1. Important information and who we are
This website is not intended for individuals under the age of 18 years old and we do not knowingly collect data relating to such individuals.
For the purposes of this Policy, the relevant controllers are:
|Controller entity||Business address|
|Bequant Pro Limited Company Registration Number: C 88065||6, Villa Gauci, Mdina Road, Balzan BZN 9031, Malta|
For the purposes of this Policy, the relevant processor is:
|Processing entity||Business address|
|Bequant Servicing Limited Company number: 11518450||99a Mews Street, St Katharine Docks, London, United Kingdom, E1W 1BD|
Full name of legal entity: Bequant Servicing Limited
Email address: [email protected]
Postal address: 99a Mews Street, St Katharine Docks, London, United Kingdom, E1W 1BD
Telephone number: +442038933214
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
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 as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Formal Identification Information: Government issued identity document such as Passport, Driver's License, National Identity Card, State ID Card, Tax ID number, passport number, driver's license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.
Institutional Information: Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Sensitive Personal Data about you. Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:Direct interactions where we collect: if you register to become a client of our services; if you send us a message through our services or correspond with us by telephone, in writing or otherwise; administering and operating your account; as you visit web pages on our website; and from any of your activities in connection with your use of our services.
We may also collect personal information from third parties such as organisations that you have dealings with, regulators, government agencies, credit reporting agencies, publicly available records (including electronic data sources to carry out checks to enable us to comply with applicable law), information or service providers (some of whom may process your personal information on our behalf) and third party platforms that we engage.
We will at all times minimise the collection and use of personal data to what is necessary to administer our business and deliver our services to you. In order to process your requests and transactions we will use the information provided by you. To serve you better, we may combine information you give us through various channels.
4. Why and How we use your personal data
Why we collect your personal data
We do not seek to collect or otherwise Process your Sensitive Personal Data. We will only process your personal data when the law allows us to. Most commonly, we require your personal data in the following circumstances:Processing is necessary for the performance of our services to you under the contract with you or your organisation;Processing is necessary for the purpose of our legitimate interests;the Processing is necessary for compliance with legal and regulatory obligations(e.g., to comply with the AML/KYC and sanction requirements or to comply with our diversity reporting obligations);the Processing is necessary for the detection or prevention of crime (including the prevention of fraud and money laundering) to the extent permitted by applicable law; the Processing is necessary for the establishment, exercise or defense of legal rights;we have, in accordance with applicable law, obtained your prior explicit consent prior to Processing your personal data or Sensitive Personal Data;Processing is necessary for reasons of substantial public interest and occurs on the basis of an applicable law that is proportionate to the aim pursued and provides for suitable and specific measures to safeguard your fundamental rights and interests;to enforce the terms in our user agreement and other agreements. Bequant handles sensitive information, such as your identification and financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our user agreement or other agreements;to enforce the terms in our user agreement and other agreements. Bequant handles sensitive information, such as your identification and financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our user agreement or other agreements;to ensure network and information security. We process your personal data in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations; orfor research and development purposes.
In addition, the processing may be based on your consent where you have expressly given that to us. Although, we do not generally rely on consent as a legal basis for processing your personal data, we will obtain your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Where we rely on legitimate interests as a lawful basis to process your personal data, we will carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways we plan to use your personal data, type of 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||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer, administer your account, provide services to you|
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Record keeping obligations, compliance screening or recording obligations (e.g. for anti-money laundering, financial and credit checks and fraud and crime prevention and detection purposes)
(c) Monitoring and assessing compliance with our internal policies and standards
(d) Monitoring your transactions and use of our services
(e) Asking you to leave a review or take a survey
(f) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To comply with court orders and exercises and/or defend our legal rights|
|To administer and protect our business, our website and security; to manage access to our IT and communication systems, online platforms, websites and other systems (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data); to prevent and detect security threats, fraud or other criminal or malicious activities|
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you|
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you|
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links (“unsubscribe”) on any marketing message sent to you or 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 a product or service purchase, product or service experience or other transactions.
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 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.
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.
