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This Privacy Policy sets out how we, Hackwac, collect, store and use information about you when you use or interact with our website, https://hackwac.com/ (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 1st October 2022.
For ease of reference, this Privacy Policy is divided in two: a summary privacy policy and the full privacy policy.
If you have any questions about our Privacy Policy, please contact us by sending an email to [email protected].
This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
Data controller: FX Technology Limited.
How we collect or obtain information about you:when you provide it to us (e.g. by contacting us, subscribing for our newsletter or placing an order on our website),from your use of our website, using cookies, and occasionally, from third parties.
Information we collect: name, contact details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable), and VAT number (if applicable).
How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to advertise our goods and services, to analyse your use of our website, and in connection with our legal rights and obligations.
Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, and where required by law or to enforce our legal rights.
Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No
How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.
Use of cookies: we use cookies on our website including essential, functional and analytical cookies. For more information, please visit our cookies policy
Transfers of your information outside the European Economic Area: in certain circumstances we transfer your information outside of the European Economic Area, including to the United States of America. When we do so, we will ensure appropriate safeguards are in place, including, for example, that the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield.
Your rights in relation to your information:
Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.
Data controller
The data controller in respect of our website is Hackwac, a brand of FX Technology Limited – registered in England and Wales No. 11602958. The office of which is at FX Technology Limited, 2 Stone Buildings, Lincoln’s Inn, London, England, WC2A 3TH.
You can contact the data controller by writing to FX Technology Limited or Hackwac, FX Technology Limited, North west House, 119 Marylebone Road, London, United Kingdom, NW1 5PU or sending an email to [email protected]. If you have any questions about this Privacy Policy, please contact the data controller.
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
Web server log information
We use a third party server to host our website. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.
Our server is located in the United Kingdom.
Use of website server log information for IT security purposes
Our third party hosting provider stores server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our website server provider to make any attempt to identify you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.
Cookies
Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
We use cookies, including essential, functional and analytical cookies. For further information on how we use cookies, please see our cookies policy.
You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings and other ways in which you can reject cookies, please visit www.allaboutcookies.org or see our cookies policy.
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you send an email to the email address displayed on our website, we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Transfer and storage of your information
We use a third party email provider to store emails you send us. Our third party email provider is based in the United States of America.
Emails you send us will be stored outside the European Economic Area on our third party email provider’s servers in the United States of America. For further information and safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.
Contact form
When you contact us using our contact form or via [email protected], we collect the following information: your name, email address and any information you include in the message field. We also collect your company name if you provide it.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Transfer and storage of your information
Messages you send us via our contact form will be stored on our web servers in the UK and also transferred to our email provider’s servers outside the European Economic Area.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Phone
When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us. We do not record phone calls.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Transfer and storage of your information: Information about your call, such as your phone number and the date and time of your call, is processed by our third party telephone service provider and stored in the United Kingdom.
Post
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Transfer and storage of your information
Information you send us by post is stored in the United Kingdom.
We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
E-Newsletter
When you sign up for our e-newsletter to receive news and offers about our products and services on our website we collect your email address.
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.
Transfer and storage of your information
We use a third party service to send out our e-newsletter and administer our mailing list, called MailChimp and Campaign Manager. You can access their privacy policy here.
Information you submit to subscribe for our newsletter will be stored outside the European Economic Area on MailChimp’s servers in the United States of America. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Registering on our website
When you register and create an account on our website (at checkout), we collect the following information: your name, company name (if applicable), your address (including country, street address, town/city and postcode), phone number, email address and password (we do not view your password).
If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: registering and administering accounts on our website to provide you access to content and updates you have purchased and facilitate the efficient running and operation of our business.
Transfer and storage of your information
Information you submit to us via the registration form on our website will be stored within the European Economic Area on our third party hosting provider’s servers in the United Kingdom.
We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information
Information we collect when you place an order
When you place an order for goods or services on our website, we collect the following mandatory information: name, email address, phone number, billing address, company name (if applicable), VAT number (if applicable) and account password (if you create an account).
If you do not provide this information, we will not be able to purchase goods or services from us on our website or enter into a contract with us.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: other than phone number and password, we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: other than phone number and password, we have a legal obligation to issue you with an invoice for the goods and services you purchased from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose.
Legal basis for processing: we collect your phone number and password in our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s):
We collect your password for our legitimate interests in: (i) registering and administering accounts on our website to provide you access to content and updates you have purchased; and (ii) to facilitate the efficient running and operation of our business.
We collect your phone number for our legitimate interest of more easily and effectively contacting you in relation to your order and your account.
Marketing communications
At checkout you will have the option of receiving marketing communications from us.
Offers relating to our goods and services
You can opt in to receiving marketing communications from us in relation to our news and events by email by ticking the box ‘I would like to receive the latest news from Hackwac by email’.
We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.
Transfer and storage of your information
We use a third party service to send out our e-newsletter and administer our mailing list, called Campaign Manager. You can access their privacy policy here.
Information you submit to subscribe for our newsletter will be stored outside the European Economic Area on Campaign Monitor’s servers in the United States of America. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Processing your payment
After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use a number of third party payment processors, including PayPal and Stripe. Your payment will be processed by the payment provider you choose to process your payment via a payment gateway.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.
