Introduction

Welcome to Bequant's privacy policy.

This policy is issued by Bequant Prime Ltd operating under a trading name of Bequant Global (on behalf of their, branches, their subsidiaries and their affiliates (where applicable)), identified as controllers or processors in the tables in Section 1 below (together, “Bequant”, “we”, “us” or “our”). Bequant respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Bequant collects and processes your personal data through your use of this website, including any data you may provide through this website when you register/open an account with Bequant Prime Ltd respectively.

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.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

For the purposes of this Policy, the relevant controllers are:

For the purposes of this Policy, the relevant processor is:

Contact details

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise any legal rights, please contact the data privacy manager using the details set out below.

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

• Full name of legal entity: Bequant Servicing Limited
• Email address: [email protected]
• Postal address: 71-75, Shelton Street, Covent Garden, London, WC2H 9JQ, UK

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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 also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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. The data we collect about you

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.
• Automated technologies or interactions collect Technical Data about you. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

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 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; or
• for 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.

Marketing

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.

Opting out

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 data

We may share your personal data in the following circumstances:

• such 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; and
• courts, 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.

Any data sent out of the relevant jurisdiction, shall be sent to a jurisdiction with valid and enforceable data protection laws or regulations.

6. 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.

7. 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.

8. 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:

• 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.
• 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.
• 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.
• 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.
• 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.
• 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.
• 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.

Contact

If you have any questions or concerns, please contact our data privacy manager by emailing [email protected].

9. Glossary

“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 the Seychelles 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 August 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.