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
5. Disclosures of your personal datasuch third parties as we reasonably consider necessary in order to prevent crime, e.g. the police;we are under a legal, regulatory or professional obligation to do so (for example, to comply with anti-money laundering or sanctions requirements);our associated companies for the purpose of administering your trading account and orders, providing trading and/or brokerage services to you;where reasonably necessary, to any third party service providers and specialist advisers who provide us with administrative, technology, financial, research or other services we provide to you;our auditors for the purposes of carrying out financial and regulatory audits;our agents, including credit reference agencies, acting on our behalf, carrying out such credit and identity checks, including money laundering checks, compliance regulatory reporting and fraud prevention checks, as we may reasonably consider necessary or desirable. Any third party referred to in this clause may share any personal information concerning you with us and other organisations involved in credit reference, the prevention of fraud and/or crime and/or money laundering or for similar purposes or to recover debts involved; andcourts, law enforcement authorities, tribunals, regulatory authorities, attorneys or other parties where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim or to comply with the requirements of a court, regulator or government agency;you have consented to us doing so (where necessary) or the organisation that you work for has obtained your consent for us to do so (where necessary);the purchaser or potential purchaser of one or more of our businesses or service lines and their professional advisers;sanctions requirements.
We require all third parties to respect the security of your personal data and to respect your right to privacy and comply with the data protection principles and this policy. We may also instruct third party service providers to process personal data on our behalf and in accordance with our instructions. We will retain control over and will remain fully responsible for your personal data and will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers;
Otherwise, we will only disclose your personal data when you direct us or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.
6. International transfers
We share your personal data within Bequant and its associated companies. This will involve transferring your data outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
•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 ( Adequacy decisions | European Commission ).
•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 ( Standard Contractual Clauses (SCC) | European Commission ).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
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.
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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfill 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 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.
We will only retain your personal information for as long as is necessary for the purpose for which it was collected, including for the purposes of complying with any legal, regulatory, accounting or reporting requirements. In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will 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.
9. Your legal rights
You have certain rights that you can exercise under certain circumstances in relation to the personal information that we hold. You have the right to:
1. 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.
2. 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.
3. 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.
4. 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.
5. 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.
6. 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.
7. 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.
We hope that Bequant’s data privacy manager can resolve any query or concern you raise about our use of your personal information. If you feel we have not handled your query or concern to your satisfaction you can contact the following authorities:
Bequant Servicing Ltd as a processor: the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues at ico.org.uk/concerns or telephone 0303 123 1113.
You will not, in general, have to pay a fee to exercise any of your individual rights set out in this policy. However, should you wish to exercise any of your individual rights, we may not be able to provide services to you and may charge a fee for access to your personal data if the relevant data protection legislation allows us to do so, in which case we will provide reasons for our decision as required by the law.
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
Updating personal data about you
If any of the personal data you have provided to us changes, for example if you changed your email address, or if you become aware that we have any inaccurate personal data about you, please let us know by sending an email to [email protected] We will not be responsible for any losses arising from incomplete, inaccurate, inauthentic or deficient personal data that you have provided to us.
If you have any questions or concerns, please contact our data privacy manager by emailing [email protected]
“Aggregated Data” refers to numerical or non-numerical information that is (1) collected from multiple sources and/or on multiple measures, variables, or individuals and (2) compiled into data summaries or summary reports, typically for the purposes of public reporting or statistical analysis.
“Internal Third Parties” means other companies in the Bequant Group acting as joint controllers or processors and who are based in Malta or in the UK.
“External Third Parties”means:Service providers acting as processors including processing ID verification, regulatory, transaction and sanction monitoring, IT and system administration services and audit services.Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.regulators and other authorities acting as processors who require reporting of processing activities in certain circumstances.Introducing brokers, market makers, clearers, settlement agents, liquidity providers, prime brokers, trading platforms, custodians, or exchanges acting as processors who may provide trading, and settlement services in relation to your transaction.
“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 make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for 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.
“Process” or “Processed” or “Processing” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Sensitive Personal Data”means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, or any other information that may be deemed to be sensitive under applicable law.
“Technical Data” includes the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, your ISP and/or mobile carrier, browser plug-in types and versions, operating system and platform, your location; information about your visits, including the full Uniform Resource Locators (URLs) to, through and from which you access our service (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information, methods used to browse away from the page.
Updates to this Policy
This policy was last updated in June 2022. We reserve the right to update and change this policy from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. In case of any such changes, we will post the updated policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on the website.