacy policies or the content of the websites nor other marketing material the Affiliate may publish from time to time. The Company has no control of the use or protection of information provided by the Affiliate or the End User or collected from them by those websites. Whenever the Affiliate elects to link to a co-branded website or to a linked website, it may be asked to provide registration or other information. Please note that such information is recorded by a third party and will be governed by the privacy policy of that third party.

Your Rights under the Data Protection Legislation

As a data subject you have certain rights which are detailed below. Some of these only apply under specific circumstances and are qualified in several respects by exemptions in accordance with the Data Protection Legislation. We will advise you in our response to your request if we are relying on any such exemptions.
  1. Access to Personal Data: You have a right to request a copy of the personal information that we hold about you.
    You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request. Your request will be dealt with as soon as possible.
  2. Correction of Personal Data: You can request us to rectify and correct any Personal Data that we are processing about you which is incorrect.
  3. Right to withdraw consent: Where we have relied upon your consent to process your Personal Data, you have the right to withdraw that consent.
    To opt out of email marketing, you can use the unsubscribe link found in the marketing communication you receive from us. Alternatively, you can send us a message to unsubscribe@markets.com or send a letter to our offices in in London at 11th Floor, Broadgate Tower, 20 Primrose Street, London, EC2A 2EW, United Kingdom.
  4. Right of erasure: You can request us to erase your Personal Data where there is no compelling reason to continue processing. This right only applies in certain circumstances, it is not a guaranteed or absolute right (for example, we may retain your data as described above).
  5. Right to data portability: This right allows you to obtain your Personal Data that you have provided to us with your consent, for the fulfillment of the Agreement (contractual obligation) or which was necessary for us to provide you with our products and services in a format which enables you to transfer that Personal Data to another organisation. You may have the right to have your Personal Data transferred by us directly to the other organisation if this is technically feasible.
  6. Right to restrict processing of Personal Data: You have the right in certain circumstances to request that we suspend our processing of your Personal Data. Where we suspend our processing of your Personal Data we will still be permitted to store your Personal Data, but any other processing of this information will require your consent, subject to certain exemptions.
  7. Right to object to processing of Personal Data: You have the right to object to our use of your Personal Data in certain circumstances. However, we may continue to process your Personal Data, despite your objection, where there are compelling legitimate grounds to do so, or we need to process your Personal Data in connection with any legal claims.
  8. Rights relating to automated decision making and profiling: You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. This right means you can request that we involve one of our employees or representatives in the decision-making process. We are satisfied that we do not make automated decisions of this nature.
  9. Right to lodge a complaint: You have the right to lodge a complaint with the Data Protection Authority of your jurisdiction.

If you wish to exercise any of your rights or if you have any concerns about our use of your personal data you can make a complaint to us by contacting us at privacy@markets.com or you can contact our Customer Support Department on our contact us page or via Live Chat . You can also send a letter to our offices in London at the following address: 11th Floor, Broadgate Tower, 20 Primrose Street, London, EC2A 2EW, United Kingdom.

Please note that where you make a request to exercise any of your rights, we will require proof of identification and/or any clarifications that may be deemed necessary.

Use of ‘cookies’

The Company uses cookies to secure the Affiliate activities and to enhance the performance of its websites. Cookies used by the Company do not contain personal information or other sensitive information.

The Company may share web site usage statistics with reputable advertising companies and with its affiliated marketing companies. The information collected by the advertising company does not include personally identifiable information.

To administer and improve the Company’s websites, the Company may use third parties to track and analyze usage and statistical volume information. The third party may use cookies to track behavior and may set cookies on The Company’s behalf. These cookies do not contain any personally identifiable information.

For more information on the cookies we use you may visit our Cookie Policy on our website.

Privacy Policy Updates

From time to time, the Company may update this policy. In the event the Company materially changes this policy including how the Company collects, processes or uses the Affiliate’s personal information, the revised policy will be posted to the Company’s website. The Affiliate agrees to accept posting of a revised policy electronically on the Company’s website as actual notice to the Affiliate of any future updates. Any dispute over this policy is subject to this notice, the Agreement and the Code of Conduct of the Company practice with the Affiliate. The Company encourages the Affiliate to periodically check back and review this policy so that the Affiliate will always know what information the Company collects, how the Company uses it, and to whom, the Company may disclose it.

Agreement

I have read, understood and agree with the terms of this Privacy Policy, and I confirm that I have full power and authority to be bound by the terms of this Privacy Policy.

For any queries or further information in relation to this Privacy Policy please contact us at privacy@markets.com or send a letter to the following address: 1th Floor, Broadgate Tower, 20 Primrose Street, London, EC2A 2EW, United Kingdom.