(GDPR and DPA 2018) (UK)
Consent: the agreement referred to in the Privacy Notice on the website.
Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the GDPR. We are the Controller of all Personal Data relating to our website users.
Data Subject: a living, identified or identifiable individual user of our website about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.
Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business change programmes involving the Processing of Personal Data.
Data Protection Officer (DPO): the person required to be appointed in specific circumstances under the GDPR. Where a DPO has not been appointed, this term means a data protection manager or other voluntary appointment of a DPO or refers to the Company data privacy team with responsibility for data protection compliance.
EEA: the countries in the EU, and Iceland, Liechtenstein and Norway.
General Data Protection Regulation (GDPR): the General Data ProtectionRegulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the GDPR.
Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data excludes anonymous data or data that has had the identity of an individual permanently removed. Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the GDPR.
Privacy Notice: any notice setting out information that may be provided to Data Subjects using the website when the Company collects information about them.
Processing or Process: any activity that involves the use of Personal Data.
Related Policies: the Company's policies, operating procedures or processes related to this Privacy Standard and designed to protect Personal Data from time to time
This Privacy Standard sets out how DIGITAL DEBT CAPITAL MARKETS LIMITED ("we", "our", "us", "the Company") handle the Personal Data of persons who use our website (‘website users’ ‘you’ or ‘your’).
This Privacy Standard applies to all website users’ Personal Data that we Process regardless of the media on which that data is stored or whether it relates to past or present website users.
Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times.
Please contact us with any questions about the operation of this Privacy Standard
PERSONAL DATA PROTECTION PRINCIPLES
We adhere to the principles relating to Processing of Personal Data set out in the GDPR which require Personal Data to be:
(a)Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency);
(b)collected only for specified, explicit and legitimate purposes (Purpose Limitation);
(c)relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation);
(e)not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation);
(f)Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality);
(g)not transferred to another country without appropriate safeguards being in place (Transfer Limitation); and
(h)made available to Data Subjects and allow Data Subjects to exercise certain rights in relation to their Personal Data (Data Subject's Rights and Requests).\ We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).
A Controller must only process Personal Data on the basis of one or more of the lawful bases set out in the GDPR. These include Consent.
By submitting Personal Data to the website, the Data Subject consents to Processing of their Personal Data. The consent may be withdrawn by contacting us
The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires that data to be kept for a minimum time.
PROTECTING PERSONAL DATA
We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks. We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data, protecting the confidentiality, integrity and availability of the Personal Data
DATA SUBJECT'S RIGHTS AND REQUESTS
Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:
(a)withdraw Consent to Processing at any time;
(b)request access to their Personal Data that we hold;
(c)prevent our use of their Personal Data for direct marketing purposes;
(d)ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;
(e)prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else; and
(f)make a complaint to the supervisory authority.
We will implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles.
We will keep and maintain accurate records reflecting our Processing.
PRIVACY BY DESIGN AND DATA PROTECTION IMPACT ASSESSMENT (DPIA)
To the extent necessary, we will implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures in an effective manner, to ensure compliance with data privacy principles.
We may be subject to certain rules and privacy laws when marketing to website users.
A Data Subject's objection to direct marketing will be promptly honoured.
SHARING PERSONAL DATA
Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.
We will only share Personal Data we hold with third parties if:
(a)they have a legitimate need to know the information;
(b)sharing the Personal Data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject's Consent has been obtained;
(c)the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place; and
(d)the transfer complies with any applicable cross-border transfer restrictions.
CHANGES TO THIS PRIVACY STANDARD
We keep this Privacy Standard under regular review. This version was last updated on July 20 2019.
Digital Debt Capital Markets Ltd (FRN: 944793, Registered Address: 42 Mincing Lane, London, EC3R 7AE) is an Appointed Representative of MJ Hudson Advisers Limited, an entity who is authorised and regulated by the Financial Conduct Authority (FRN: 692447; Registered Address: 1 Frederick’s Place, London, EC2R 8AE).
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