CTX Privacy Policy
Effective Date: May 25, 2018

PURPOSE

This Privacy Policy is used to inform you of how and why we obtain, collect, store and transfer your information and how you can access, manage, delete and update that information. A version of this policy is available on our websites.

WHO WE ARE

This Privacy Policy applies to Global Environmental Markets (GEM) and its subsidiary and affiliate companies and their services including but not limited to: GEM Global Pty Ltd, Environmental Market Services Limited (EMS) – trading as Carbon Trade Exchange (CTX). When we refer to the following terms (‘we’ or ‘our’ or ‘us’) that means the above-mentioned companies.

JURISDICTION

This Privacy Policy has been implemented to comply with the following regulation:

Regulation (EU) 2016/679 the (European Union) General Data Protection Regulation (GDPR)

The GDPR is effective as of 25 May 2018. 

LEGAL BASIS FOR COLLECTING AND PROCESSING DATA

We collect and process personal data as we are required to undertake due diligence checks on you and your business.

We are required to comply with the following:

4th Anti-Money Laundering Directive (EU) No. 2015/849 (4th AMLD) European Union

Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (England and Wales)

Anti-Money Laundering and the Counter-Terrorism Financing Act 2006 (Australia)

  1. WHAT INFORMATION DO WE COLLECTWe collect several types of information and data. Unless otherwise stated all the personal data we obtain, has been supplied by you having given your consent.  We use this information to provide you with information, updates, services and for business administrative purposes. We do not sell your information or data to third parties (other than in the course of a business sale, purchase or similar event).

1.1            Personal Information

We collect the following types of information that you supply to us, depending on the type of service you require. The data we collect may include information such as your name, address, email address, contact number, dates of services provided, type of service provided, payment history, manner of payment, amount of payment, domain name, credit card or other payment information. We use Paypal for transactions through the ‘Carbon Widget’. to see their Privacy Policy please go to Paypal Privacy Policy

1.2            Newsletters and Updates

Through our websites, you have the option of receiving updates, newsletters and occasional marketing material from us and relevant third-parties. You can also sign up to receive information by contacting us, or on occasion, passing on your business card or details at events. You will be notified via email of your preferences, and you able to unsubscribe immediately if you choose to do so.

1.3            Cookies and Tracking

We use technologies, like cookies and web beacons, to provide services to you and to analyse how users interact with our website. We use cookies to save your preferences and log in information and to personalise your visit. We may use cookies to collect, store and track interactions with our website for statistical and performance purposes. You can change your browser settings to block and remove cookies, but this may affect the way our website performs on your device. Click here for Cookies information and instructions on how to change your browser settings. Web beacons are used in the emails we send out from our Third-party email provider. Web beacons measure information on how people interact with our emails. This provides us with information on how to create useful and relevant information. We also use Google Analytics to anonymously track traffic statistics from our website. To find out what information Google collects, how it uses and how to control the information sent to Google, see their Privacy Policy. The information collected is used to provide an overview of how people access and use our websites. It is not used for profiling purposes.

1.4            Membership sign up

When signing up for a CTX Trading Account we are required by law to collect personal data on you and your business including but not limited to you, your business partners, directors. This information supplied to us by you can include full legal name, DOB, address, email, contact details, business name and registered address, identification documents, bank account details, IP Address and any other Know Your Client (KYC) information that we are required to collect for the purpose of processing your application.

1.5            Disclosure of your Personal Information

We only disclose your personal information to third-parties only where necessary to run our business, to our service providers eg. Financial institutions, financial software, IT service providers, Telephone providers (when you call us). We will comply with Government agencies and Law enforcement officials and private parties to comply with the law. We will comply with other agencies and governing bodies when we are required by law or to enforce our legal rights.

1.6            Third Party Information supplied to us

Occasionally we must obtain information about you from third-parties. This is only done when we are required by law to complete due diligence checks on you and your business when signing up for a CTX Trading Account. For further information see the CTX Rules supplied to you when activating your account. Occasionally, to verify information we hold about you or obtain missing information, we will obtain information about you from certain publically accessible sources both in the EU and non-EU.

1.7            Transfer and Storage of your Information

We only transfer your data outside the European Economic Area (EEA) to internal companies for administration purposes, for secure data storage, email transmissions, bulk email services and other legitimate business purposes. Where we do transfer and store your data we will ensure appropriate safeguards and protections are in place. Some of the countries that your data is transferred to and stored in include the USA and Australia. The service provider that we have engaged in Australia has adopted the European Union Model Clauses for the transfer of personal data to processors. If you have any concerns or need to see the privacy policy of the services we engage to process and store your data, please contact us at privacy@ctxglobal.com

  1. YOUR RIGHTS REGARDING YOUR INFORMATION

You have the right to:

–                 Access your information and receive information on how it is used

–                 Have your information corrected and/or completed

–                 To have your information deleted (within reason)

–                 To restrict and object to the use and processing of your information

–                 To receive your information in a portable format (within reason)

–                 To withdraw your consent to the use of your information

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. We will use any measure necessary to protect your information, reduce the risk of identity theft and any general unauthorised access to your information.

We will endeavour to fulfil your request to access your data, but under certain circumstances we will be unable to process those requests. These may include nuisance requests, unauthorised requests or if releasing your information may expose another individual’s information.

Sensitive Personal Information

We do not knowingly or intentionally collect ‘sensitive personal information’ which includes information that may identify your racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic information, biometric information, information about sex life, sexual orientation or health. Please do not submit your personal information to us. We will use all reasonable efforts to delete any data that we may have erroneously collected.

  1. DATA SECURITY AND RETENTION

We use multiple security measures to protect your personal data. These include but are not limited to: physical, electronic, internal and external policies and procedures. All personal data is collected and stored on a secure server. Transfer of personal data eg. Using a credit card or Paypal uses Secure Sockets Layer (SSL) technology.

We retain personal data only for as long as necessary to provide the services you have requested. Due to our legal obligations, we may retain your personal data for a longer period. These reasons may include but are not limited to:

–                 Mandated by law

–                 For resolving, defending or enforcing our legal/contractual rights

–                 Needed to maintain financial records

  1. CHANGES

    We may change this Privacy Policy from time to time. The most recent version of this policy is reflected in the version date at the beginning of this policy. All changes are effective immediately unless otherwise stated. We encourage you to review this Privacy Policy page from time to time to ensure you are kept updates on any changes.
  1. AGE RESTRICTIONS

    Our services and the interactions with our websites are not intended to be to be used, nor have they been designed to entice individuals under 18 years old. If you know of or have reason to believe anyone under the age of 18 has provided us with personal data, please contact us. We will use all reasonable efforts to delete any data that we may have erroneously collected on behalf of anyone under 18.
  1. CONTACT US

    If you have any questions or concerns, you can contact us as below
    Carbon Trade Exchange (CTX) London Office
    phone: +44 203 598 5890
    post: 1 Fore Street, London, EC2Y 9DT, UK
    email: privacy@ctxglobal.comWe will respond to your request or concerns within thirty (30) days

Data Protection Authority

If you are a resident of the European Economic Area (EEA) and you have any concerns on how we collect and process your data, you have the right to contact the lead supervisory authority in the EEA

Information Commissioner’s Office

phone: 0303 123 1113

email: accessicoinformation@ico.org.uk

website: https://ico.org.uk/

 

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