Third party payment processors
The third party payment processors we use all collect, use and process your information, including payment information, in accordance with their privacy policies. You can access their privacy policies via the following links:
We use WooCommerce as the ecommerce platform for processing orders on our website. When you place orders on our website, your information will be processed by WooCommerce. WooCommerce does not collect any information about you when it processes your order on our site. WooCommerce is owned by Automattic and you can access their privacy policy here.
Transfer and storage of your information
Stripe is based in the United States of America. Information relating to Stripe’s processing of your payment may be transferred outside the European Economic Area to the United States of America. Stripe has self-certified itself with the EU-U.S. Privacy Shield for the purpose of such transfers.
PayPal may transfer information relating to your transaction and the processing of your transaction outside the European Economic Area. Where they do so, they will put appropriate safeguards in place.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
This section sets out how we obtain or collect information about you from third parties.
Information received from third parties
Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include other businesses and clients we work with from time to time who may recommend our services to you. These could be businesses in any industry, sector, sub-sector or location.
It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass your information on to us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a subcontract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
Information obtained by us from third parties
In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one). We may do this, for example, if we have insufficient information to be able to contact you or to better understand your business.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.
For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.
This section sets out the circumstances in which we will disclose information about you to third parties and any additional purposes for which we use your information.
Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:
Apart from our email provider and our mailing list provider, which are located in the United States of America, our service providers are located in the United Kingdom.
Your information will be shared with these service providers only where necessary to enable us to run our business.
Disclosure of your information for legal reasons
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that a fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements
We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering matters.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.
Disclosure of your information to third parties
We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to Google Inc.
Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the partners page of Google’s privacy policy.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service and allowing the Google Analytics to work on our website.
You can opt out of Google Analytics by installing the browser plugin here.
Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.
Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business partners, independent contractors, and insurers.
Further information on each of these third parties is set out below.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.
Accountants
We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.
Our accountants are located in the United Kingdom.
Advisors
Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and other specialists. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.
Our advisors are located in the United Kingdom.
Affiliates
Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their websites, for example. Our affiliates can be in in any industry, sector or sub-sector. Affiliates will share information with us and we will share information with them where you have expressed an interest in our products or services.
Our affiliates are located in the United Kingdom.
Business partners
Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.
Our business partners are located in the United Kingdom.
Independent contractors
Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them perform in relation to our business.
Our independent contractors are located in the United Kingdom.
Insurers
We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.
Our insurers are located in the United Kingdom.
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Specific retention periods
Order information: when you place an order for goods and services, we retain that information for a minimum period of six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes under paragraph 6, Schedule 11 of the Value Added Tax Act 1994.
Correspondence and enquiries: when you make an enquiry or contact us by email or via our contact form, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 6 further month(s), after which point we will delete your information.
Mailing list: we retain the information you used to sign up for our newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our newsletter service, whichever occurs first.
Criteria for determining retention periods
Mesures taken to secure your information
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
Transmission of information to use by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below.
We will also transfer your information outside the EEA or to an international organisation in the unlikely event that we are required to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers.
Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our third party email provider has self-certified its compliance with the EU-U.S. Privacy Shield which is available here. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here.
Contact form
Information you submit via our contact form is stored on our server in the United Kingdom but is also forwarded to our email address and transferred outside the European Economic Area. For more information, please see ‘Email’ immediately above.
E-Newsletter
Information you submit to us when you sign up for our newsletter (your email address) is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is MailChimp. You can access their privacy policy here
Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: MailChimp has self-certified its compliance with the EU-U.S. Privacy Shield which is available here. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here.
Payment processing
When you pay for goods and services on your site, if you select Stripe or PayPal, information about your order and the processing of your order may be transferred outside the European Economic Area.
Stripe: Information processed by Stripe is transferred outside the EEA and stored on Stripe’s servers. You can access Stripe’s privacy policy here
Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Stripe has self-certified its compliance with the EU-U.S. Privacy Shield which is available here. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here.
PayPal: PayPal may transfer information they process about your order outside the EEA. Where they do so, they will ensure appropriate safeguards are in place.
You can access PayPal’s privacy policy here.
Your rights
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to FX Technology Limited or Hackwac, FX Technology Limited, North west House, 119 Marylebone Road, London, United Kingdom, NW1 5PU or sending an email to [email protected]:
to request access to your information and information related to our use and processing of your information;
to request the correction or deletion of your information;
to request that we restrict our use of your information;
to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information); and
to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here.
Further information about your rights
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here.
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
Your rights to object
You have the following rights in relation to your information, which you may exercise by writing to FX Technology Limited or Hackwac, FX Technology Limited, North west House, 119 Marylebone Road, London, United Kingdom, NW1 5PU or sending an email to [email protected]:
to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
sending an email to [email protected] asking that we stop sending you marketing communications or by including the words “OPT OUT”.
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy.
What is ‘Sensitive Personal Information’
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
Our policy on Sensitive Personal Information
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
Children’s privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to [email protected].
California Do Not Track Disclosures
“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org
At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other cookies to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to block and opt out from tracking technologies used on our website, see our cookies policy.
Copyright
The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.
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