Key to Markets is a provider of an online trading platform to trade CFDs on currencies and commodities. KTM is headquartered in the UK and has offices, partners, and affiliates in other jurisdictions. For more information please see our website keytomarkets.com.
INFORMATION WE MAY COLLECT
When you apply for or maintain a demo or live account through Key to Markets (“KTM”) we need to collect information from you (“Personal Data”) for business purposes. The Personal Data we collect from you will also allow us to treat you (i.e. our customer) fairly, such as understand your financial needs and/or investment prospectus so that we can provide you the products and services that are suitable for you, process your requests as well as provide you with sales and post sales services.
The Personal Data that we collect from you includes:
- Personal information you provide to us on applications and other forms, such as your name, address, date of birth and occupation;
- Financial information such as income, assets and your financial investment experience;
- Documents that you provide to us to verify your identity, such as your passport, national id card, utility bills, and/or bank statement or your company incorporation details.
We will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect vital interests.
Automatically Collected Data
Cookies are small pieces of information sent by a web server to store on a web browser so it can later be read back from that web browser. Cookies may be used on some pages of the Site for us to provide website users a more customised web browsing experience. Cookies are not used to determine the personal identity of anyone merely visiting the Site. If you do not wish to receive cookies, most web browsers will permit you to decline cookies and in most cases will still allow you fully browse our Site.
WHY WE PROCESS YOUR PERSONAL INFORMATION
We may be required to retain, process and use your personal information on one or more legal grounds: (i) the processing is necessary for the performance of the agreement between you and us; (ii) to comply with our legal or regulatory obligations or; (iii) the processing is necessary for our legitimate interests or the legitimate interests of a third party that receives your personal data, provided that such interests are not overridden by your interests or fundamental rights and freedom.
Disclosure of Personal information
We may disclose your personal information to the following categories of recipients:
- our KTM Group: we may make personal information available to any member of our group, which means any subsidiary company or holding company, and/or any subsidiary company of such holding company (the Group). This may be necessary to provide you with or administer our products, services, customer and technical support. All of our employees and contractors are required to follow our privacy and security policies when handling personal data.
- Third party service providers: We may share your personal information with our third party service providers so that they can support our products and services, such as system and platform maintenance services, conducting customer due diligence or credit checks, collecting customer feedback, marketing and advertising services, and data analytics and search engine services. Our third party service providers are permitted to use your personal information only for the purpose of providing services to us and may not otherwise share or use your personal information.
- Fraud prevention and credit reference agencies: We may share your personal information with our third party service providers to conduct anti-money laundering, fraud, sanctions, credit risk and customer due diligence checks, credit reference checks and fraud prevention checks.
- Introducers and advisers: We may disclose your personal information to an introducer if they directed you to us.
- Courts, regulators and law enforcement agencies: We will share your personal information when we believe it is required to comply with applicable legal or regulatory obligations and to respond to requests from government authorities, including law enforcement or financial regulators. This may include authorities outside your country of residence.
- Other third parties: We may share personal information 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 If you have questions about or need further information concerning the lawful basis on which we collect and use your personal information, please contact us at email@example.com.
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. In particular, we:
- Hold personal information in secure facilities and where the information is held electronically, on secure servers.
- Use other safeguards such as firewalls, authentication systems (e.g., passwords), and access control mechanisms to control unauthorised access to systems and data.
- Regularly review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
- Restrict access to personal information to our employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations.
INTERNATIONAL DATA TRANSFERS
Your personal information will be retained for as long as required to fulfil the purposes for which we collected it, including any legal, regulatory, business or reporting requirements. When deciding the length of the retention period we take into consideration applicable law, regulation, our agreement with you, and the expectations and requirements .
YOUR RIGHT OF ACCESS TO YOUR PERSONAL INFORMATION
Subject to certain legal conditions, you have certain rights in relation to your personal information which include:
- Right to obtain a copy of your personal information. You have the right to obtain a copy of the personal information we hold about you.
- Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal information. We will then correct out records, and notify any third parties to whom such personal information may have been transmitted as described above.
- Right to erasure. You also have the right to request us to delete your personal information unless we are required to hold it for legal or regulatory reasons or our own internal compliance requirements.
- Right to object to processing. You may request that we stop processing your personal information. Please note you may not be able to benefit from certain service features for which the processing of your personal information is essential.
If you wish to exercise any of these rights, please contact us by email at firstname.lastname@example.org
We will generally respond to any requests within twenty-eight days of receipt. We will not usually charge you a fee for a request, However, we may charge a reasonable fee if your request is clearly unfounded or excessive.
Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website for instructions.